Interpretation ID: nht68-3.34

DATE: 05/14/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 1, 1968, to Mr. Edwin L. Slagle, requesting a clarification of the location requirements for identification lamps on real trailers.

The brochures attached to your letter describe two types of reel trailers as manufactured by the Standard Trailer Company and designated as the "Reelmaster" and "Cable Winder/Stringer." These trailers are completely open in the rear with no permanently attached crossbar for mounting rear identification lamps. On these trailers, identification lamps mounted on permanently attached swinging arms which are located near the wheels of the trailers would appear to conform to the requirements of Motor Vehicle Safety Standard No. 108.

With respect to the requirements of Standard No. 108. I must point out that this Bureau does not issue approvals 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 the standard.

Thank you for writing.