Interpretation ID: aiam3055
Laboratory Manager
Truck-Lite Co. Inc.
310 East Elmwood Avenue
Falconer
NY 14733;
Dear Mr. Bragg: This is in reply to your letter of June 19, 1979, to Mr. W. M. Elliot of this agency requesting clarification of Paragraph S4.3.1.1.1 of Federal Motor Vehicle Safety Standard No. 108.; This Paragraph states: >>>'Clearance lamps may be mounted at a location other than on th front and rear if necessary to indicate the overall width of a vehicle, as for protection from damage during normal operation of the vehicle, and at such a location they need not be visible at 45 degrees in board.'<<<; You have asked the following questions: '1. Is the decision to use another mounting location made at th discretion of the manufacturer?'; Yes. The manufacturer determines whether placement of the lamps i accordance with Standard No. 108 will indicate overall width or whether they are susceptible to damage if so placed, and there is no requirement that it obtain the concurrence of this agency in its decision.; '2. Are there any specific conditions that are required in order t consider it 'necessary' to mount clearance lamps in another location?'; No. The agency has established no criteria of necessity and question on variations from front and rear mounting requirements are treated on an *ad hoc* basis.; '3. When the decision is made to mount the clearance lamps in anothe location, can a manufacturer use *combination* clearance/side marker lamps mounted on the *side of vehicle* to fulfill the clearance lamp requirements.'; Yes, as long as the clearance lamp function is visible from the rea and indicates the overall width of the vehicle.; '4. Section S4.1.1.1 states that in 'such a location they need not b visible at 45 degrees inboard'. Does this mean that they need not be visible from 0 to 45 degrees inboard?'; No. SAE Standard J592e, *Clearance, Side Marker, and Identificatio lamps*, July 1972, requires clearnce (sic) lamps to be visible at the H Point at 10 R and L, 20 R and L, 30 R and L, and at 45 R and L. Paragraph S4.3.1.1.1 specifies that under the alternate mounting positions the lamps need not be visible at the 45 degrees positions. They must, however, be visible at the other positions.; I hope this answers your questions, Sincerely, Frank Berndt, Chief Counsel