Interpretation ID: nht68-3.33

DATE: 05/06/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Utility Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 11, 1968, to Mr. George C. Nield requesting clarification of the positioning of lamps and reflectors as required by Motor Vehicle Safety Standard No. 108.

The lamps and reflectors that are shown on your Drawing No. X-78, dated January 17, 1968, appear to be in conformance with the requirements of Standard No. 109 with the following exceptions:

1. The front clearance lamps mounted on the chassis-cab of the top two vehicles on your drawing are not required by Standard No. 108, since those on the body and crew-carrying cab adequately define the extreme width and are as high as practicable.

2. The rear clearance lamps shown on the crew-carrying cab should be mounted on the rear of the bed similar to those on the bottom vehicle (P) to meet the requirement that they be mounted on the rear and indicate the extreme width.

3. The front clearance lamps on the third vehicle (S, SL, CO) should be mounted on the front of the tool panels at or near the same level as the rear clearance lamps to indicate the extreme width.

4. The front clearance lamps on the bottom vehicle (P) should be mounted on the front of the bed or platform if it projects beyond the sides of the chassis-cab.

Since no dimensions are specified on your drawing, we can only assure that the locations are as specified in the standard.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.