Interpretation ID: aiam1411
Engineering Division
Mack Trucks
Inc.
P. O. Box 1761
Allentown
PA
18105;
Dear Mr. Fischer: This is in reply to your letter of February 4, 1974, concerning th location requirements of front identification lamps on certain solid-waste disposal vehicles.; You describe the vehicles in question as 'short BBC low cab-over-engin type vehicles -- equipped with a large volume body and a hydraulically operated front loader mechanism. This unit lifts containers of waste up and over the front of the cab and empties the waste into the top of the body. To prevent damage to the front of the vehicle and lamps, a protective guard is installed on the front centerline of the vehicle.' You further state that 'This guard could obstruct the center identification lamp.'; You ask whether or not all three of the front identification lamps ma be offset from the front centerline of the vehicle to ensure compliance with the visibility requirements of FMVSS No. 108. In accordance with paragraph S4.3.1, Table II of FMVSS No. 108 specifies that the front identification lamps be located 'as close as practicable to the top of the vehicle, at the same height, as close as practicable to the vertical centerline.' For the vehicles which you have described, it would appear that location of the front identification lamps either left or right of the vertical centerline would meet this requirement.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;