Interpretation ID: 21964

Mr. Larry Cernosek, Chairman
Texas Towing & Storage Association
2104 Lyons Avenue
Houston, TX 77020

Dear Mr. Cernosek:

This is in reply to your letter of July 25, 2000, "responding to [my] letter of May 9, 2000, for further clarification." My letter provided an interpretation of Standard No. 108 as it relates to a light bar consisting of stop and taillamps.

In that letter, I expressed my assumption that the light bar was installed on tow trucks, as required by S5.3.1.1, to serve as a compliance surrogate for required lighting equipment whose conformance was affected by the truck's work-performing equipment. You have explained in your latest letter that the original equipment is unaffected by the work-performing equipment and that the lamps in the light bar are additional lamps within the meaning of S5.1.3.

In my earlier letter, I stated that additional lighting equipment was permitted as long as it does not impair the effectiveness of the lighting equipment required by Standard No. 108. I further commented that additional lighting equipment "need not meet any performance or location requirements." You have replied that the additional stop and taillamps do not impair the effectiveness of the original equipment lamps and do not have to meet any location or performance requirements.

We agree with your remarks. There are no location or performance requirements for supplementary lighting equipment. From the photos you enclose, it does not appear that that the supplemental stop lamps in the light bar would cause "impairment" of the original ones located below, or of any other required rear lighting equipment.

Sincerely,
Frank Seales, Jr.
Chief Counsel

ref:108
d.10/13/00