Interpretation ID: nht68-2.15

DATE: 06/07/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Ideal Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: In response to your trailer lighting questions during your visit with Mr. W. R. Eason and the questions in your letter of March 26, 1968, the following information is provided.

1. Your letter of March 26, 1968, indicates provision of two red tail lamps, two red or amber stop lamps, one white license plate lamp and two red or amber turn signal lamps for compliance with Motor Vehicle Safety Standard 103 after January 1, 1969. In addition to the afore specified lamps the Motor Vehicle Safety Standard 108 requires side reflex reflectors and side marker lamps as specified in the standard. Location of all lamps and reflectors shall be in accordance with Motor Vehicle Safety Standard 10 requirements. Additional requirements are specified for trailers that are 80 inches or more overall width.

2. Your statement (March 26 letter) that, "The above may be combined and may be Class A in photometric value but Class B in size," is essentially correct except that turn signal lamps "shall" be of Class A photometric value rather than "may."

3. The provision of two Class A red reflectors and two Class A amber reflectors does not completely conform to Motor Vehicle Safety Standard 108 requirements, because four Class A red reflectors and two Class A amber reflectors are required. Two of the red reflectors are for rear mounting and two are for aft side mounting, while the two amber reflectors are forward side mounting. Your interpretation that either reflective material conforming to specification L-S-300 or reflectors conforming to SAE Standard J594C may be utilized for the side reflex reflector requirements of Motor Vehicle Safety Standard 108 is correct.

4. With regard to the question of applicability of Motor Vehicle Safety Standard 103 to chassis trailers, enclosed is a copy of Federal Register Volume 33, Number 1, dated January 3, 1968. If the chassis trailer meets the requirements of this document, primarily that it is an incomplete vehicle and is properly labeled in accordance with paragraph 255.13, then the original manufacturer need not install all of the required lighting of Motor Vehicle Safety Standard 108.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

The nomenclature as used on your proposed label drawing would be considered acceptable for certification requirements and we would appreciate your sending of an actual label sample when they are available. In addition, we would like to have for our records, the actual starting serial number that will identify your vehicles as being built on or after January 1, 1969.

Thank you for your interest in the safety program and we trust this information will be of assistance to you in regard to your inquiries.