Interpretation ID: cowley.ztv

Mr. Vance B. Cowley
International Equipment Distributors
Woods Cross, UT 84087

Dear Mr. Cowley:

This is in reply to your recent letter asking about the "placement and quantity of marker lamps required on a truck" your company is manufacturing. The overall length of the truck is 31 feet 6 inches. You have provided two drawings depicting the lamps presently installed and would like us to indicate where any additional lamps and reflectors should be located, and the color of such lamps and reflectors.

I enclose a copy of Federal Motor Vehicle Safety Standard No. 108, and a chart "Federal Lighting Equipment Location Requirements" applicable to trucks, buses, and multipurpose passenger vehicles, which was jointly issued by the National Highway Traffic Safety Administration and Transport Canada. These will provide you with the requirements relating to the number and location of all lamps and reflectors on your truck. Among other things, Standard No. 108 requires rear identification and clearance lamps to be mounted on the rear of a truck, not the rear of the truck cab. Furthermore, intermediate side marker lamps are required to be amber, not red. Your drawings appeared to deviate from these requirements.

If you have any questions about the chart in connection with your design, you may call Rich Van Iderstine in our Office of Rulemaking (202-366-2720).

Sincerely,

Z. Taylor Vinson
Senior Attorney

Enclosures
ref:108
d.5//14/03