Interpretation ID: 3243yy
Manager, Special Projects
The Grote Manufacturing Company
2600 Lanier Drive
Madison, Indiana 47250
Dear Mr. Weidman:
This responds to your letter of November 25, 1991, with respect to the applicability of some new requirements of Motor Vehicle Safety Standard No. 108 to "agricultural vehicles and implements when they are traveling on the highways." Specifically you ask whether the requirements of Standard No. 108 or SAE J137 must be complied with when agricultural equipment is in use.
The Federal motor vehicle safety standards apply to motor vehicles, which are defined, in pertinent part, by the National Traffic and Motor Vehicle Safety Act as vehicles "manufactured primarily for use on the public streets, roads, and highways." Because the primary use for agricultural vehicles such as farm tractors, combines, and the like is off the public roads, and their use of the public roads is incidental to their intended use, NHTSA does not consider agricultural vehicles to be "motor vehicles" within the meaning of the Act. This means that they do not have to conform to Standard No. l08, or any other Federal motor vehicle safety standard.
Regulations governing the use of the public roads are issued and enforced by the individual States. We have no knowledge whether any State requires the lighting on agricultural equipment to conform to SAE J137, or to Standard No. l08. The American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, may be able to answer this question for you.
Sincerely,
Paul Jackson Rice Chief Counsel
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