Interpretation ID: noll.ztv
Director of Manufacturing
Orange Blossom Quick Loader
4 Anderson Drive
Albany, NY 12205
Dear Mr. Noll:
This responds to your letter of February 28, 1997, regarding the rear lamp location requirements of Motor Vehicle Safety Standard No. 108. You ask whether the location of rear taillamps and turn signal lamps shown in the photographs you enclosed comply with the requirements of Standard No. 108. You comment that "the center bar is the only practical area. . . ."
Table II of Standard No. 108 requires rear taillamps and turn signal lamps on vehicles whose overall width exceeds 2032 mm (80 inches) to be located "on the rear" and "as far apart as practicable." In certifying compliance of the vehicle with all applicable Federal motor vehicle safety standards, the manufacturer is certifying that the trailer also meets the rear lamp and reflector location requirements of Standard No. 108.
Unless the manufacturer's determination of practicability is clearly erroneous, it is the policy of this agency not to contest it. In this instance, you have located the lamps on the "center bar" because "the ramp will extend from the original frame of the trailer and we would not be in compliance with the lamps only on the outside corners." We accept, therefore, your representation that the rear taillamps and turn signal lamps shown on the photographs you enclosed are located "as far apart as practicable."
If you have any questions, you may call Taylor Vinson of this office (202-366-5263).
Sincerely,
John Womack
Acting Chief Counsel
ref:108
d:4/4/97