Interpretation ID: nht88-4.6

TYPE: INTERPRETATION-NHTSA

DATE: 11/09/88

FROM: JAMES A. LUTES -- KENTUCKY MANUFACTURING COMPANY

TO: ERIKA Z. JONES -- CHIEF COUNSEL N.H.T.S.A.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/19/88 FROM STEPHEN P. WOOD -- NHTSA TO JAMES A. LUTES; REDBOOK A33 [4]; VSA 102; STANDARD 108; LETTER DATED 10/28/88 FROM THOMAS A. COZ TO JIM LUTES RE CALIFORNIA CITATIONS HIGH MOUNTED TRAILER STOP LAMPS

TEXT: Dear Erika,

Kentucky Manufacturing Company at the request of numerous customers, including North American Van Lines of Fort Wayne, Indiana has been installing high mount stop and turn lights in the rear doors of van-type trailers; the height of these lights is appro ximately 12'-0" above ground level.

The above lights are in addition to the standard stop, tail, and turn lights that are located within the specified dimension range of 15" to 72" above ground level, as specified by F.M.V.S.S. #108.

Our interpertation of F.M.V.S.S. #108 is that all lights that are required by law have a specified location within given dimensions; extra lights may be installed on a trailer in any location as long as the extra lights do not obscure or hinder the ident ification of the lights required by law.

We are attaching a photograph showing the extra stop and turn lights in the rear doors. We are also attaching copies of citations issued to North American Van Lines drivers by California Highway Patrol. Also enclosed is a letter addressed to myself fro m North American Van Lines dated October 28, 1988 and signed by Mr. Thomas A. Coz, Senior Attorney at North American.

As stated on the citations, stop & turn signals mounted higher than 72" above ground are in violation (24603CVC).

We would appreciate very much your interpretation and/or clarification of the above situation.

Very truly yours,

Enclosures

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