Interpretation ID: 2406y
Engineering Manager
Duralite Truck Body and Container Corp.
1300 Bush Street
Baltimore, MD 21230
Dear Mr. Smith:
This is in reply to your letter to Taylor Vinson of this Office. I regret the delay in responding.
You have asked for an interpretation of Motor Vehicle Safety Standard No. l08 as it pertains to the location of clearance lamps. You stated your understanding that "if a chassis cab is equipped with clearance and marker lamps, it is not necessary to add a second set of two lamps to act as clearance lamps to the front wall of the truck body." This is not correct. A chassis cab is an incomplete motor vehicle, and not required to comply with Standard No. l08. However, when the chassis cab is completed, the completed vehicle must comply, and be certified by its final-stage manufacturer as complying, with Standard No. l08 (and all other applicable Federal motor vehicle safety standards). Standard No. l08, in pertinent part, requires front clearance lamps to be mounted to indicate the overall width of the vehicle, and as near the top as practicable.
This means that if clearance lamps have been mounted on the chassis cab, and if in that location they do not indicate the overall width of the completed motor vehicle and are not as near the top of the completed motor vehicle as practicable, the final stage manufacturer must add a set of clearance lamps to the front of the truck body to meet that requirement. In this event, the cab-mounted clearance lamps may be disconnected or removed.
However, this is not true with respect to the mounting of identification lamps on chassis cabs. Standard No. l08 allows them to be mounted as close as practicable to the top of the cab as an alternative to the top of the vehicle. Further, on truck tractors, clearance lamps mounted on the cab may be located to indicate the width of the cab rather than the overall width of the vehicle.
I hope this has answered your question.
Sincerely,
Stephen P. Wood Acting Chief Counsel
/ ref: l08 d:4/25/90