Interpretation ID: nht89-3.11

TYPE: INTERPRETATION-NHTSA

DATE: OCTOBER 10, 1989

FROM: J. DOUGLAS SMITH -- ENGINEERING MGR., DURALITE TRUCK BODY AND CONTAINER CORP. TO: TAYLOR VINSON -- LEGAL COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-25-90 TO J. DOUGLAS SMITH FROM STEPHEN P. WOOD; (A35; STD. 108)

TEXT:

As an O.E.M. manufacturer of truck bodies, Duralite is responsible for final certification on literally thousands of new straight trucks. Recently however there has been some question regarding the interpre- tation of FMVSS 108 (lamps, reflective devices , and associated equipment). It is our understanding as well as industry standard 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. During the last week, a customer of ours received a warning for not having clearance lights in the proper location. Corporal Talbot of the Maryland State Police said that it was their interpretation that the cab mounted lights were sufficie nt and that a new officer had interpreted the meaning differently.

A change in the interpretation of this standard would effect many thousands of vehicles already on the road. Of all the major truck body manufacturers there is only one of which I am aware that has body mounted clearance lamps visible to the front. To revise the standard at this point would cost fleets a great deal of time and money.

As it is our responsibility to build and certify new units, your immediate attention and response to this situation would be greatly appreciated. If you have any question please feel free to contact me at (301) 727-6962.