Interpretation ID: aiam2979
Vice President
Engineering
The Grote Manufacturing Company
State Route 7
P.O. Box 766
Madison
IN 47250;
Dear Mr. Newman: This is in reply to your letter of February 15, 1979, asking for a interpretation of S4.3.1.1.1 of Motor Vehicle Safety Standard No. 108.; You have informed us that dimensional changes in refrigeration units o the front of commercial trailers mean that clearance lamps are no longer visible at 45 degrees inboard if they are mounted as they have been in the past. You have proposed three alternate solutions to the problem.; S4.3.1.1.1 provides in pertinent part that 'clearance lamps may b mounted at a location other than on the front and rear if necessary to indicate the overall width of the vehicle...and at such a location they need not be visible at 45 degrees inboard.' Your first proposed solution is that 'The lamps could be mounted on the front of the vehicle as normal and the 45 degree inboard visibility requirements waived in accordance with S4.3.1.1.1.'; We believe that this is preferable to your other suggested solution that utilize angle-mounted combination lamps. Standard No. 108 appears to prescribe alternate requirements for location and visibility of clearance lamps--preferable on the front and visible throughout 45 degree angles, but if not, elsewhere than the front and where they need not be visible through the 45 degree angles. Your first proposed solution comprises elements of each of Standard No. 108's alternatives, and while it is not expressly permitted by Standard No. 108, it does not appear to violate it.; Sincerely, Frank Berndt, Acting Chief Counsel