Interpretation ID: aiam0055
Sales Manager
Utility Body Company
901 Gilman Street
Berkeley
CA 94710;
Dear Mr. Romney: Thank you for your letter of March 6, 1968, to Mr. George C. Nield concerning the additional clearance lamps and reflectors that you have been requested to install on vehicles shipped to Hawaii.; Referring to the drawing attached to your letter, the use of clearanc lamps as shown does not appear to impair the effectiveness of the lighting equipment required by Motor Vehicle Safety Standard No. 108, provided (1) the two lamps on front of the body are *amber* in color, and (2) the lamp on the rear of the body is red in color. Also, use of the amber reflex reflector on front of the body would not appear to impair the effectiveness of the required equipment. Paragraph S3.1.2 of the Standard states: 'No additional lamp, reflective device, or associated equipment shall be installed if it impairs the effectiveness of the required equipment.' This requirement applies to all applicable vehicles, including those owned by a State.; On your drawing, it appears that you have inadvertently indicated a re color for the clearance lamps on the front of the body. Use of red lamps at the locations shown would impair the effectiveness of the required equipment, since red lamps are used, in accordance with the standard, to designate the rear of the vehicle.; With respect to the requirements of Standard No. 108, I 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.; Thank you for writing. Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance;