Interpretation ID: nht90-3.73

TYPE: Interpretation-NHTSA

DATE: August 30, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: M. Michael Mascho -- Safety & Compliance Specialist, Kenworth Truck Company

TITLE: None

ATTACHMT: Attached to letter dated 7-12-90 from J.M. Mascho to T. Vinson (OCC 4988) with photograph

TEXT:

This is in reply to your letter of July 12, 1990, to Taylor Vinson of this Office, requesting an interpretation of Motor Vehicle Safety Standard No. 108.

Kenworth builds a wide truck that is equipped with a sleeper, located behind the cab and extending somewhat above it. On this model, the clearance and identification lamps are mounted on the cab. A customer has asked for an additional set of clearance and identification lamps to be mounted on the sleeper. You have enclosed photographs of this configuration, and asked whetber such a vehicle would be in compliance with Standard No. 108.

The answer is yes. Section S5.1.3 of Standard No. 108 permits supplementary lighting equipment to be installed provided that it does not impair the effectiveness of the lighting equipment required by the standard. The duplicate clearance and identifica tion lamps that your client wishes Kenworth to provide would appear to enhance, rather than impair, the effectiveness of the original equipment clearance and identification lamps installed in accordance with Standard No. 108.