Interpretation ID: aiam2632
President
Cox Trailers
Inc.
Grifton
NC 28530;
Dear Mr. Cox: This is in reply to your letter of July 7, 1977, informing us of you 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.' (sic) as the standard requires.; Sincerely, Joseph J. Levin, Jr., Chief Counsel