Interpretation ID: aiam1789
Manager
Vehicle Safety Activities
Sheller-Globe Corporation
2885 St. Johns Avenue
Lima
OH 45804;
Dear Mr. Semark: This is in reply to your letter of January 16, 1975, asking whether yo must install clearance lamps on a vehicle's rear fenders, rather than its body, in order to conform to Motor Vehicle Safety Standard No. 108.; Table II of Standard No. 108 requires red clearance lamps to be 'on th rear, to indicate the overall width of the vehicle . . . and as near the top as practicable.' Paragraph S4.3.1.1 requires clearance lamps to be located so as to meet the visibility requirements of SAE Standard J592e, which includes test points at 45 degrees inboard. Therefore, the location of clearance lamps as shown on the TBEA sheet you enclosed conforms to the intent of the standard. Clearance lamps mounted near the top and outer extremities of a body, as in your diagrams, do sufficiently indicate overall width for purposes of safety, even though the actual vehicle width at the fender may be somewhat greater.; Yours truly, Richard B. Dyson, Asst. Chief Counsel