Interpretation ID: nht68-2.11

DATE: 05/27/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: FWD Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 11, 1968, Dr. William Haddon, Jr., concerning the location of headlamps on vehicles which are used for snow plow service. I regret that a clerical error resulted in this late reply to your inquiry.

Snow plows are motor vehicles and subject to regulatory actions as established by the National Traffic and Motor Vehicle Safety Act of 1966.

Motor Vehicle Safety Standard No. 108 requires that vehicles to which the standard is applicable be equipped with headlamps that are located not less than 24 inches nor more than 54 inches above the road surface (see Table II of the standard). This requirement does not prohibit the use of additions) headlamps located at greater heights as illustrated by the photographs enclosed with your referenced letter.

Thank you for writing.