Interpretation ID: nht67-1.5

DATE: 09/21/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Fire Apparatus Manufacturers Association Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 17, 1967, requesting clarification of several requirements specified in Motor Vehicle Safety Standard No. 108.

In answer to question No. 1 of your letter, the addition of a side mounted ladder would not be considered as an extension of the length of the vehicle.

Question No. 2 concerns the requirement for use of front identification lamps on open-cab fire trucks and trucks equipped with rotating red lights. We agree that the front identification lights might be slightly obscured while the emergency red lights are flashing. However, when these lights are not flashing, the identification lights would clearly identify a vehicle that is more than 80 inches in overall width. Therefore, identification lights will be required on the fire trucks which are depicted on the photographs enclosed with your letter.

With respect to question No. 3 regarding possible locations for rear identification lamps on fire trucks, it should be noted that Standard No. 108 does not specify a height requirement for location of these lamps. Therefore, a possible location for the lamps would be along the edge or under the edge of the rear step. In any event, the problem of providing the lamps does not appear to be a major one.

Question No. 4 relates to possible locations for clearance lamps on the front and rear of fire trucks. Standard No. 108 requires that clearance lamps be mounted as near as practicable to the upper left and right extreme edges of the vehicle. A provision is also included for mounting the rear clearance lamps at an optional height, when the rear identification lamps are mounted at the extreme height of the vehicle. We note from your photographs that (Illegible Word) lamps are normally mounted at approximately the extreme edges of the vehicle. It appears that a similar arrangement could be provided for mounting the clearance lamps.

Thank you for your interest in the motor vehicle safety standards.

Sincerely,

ATTACH.

FIRE APPARATUS MANUFACTURERS ASSOCIATION, INC.

July 17, 1967

George C. Nield, Acting Director -- Motor Vehicle Safety Performance Service, U.S. Department of Transportation

Dear Mr. Nield: The Technical Committee of our Association has reviewed the requirements of "Initial Federal Motor Vehicle Safety Standards, Volume 32, Number 23, Federal Register of February 3, 1967. The following questions have arisen and we request clarification.

1. Standard 108, Par. S3.1.1.2, page 2411. Your paragraph refers to 30 ft. overall length. The industry builds many pumpers that are less than 30 ft. length but occasionally the addition of a side mounted ladder will extend beyond the rear step and will increase the overall length beyond 30 ft. The Pirsch picture 5904 enclosed illustrates a ladder so mounted.

The question is - would this ladder addition be interpreted to mean a length greater than 30 ft.?

2. Standard 108, Par. S3.1.1.3, page 2411. Almost every fire truck will include a rotary type flashing red light and other flashing red lights which of necessity will impair the effectiveness of the front identification lights and would seemingly make (Illegible Word) lights (Illegible Word). Will these three front identification (Illegible Words) on a fire truck? See Pirsch picture 622 enclosed as (Illegible Words) please note Pirsch picture 6124 enclosed showing an (Illegible Words) is commonly used and advise if identification lights (Illegible Words) on this type.

3. Standard 108, page 2411, Trucks I and II. The (Illegible Words) lights do not appear to be (Illegible Word) to fire truck picture 5904, a rear step is included on the average fire truck with (Illegible Word) riding the rear step. As it is readily seen, there is no place for the three identification lights that could possibly be effective. We definitely feel that rear identification lights are not feasible on a fire truck.

4. The side clearance lights are specified to be mounted as near as possible to the upper right and left front edges and the upper right and left rear edges. Our pictures illustrate the problem of the extreme edges and we would like to know where lights should be placed on this type of vehicle.

Very truly yours, E. L. Koepenick -- Secretary-Treasurer

Encls.