Interpretation ID: 1982-2.30

DATE: 08/02/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Roberts Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 16, 1982, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

You enclose photos of a 1982 Kenworth truck which has two pairs of front turn signal lamps: one set (incorporating a side reflector) mounted 58 1/2 inches above the road surface and which are 83 inches apart; the other, mounted approximately 81 1/2 inches above the road surface and which are 110 inches apart. You have asked whether the vehicle would comply if the lower mounted set were removed and an amber reflex reflector placed on each side of the fender as far forward as practicable.

The answer is yes. The mounting height of 81 1/2 inches does not exceed the limit of 83 inches imposed by Table II of Standard No. 108. In addition, the lamps appear to meet the two further requirements that they be located as far apart as practicable and at the same height.

Sincerely,

ATTACH.

July 16, 1982

Administrator -- National Highway Traffic Safety Administration, Department of Transportation

Subject: Federal Motor Vehicle Safety Standard Number 108 Lamps, Reflective Devices and Associated Equipment

Gentlemen:

Enclosed please find two photographs of a 1982 Kenworth, Model W900. You will note from the photographs that two sets of turn signals are on the vehicle, one set on the hood and another set on the bottom of the mirror brackets.

On the vehicle shown, which is typical of the Model, the center of the fender mounted signals are approximately 58 1/2" above the road surface and approximately 83" apart.

The center of the mirror mounted turn signals are approximately 81 1/2" above the road surface and approximately 110" apart.

Our question concerns Federal Motor Vehicle Safety Standard Number 108(571.108), specifically, Table II, "Location of Required Equipment", "Turn Signal Lamps". Considering the dimensions above, would the vehicle be in conformance with the Standard if only the mirror mounted turn signals were installed on the vehicle and an amber reflex reflector placed on each side of the fender as far forward as practicable?

We would appreciate your consideration and reply to this matter at your earliest opportunity.

Yours truly, Ronald E. DeVolder -- Vice President

enclosures

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