Interpretation ID: aiam2403
Executive Secretary
Trailer Manufacturers Association
401 North Michigan Avenue
Chicago
IL
60611;
Dear Mr. Reed: This is in reply to your letter of September 9, 1976, asking for a interpretation of two provisions of Motor Vehicle Safety Standard No. 108.; You have informed us that 'some manufacturers are mounting lamps usin lock washers and wing nuts rather than conventional nuts to facilitate the installation of lamps when boat trailers are assembled at the dealer level.' S4.3.1 of Standard No. 108 requires that lamps 'shall be securely mounted . . . .' and you asked whether wing nuts, used as you described, provide a mounting that complies with S4.3.1. The answer is that this would appear to provide a secure mounting within the intent of Standard No. 108.; S4.3.1.3 requires that front side marker lamps for trailers be locate as far to the front as practicable, exclusive of its tongue. You ask whether 'the tongue is considered to start where the trailer frame begins to angle inward from its parallel sides . . . .' The answer is yes.; I hope this clarifies Standard No. 108 for you and your members. Yours truly, Frank Berndt, Acting Chief Counsel