Interpretation ID: aiam0070
Oshkosh Truck Corporation
P.O. Box 560
Oshkosh
WI 54901;
Dear Mr. Leu: Thank you for your letters of January 15 and March 25, 1968, to th National Highway Safety Bureau, concerning the applicability of Federal Motor Vehicle Safety Standard No. 108 to snow removal and heavy duty on-off highway vehicles manufactured by Oshkosh.; Standard No. 108 requires that headlamps be mounted not more than 5 inches above the road surface. Since your snow removal vehicles may be used in hauling operations as a secondary function, and since your heavy duty vehicles are used on the public roads, they are required to be equipped with headlamps located in accordance with Standard No. 108. Additional headlamps mounted on the cab roof or elsewhere on the front of the snow removal vehicle is permitted by the standard.; With reference to your heavy duty vehicles, headlamps located in th bumper, with adequate openings in front of the headlamps, or headlamps located below the bumpers, with protective shields around the headlamps would be permitted by Standard No. 108.; With respect to the requirements of Standard No. 108, we must point ou that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard. The certification information that you have provided us in your letter of January 15 is in accordance with our requirements.; We trust this information will be of assistance to you in your desir to comply with the existing safety standards.; Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service;