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Interpretation ID: aiam3034

Mr. Howard J. Bogner, Federal Government Relations Manager, Minnesota Mining & Manufacturing Company, 1101 Fifteenth Street, S.W., Washington, D.C. 20005; Mr. Howard J. Bogner
Federal Government Relations Manager
Minnesota Mining & Manufacturing Company
1101 Fifteenth Street
S.W.
Washington
D.C. 20005;

Dear Mr. Bogner: This is in reply to your letter of June 18, 1979, asking about 'th history of the implementation of FMVSS 108 and the dates as to these proceedings.'; I assume that you are interested in the initial standards and not th many amendments that have occurred at frequent intervals since the first effective dates. An advance notice of proposed rulemaking was published in the *Federal Register* on October 8, 1966, inviting suggestions for all the initial Federal motor vehicle safety standards. The initial motor vehicle lighting requirement were proposed on November 30, 1966 (31 FR 15212, corrected at 31 FR 15600). Standard No. 108 published on February 3, 1967, however, (32 FR 2408, establishing 23 CFR 255.21, effective January 1, 1968) applied only to vehicles whose overall width was 80 inches or more. On the same day the agency (then known as the National Traffic Safety Agency, Department of Commerce) proposed 'MVSS No. 112' to become effective January 1, 1968, to cover all vehicles whose width was less than 80 inches (32 FR 2418). The same notice also proposed amendments to the just-issued Standard No. 108 which were adopted on December 16, 1967 (32 FR 18032) with varying effective dates. Instead of adopting 'Standard No. 112', the agency also amended Standard No. 108 on December 16, 1967 (32 FR 18033) to incorporate the proposed '112' requirements, for vehicles under 80 inches in overall width, but with an effective date of January 1, 1969. At least one amendment occurred before January 1, 1969 (See 33 FR 2994, February 15, 1968), and one interpretation (See 32 FR 8808, June 21, 1967), defining 'overall width'. A petition for review of boat trailer lighting requirements was filed in 1968, and the requirements upheld (See *Boating Industry Association* v. *Boyd*, 409 F.2d 408 (7th Cir., 1969, rehearing denied).; This is the history of the early days of Standard No. 108. The onl 'documentation' that might still exist would be microfiche copies of docket comments (Docket No. 9) which are warehoused in Virginia. The head of our technical reference service, Ms. Winifred Desmond (426-2728) may be able to assist you with these.; If you have any further questions you may call me at 426-9511. Sincerely, Z. Taylor Vinson, Senior Staff Attorney