Interpretation ID: nht92-3.13

DATE: 10/21/92

FROM: CHESTER I. NIELSEN III -- VICE PRESIDENT, SALES, WESTBAR CORPORATION

TO: WALTER B. MCCORMICK, JR. -- CHIEF COUNCIL, DOT

ATTACHMT: ATTACHED TO LETTER DATED 12-1-92 FROM PAUL J. RICE TO CHESTER I. NIELSEN, III (A40; STD. 108)

TEXT: We are writing for classification and possible further explanation of S5.3.1.1.1. in FMVSS 108. Our request involves mounting locations of clearance lamps on boat trailers which are 80 inches or more in width.

In 1989, S5.1.1.9. addressed one aspect relating to the mounting location for clearance lamps on boat trailers. This paragraph allows boat trailer builders a longitudinal variance from the strictest standard whereby the clearance lamps no longer have to be at the highest point nor rearward location on a boat trailer, when design of the trailer does not allow it in effort to protect the function of the lamp from damage during normal usage.

Several of our personnel, and several of the staff from one of our major trade organizations, believe there was an additional interpretation from the DOT. This additional interpretation, also directed at boat trailers, would allow a boat trailer manufacturer to draw an imaginary line through the (outboard) tire on each side of his trailer and then mount his red and amber clearance lights outside of these lines. The rationale was to provide desired width identification while providing protection of the light during normal use. A sketch below depicts the most inboard allowable mounting locations should this interpretation be confirmed by your office.

(GRAPHIC OMITTED.)

1 = most inboard allowable mounting location for amber clearance lamps.

2 = most inboard allowable mounting location for red clearance lamps.

Thank you for your attention to this matter and we look forward to receiving your timely response to our request for a written confirmation of this mounting location interpretation.