Interpretation ID: nht89-3.51

TYPE: INTERPRETATION-NHTSA

DATE: 12/08/89

FROM: HOWARD KOSSOVER -- CMI TRAILER DIVISION

TO: TAYLOR VINSON -- LEGAL COUNCIL - FMVSS - 108 N.H.T.S.A.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 01/09/90 FROM STEPHEN P. WOOD -- NHTSA TO HOWARD KOSSOVER -- CMI TRAILER DIVISION; REDBOOK A35; STANDARD 108

TEXT: Dear Mr. Vinson:

I am writing to you in regard to the FMVSS Lighting Code. We are in process of building a semi-trailer for highway use and would like to know if we are in violation of the code with respect to the location of the rear stop, turn & tail lights.

This unit is a Rear Discharge trailer designed to haul hot mix asphalt. As the asphalt is discharged out it tends to build up on the rear components. We have recessed the lights approximately 27" from the rear so they will stay clean. I have enclosed some pictures.

Does this violate the lighting code? Please let me know.

Thank you,

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