Interpretation ID: aiam3769
P.E.
V.P. Production
Alloy Trailers
Inc.
P.O. Box 19208
Spokane
WA 99219;
Dear Mr. Kreshel: This is in reply to your letter of October 25, 1983, to Mr. Vinson o my staff, in which you question the practice by Fruehauf of replacing upper rear identification lamps with reflectors, on certain trailers. You asked if it were possible that the manufacturer would say that the header was too narrow for a light to fit.; I enclose a copy of an interpretation this office furnished Fruehau and the State of Wisconsin on June 18, 1981, which will clarify this issue. In summary, Fruehauf demonstrated to us the impracticability of mounting the identification lamps at the top of a vehicle of this configuration (principally because of the vulnerability of the wiring). At the time, Fruehauf expressed its concern about conspicuity of its vehicles and assured us that it would investigate ways to improve it in future production. Apparently it decided that adding reflectors at the top, at the body edges and towards the middle where the doors open, was the most satisfactory way to enhance conspicuity, given the design of the vehicle.; Thank you for your interest in this question. Sincerely, Frank Berndt, Chief Counsel