Interpretation ID: aiam3828
Coordinator of Technical Services
National Truck Equipment Association
25900 Greenfield Road
Oak Park
MI 48237;
Dear Mr. Herringshaw: This is in reply to your letter of February 24, 1984, with respect t mounting requirements for clearance and identification lamps under Federal Motor Vehicle Safety Standard No. 108.; Your Exhibit A depicts a body mounted on a chassis-cab, with clearanc lamps mounted both on the body and chassis-cab, but identification lamps mounted on only the chassis-cab. You have asked whether the truck body must have a set of identification lamps in order to meet Standard No. 108. The answer is yes. In order to comply with the requirements that identification lamps be located as closely as practicable to the top of the vehicle, a set of identification lamps must be provided for the truck body. You may be interested to know that there is a pending proposal which was published on February 22, 1982, a vehicle such as shown in Exhibit A would comply with a single set of identification lamps mounted on the cab. I enclose a copy of the proposal. The agency has taken no further action with respect to it.; In comparing the vehicles in Exhibit A and Exhibit B you have aske whether the one in Exhibit A is 'compliant with the intentions of FMVSS 108.' As I have just explained, this vehicle is currently noncompliant with the standard, but would comply if the proposal were adopted. The vehicle in Exhibit B meets the standard.; I hope that this answers your questions. Sincerely, Frank Berndt, Chief Counsel