Interpretation ID: nht90-1.75

TYPE: INTERPRETATION-NHTSA

DATE: 03/19/90

FROM: CLARKS GORTE -- FORD HEAVY TRUCK VEHICLE ENGINEERING

TO: NHTSA

TITLE: [FORD RATIONALE FOR FMVSS 108 COMPLIANCE]

ATTACHMT: ATTACHED TO LETTER DATED 03/27/90 FROM STEPHEN P. WOOD -- NHTSA TO LARRY F. WORT -- ILLINOIS DEPT OF TRANSPORTATION; REDBOOK A 35; STANDARD 108; LETTER DATED 03/27/90 FROM LARRY F. WORT -- ILLINOIS DEPT OF TRANSPORTATION TO TAYLOR VINSON -- DOT ; OCC 4613

TEXT: Mr. Van Alstin, listed below are the FMVSS requirements and the rationale used by Ford Heavy Truck Engineering to signoff for compliance to FMVSS 108, specifically side marker lamps.

FMVSS 108 required motor vehicle lighting equipment is covered on page 226, S4.1.1 and S4.1.1.1 of the Code of Federal Regulations for 571.108, the location is covered on page 237, S4.3, S4.3.1, & S4.3.1.1, combinations are covered on page 238, S4.4.

1990 and prior year Ford C-Series and CL-Series vehicles use the roof mounts corner marker lamps to satisfy the side marker lamp requirements of FMVSS 10 The corner marker lamps are forward of the vartical C/L of the vehicle, are prominantly displayed, s ecurely attached, and satisfy the photomarty, vibrat corrosion, moisture, dust and color requirements.

For your information, all Ford C and CL-Series are believed to be in compli. with FHWA DOT requirements, Part 393-Parts and Accessories Necessary For Sa Operation. Subpart B.

Should you require additional information or require further clarification please contact this office.

Clarke Gorte Ford Heavy Truck Vehicle Engineering

C-CT SERIES DIMENSIONAL DRAWINGS [Illustration Omitted]