Interpretation ID: nht80-1.35

DATE: 03/18/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bertolini Engineering Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 22, 1980, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

You have referenced our letter of May 5, 1977, to Mr. Dennis Moore of Dry Launch. That letter interpreted S4.3.1.1.1 with respect to a rear clearance lamp which indicated overall width though it was not located on the rear of the trailer. In that position it was not required to be visible at 45 degrees inboard. You have asked whether the same inboard visibility requirements may be eliminated for front clearance lamps "for the same reasons".

The answer is yes. If a front clearance lamp that indicates overall width is not located at the front of the trailer, S4.3.1.1.1 relieves it of the requirement that it be visible at 45 degrees inboard.

I hope this answers your question.

SINCERELY,

BERTOLINI ENGINEERING CO., INC.

February 22, 1980

Frank Berndt Acting Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration

Dear Mr. Berndt:

I am in receipt of a letter written to you on April 7, 1977 concerning the elimination of the requirement for inboard visibility of a rear clearance lamp for a truck trailer, and your reply of May 5, 1977 advising that the inboard visibility is not required.

My question is as follows: Can the same inboard visibility requirement for the front clearance light of a truck trailer be eliminated for the same reasons as cited in your letter of May 5, applying the diagram shown in the April 7, 1977 letter, with the exception that the diagram applies to the front of a trailer instead of the rear.

William A. Bertolini President