Interpretation ID: aiam3375
Iveco Trucks of North America
Inc.
P.O. Box 1102
Blue Bell
PN 19422;
Dear Mr. Pedersen: This is in reply to your letter of October 30, 1980, asking question with respect to the term 'overall vehicle width' contained in Federal Motor Vehicle Safety Standard No. 108.; You have first asked whether door handles are a part of the vehicle t be included in the definition. The answer is that they need not be included. The definition in 49 CFR 571.3(b) excludes outside rearview mirrors and other equipment items in computing 'overall vehicle width.' Although the definition does not list door handles among the equipment to be excluded in determining the nominal design dimension of the widest part of the vehicle, they are substantially similar in character to outside rearview mirrors and the other equipment items listed and may be deemed included.; Your second question is whether vehicles, whose tolerances are suc that they are less than 80 inches in overall width, must nevertheless be equipped with clearance and identification lamps if the basic vehicle design is such that the 'nominal design dimensions of the widest part of the vehicle' is 80 inches or greater. The answer is yes. If the engineering drawings, etc. of the basic vehicle design posit an overall vehicle width of 80 inches or more, all vehicles manufactured on the basis of that specification must be equipped with clearance and identification lamps even if an occasional vehicle is produced whose overall width may be slightly less than 80 inches due to the tolerances involved.; Sincerely, Frank Berndt