Interpretation ID: nht72-6.60
DATE: 11/17/72
FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA
TO: Plaskolite, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This is in reply to your letter of June 1, 1971, to Mr. Douglas W. Toms, Acting Administrator, National Highway Traffic Safety Administration, concerning an interpretation relative to the determination of(Illegible Word) of lamps.
Both of your interpretations are correct. The location of lamps and reflective devices is determined with the vehicle at its curb weight, which is the weight of a motor vehicle with standard equipment; maximum capacity of engine, fuel, oil, and coolant; and, if so equipped, air conditioning and additional weight optional engine.
The overall width is determined with "doors and windows closed" per the interpretation of 32 F.R. 8088, June 21, 1967.
The visibility requirements for lamps and reflective devices will therefore be determined with trunk lids, tail gates, hoods, and rear gates in the normal driving, or closed, position.