Interpretation ID: 86-5.48

TYPE: INTERPRETATION-NHTSA

DATE: 11/17/86

FROM: JOHN GRIFFIN -- PRESIDENT FRAZER BILT INC

TO: TAYLOR VINSON -- LEGAL COUNSEL N.H.T.S.A. U.S. DEPT. OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/06/87 FROM ERIKA Z. JONES -- NHTSA TO JOHN GRIFFIN, REDBOOK A30, STANDARD 108, ID AND CLEARANCE LAMP

TEXT: Dear Sir:

Mr. Kevin Cavey suggested that I write you regarding issues of interest to our company. We manufacture emergency medical service vehicles (ambulances). These vehicles are typically mounted on a light duty truck chasis, and are over 80" in width.

The ambulance industry typically defers to the opinions and rulings of the Federal Motor Vehicle Safety Standards in the placing of identification and clearance lights on emergency vehicles. This often presents a conflict with respect to placing emergency lights and/or lightbars at preferred locations on the ambulance. For example, a light bar above the double rear doors may be placed as high as possible and thereby give no room for identification lights. A similar situation with a front light bar is not relevant since the chassis manufacturer places clearance and identification lamps on the driver's cab roof.

Mr. Cavey indicated his belief that fire engines and E.M.S. vehicles may be exempt from identification and clearance light requirements, but I have not found such a statement in the preamble to Standard 108.

Please advise me of any ruling that might clarify this issue.

Thank you for your cooperation.

Sincerely