Interpretation ID: nht91-1.43

DATE: February 15, 1991

FROM: Sidney A. Garrett -- President, Brown Cargo Van Inc.

TO: U.S. Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3-7-91 from Paul Jackson Rice to Sidney A. Garrett (A37; Std. 108)); Also attached to letter dated 4-25-90 rom Stephen P. Wood to J. Douglas Smith (Std. 108)

TEXT:

We are manufacturers of truck van bodies and need an interpretation of Federal Motor Vehicle Safety Standard No. 108. Specifically we need an interpretation of the location of the front identification and clearance lamps.

The three amber identification lamps are to be attached at the same height, as close as practicable to the vertical centerline, and as close as practicable to the top of the vehicle. The two amber clearance lamps, indicating overall width, are to be attached at the same height, one on each side of the vertical centerline, and as near the top as practicable.

Our question is if the truck cab comes with all five amber lamps mounted on its top as in Exhibit 1, does this meet the standard and therefore we do not need to install additional lamps? If this does not meet the standard, then we need to know if either Exhibit 2, with only the clearance lamps attached to the van body, or Exhibit 3, with both clearance lamps and identification lamps attached to the van body, meets the standard.

We are trying to minimize our costs and do not want to install unnecessary lamps as long as we are meeting all safety standards. Also, we are in the process of redesigning the front of our van bodies and would like to have the answer to our question as soon as possible so that our engineers can proceed.

If you need any additional information, please contact me at 800-255-6827.

Attachment

Photos of a cargo van (Graphics omitted)