Interpretation ID: GF0002060

Don Brown, Director of Engineering
Trailer Service, L.L.C.
1000 South Caraway
Suite #211
Jonesboro, AR 72401

Dear Mr. Brown:

This responds to your February 23, 2005, letter asking whether Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices and Associated Equipment, permits relocating front trailer clearance lamps in order to limit their exposure to damage. Your letter indicates that you intend to relocate the clearance lamp so that it is recessed into the "top rail".

Table II of FMVSS No. 108 specifies that for a trailer with an overall width of 80 inches or more, two amber clearance lamps must be located at the front edges of the trailer as near the top as practicable. S5.3.2.1 (formerly S5.3.1.1.1) of FMVSS No. 108 specifies that clearance lamps may be located elsewhere, if necessary for protection from damage during normal operation of the vehicle. Accordingly, our regulations do not prohibit relocation of clearance lamps in order to limit their exposure to damage.

Please note that S5.3.2.1 also specifies that a relocated clearance lamp need not meet the applicable photometric output requirements at any test point that is 45 degrees inboard. Other applicable photometric output requirements remain (see SAE Standard J592e "Clearance, Side Marker, and Identification Lamps", July 1972).

I hope you find this information helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:108
d.4/26/05