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Interpretation ID: 2623y

Mr. Jack Rademacher
Chief Engineer
Polar Tank Trailer, Inc.
12810 County Road 17
Holdingford, MN 56340

Dear Mr. Rademacher:

This is in reply to your letter of May 8, l990, to Stephen P. Wood of this Office, asking for reconsideration of a recent interpretation of Standard No. l08.

We assume you mean our letter of January 9, 1990, to Howard Kossover of Oklahoma City. That interpretation stated that if rear lamps on a semi-trailer were mounted 27 inches forward of the rear edge of the vehicle, they were not mounted "on the rear", the location specified by Standard No. l08. We also observed that compliance with the 45-degree visibility requirements in that location appeared questionable. You say that it has long been the practice of the Truck Trailer Manufacturers Association (TTMA) and its members that "if the 45 degree visibility requirement of these lights were met 'on the rear' of the trailer both inboard and outboard, the manufacturer met the intent of the standard." You inform us that the liquid bulk transport industry is especially affected by this interpretation because of reasons of practicality unique to tank transports. On these vehicles, you state that the rear lamps have been "mounted as far as 36 inches forward from the rear of the bumper", but that, in this location, they "still maintain the 45 degree visibility requirements." You therefore ask for reconsideration of the interpretation if the 45 degree visibility requirements are met.

The lamps in your letter (and Mr. Kossover's) are stop, turn signal, and taillamps. Only the taillamps are presence lamps. The stop lamps and turn signal lamps operate independently of the headlamps. That is to say, they are intended for use at all times and not just at night or under other conditions of reduced visibility. They indicate actions taken by the vehicle operator to signal his operational intentions to other drivers and pedestrians. Problems with depth perception of following drivers could result if the lamps are not mounted "on the rear" as the standard requires. We are willing to interpret "on the rear" as meaning the trailing edge of the rear fender, which may not extend as far rearward as the bulk tank container, provided the visibility requirements are met, but we conclude that a mounting location for stop and turn signal lamps that is 36 inches forward from the rear of the bumper is not "on the rear" as the standard requires.


Paul Jackson Rice Chief Counsel

ref:l08 d:8/22/90