Interpretation ID: nht91-2.16
DATE: March 7, 1991
FROM: Paul Jackson Rice -- Chief Counsel
TO: Sidney A. Garrett -- President, Brown Cargo Van, Inc.
TITLE: None
ATTACHMT: Attached to letter dated 4-25-90 from Stephen P. Wood to J. Douglas Smith (Std. 108); Also attached to letter dated 2-15-91 from Sidney A. Garret to U.S. Department of Transportation, NHTSA (OCC 5732)
TEXT:
This is in reply to your letter of February 15, 1991, asking the agency for an interpretation of Motor Vehicle Safety Standard No. 108 as it pertains to the location of front clearance and identification lamps on truck van bodies.
Specifically, where the chassis-cab is equipped with clearance and identification lamps, you have asked whether this relieves you, as the manufacturer of the van body, from installing additional clearance and identification lamps on the van body. If the answer is no, you have asked whether the van body may be equipped with clearance lamps only, or must it be equipped with both clearance and identification lamps.
We answered a similar request on April 25, 1990, and I enclose a copy of our response for your guidance. With respect to your particular design, the clearance lamps mounted on the cab would not be as near the top of the completed motor vehicle as practicable, and therefore must be located on the van body. However, identification lamps may be mounted on the cab, and your lamps located as shown in your Exhibit 2 would meet Standard No. 108. Identification lamps may also be mounted on the van body, and Exhibit 3 would also meet the location requirements of Standard No. 108.