Interpretation ID: aiam1970
President
Truck Trailer Manufacturers Association
2430 Pennsylvania Avenue
N.W.
Washington
DC 20037;
Dear Mr. Calvin: This is in reply to your letter of June 17, 1975, requesting our revie of your Recommended Practice No. 9-75 - Lighting Devices for Trailers and Container Chassis.; With several minor revisions, your recommended practice will accuratel reflect the requirements of Federal Motor Vehicle Safety Standard No. 108. These revisions are as follows:; >>>1. Chart entitled, 'Truck Trailer Lighting Requirements' - a. Under the 'Remarks and Text Reference' column, opposit 'Identification Lamps,' delete 'May be at bottom level provided rear clearance lamps are as high as practicable.' This provision is not specified in Standard No. 108.; b. Under the 'Remarks and Text Reference' column, opposite 'Clearanc Lamps,' change '(S4.3.1.5)' to '(S4.3.1.4).'; c. Under the 'Height' column, opposite 'Reflex Reflectors,' the not 'Both on same level' applies only to rear reflex reflectors. The note 'Between 15 & 60' applies to both rear and side reflex reflectors.; 2. Drawing entitled, 'Required Lamps and Reflectors for Closed and Ope Top Trailers and Platform Vehicles' -; In Note 5, delete 'and rear clearance.' Rear clearance lamps must b mounted as near as practicable to the top of the vehicle, unless the identification lamps are located at the extreme height of the vehicle (paragraph S4.3.1.4 of Standard No. 108).<<<; We note that you provide identified zones of specified dimension within which you recommend that lamps be located. The standard actually requires these lamps to be 'as close to the top or practicable.' 'as far forward as practicable' etc. In most instances this should fulfill the requirements of the standard. However, we recommend that paragraph 3.1 of your recommended practice be revised to state both the locations actually specified by Standard No. 108 and the fact that your drawings provide your interpretation of these requirements which may not necessarily be that of the NHTSA.; Your efforts in promoting compliance with the requirements of Standar NO. 108 are greatly appreciated.; Sincerely, Richard B. Dyson, Assistant Chief Counsel