Interpretation ID: 15309.ztv

Mr. Louis W. Camp
Director
Automotive Safety and Engineering Standards
Environmental and Safety Engineering
Ford Motor Company
330 Town Center Drive
Dearborn, MI 48126

Dear Mr. Camp:

This is in reply to your letter of May 29, 1997, to the Administrator asking that the term "overall width" as used in Federal Motor Vehicle Safety Standard No. 108 be interpreted to exclude running boards. Specifically, Ford Motor Company wishes to equip certain pickup trucks and sport utility vehicles with running boards that are wider than currently offered; however to do so would increase the vehicles' "overall width" from 79.8 inches to 85 inches.

Standard No. 108 requires trucks and multipurpose passenger vehicles which are 80 inches or more in overall width to be equipped with clearance lamps and identification lamps. In 1967, the agency clarified, in Note 1 to Standard No. 108, that

"'Overall width' refers to the nominal design dimension of the widest part of the vehicle, exclusive of signal lamps, marker lamps, outside rearview mirrors, flexible fender extensions, and mud flaps, determine (sic) with doors and windows closed and the wheels in the straight-ahead position."

Although the definition of "overall vehicle width" in 571.3(b), which you quote, is substantively identical, it is the interpretation of Standard No. 108's term "overall width" that is the conformance determinant at issue.

You call our attention to the fact that "outside door handles" have also been excluded from the definition through a letter of interpretation to Iveco Trucks of North America dated December 9, 1980. Ford is unclear whether running boards should be included in the measurement for determination of "overall width" but believes that running boards should be treated in a fashion similar to door handles. You point out that the overall width of the vehicles for which you seek exemption is actually 90.5 inches when their exterior rear view mirrors are included.

Our review of the letter to Iveco indicates that we excluded door handles from "overall width" because "they are substantially similar in character to outside rearview mirrors and the other

equipment items listed." We agree that running boards are also similar to these items, and, therefore, they need not be included in the nominal design dimension of the widest part of the vehicle when a manufacturer calculates a vehicle's "overall width" for purposes of compliance with the lighting requirements of Standard No. 108, as long as they do not extend beyond the width of the other items excluded from the definition of "overall width."

If you have further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.6/17/97