Interpretation ID: 77-3.36

TYPE: INTERPRETATION-NHTSA

DATE: 07/29/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Cox Trailers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 7, 1977, informing us of your wish to relocate combination stop, tail, turn signal and side marker lamps "to the upper rear fender" of the boat trailers that you manufacture. You have asked whether this location complies with the requirements of Standard No. 108.

I am sorry that we cannot give you the interpretation you seek. Standard No. 108 requires that rear side marker lamps be mounted "as far to the rear as practicable," and stop, tail, and turn signal lamps must be mounted "on the rear." Even though, in your opinion, at your planned fender location "the lights will pass all of the required photometric and visibility requirements", when the trailer is carrying a boat the lamps are more likely to be visible "on the rear," as the standard requires.

SINCERELY,

July 7, 1977

Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

With reference to Motor Vehicle Standard 108, we intend to relocate some of the combination stop, tail, turn and side marker lamps to the upper rear fender of our boat trailers. At this location the lights will pass all of the required photometric and visibility requirements.

We need from you an interpretation of the statement that "these lights must be mounted on the rear of the trailer". Could we use this mounting as long as these lights meet the other requirements and can be considered mounted as far to the rear as practicable. The distance from the rear would normally not exceed four (4) feet.

Our reasons for deviating from the rear most position on the trailer is due to trailer construction which makes rear mounting highly impractical.

Your prompt attention to this matter will be greatly appreciated.

COX TRAILERS, INC

William F. Cox President