Interpretation ID: 1985-01.14

TYPE: INTERPRETATION-NHTSA

DATE: 01/16/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Donald W. Vierimaa -- Director of Engineering, Truck Trailer Manufacturers Association

TITLE: FMVSS INTERPRETATION

ATTACHMT: 5/2/69 letter from Charles A. Baker to Reliance Trailer and Truck Company Inc.; 11/10/81 letter from F. Berndt to Truck Trailer Manufacturers Association

TEXT:

Mr. Donald W. Vierimaa Director of Engineering Truck Trailer Manufacturers Association 1020 Princess Street Alexandria, VA 22314

This is in reply to your letter of December 7, 1984 asking our "concurrence that the front clearance lamps on a trailer with a low front end or one designed to be equipped with a tarpaulin...may be mounted at the trailer frame level ( about 50 inches above the ground), to avoid these lamps reflecting into the driver's eyes by way of the side view mirror."

You thoughtfully attached a copy of my letter to you of November 10, 1981 in which I advised you that "the determination of practicability is one that is made by the manufacturer of the trailer", and that "NHTSA will accept a determination that mounting of clearance lamps at the top...is not practicable if such lamps are reflected into the driver's eyes by way of the side view mirror." That remains our view if the configuration of any the side view mirror." That remains our view if the configuration of any trailer is such that location of clearance lamps at or near the top of the trailer results in the reflection of the light into the eyes of the driver of the truck tractor.

Sincerely,

Frank Berndt Chief Counsel Truck Trailer Manufacturers Association ALEXANDRIA, VA. 22314 December 7, 1984 Frank Berndt, Chief Counsel NHTSA, NOA-30 400 Seventh Street, S.W.

Washington, D.C. 20590

SUBJECT: Request for Interpretation of the Height of Front Clearance Lamps on Trailers with Effective Low Front Ends

Dear Mr. Berndt:

We request your concurrence that the front clearance lamps on a trailer with a low front end or one designed to be equipped with a tarpaulin which would necessicate mounting the clearance lamps low may be mounted as the trailer frame level (about 50 inches above the ground), to avoid these lamps reflecting into the driver's eyes by way of the side view mirror.

In your letter of May 2, 1969 to Reliance Trailer and Truck Company, you stated that, "the front clearance lamps should be mounted as high as practicable to clear the bottom edge of the tarp." In your letter of November 10, 1981 to TTMA you stared that with regard to low front bulkheads on platform trailers that, "NHTSA will accept a determination that mounting of clearance lamps at the top or the bulkhead is not practicable if such lamps are reflected into the driver's eyes by way of the side view mirror."

With your concurrence, the sketch in our Recommended Practice No. 9, "Location of Lighting Devices for Trailers", will be revised as shown in the attachment.

Sincerely yours,

Donald W. Vierimaa Director of Engineering Attachments: Interpretations(Letters referenced above) - see 5/2/69 letter to Reliance Trailer and Truck Co., and 11/10/81 letter to Truck Trailer Manufacturers Association RP No. 9 with Drawing - Omitted.

cc: TTMA Engineering Committee