Interpretation ID: nht68-2.37
DATE: 05/27/68
FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA
TO: E.B. Buske Manufacturing Company, Incorporated
TITLE: FMVSS INTERPRETATION
TEXT: Thank you for your letter of April 19, 1968, to Dr. William Hadden, Jr., requesting comments on the proposed installation of lighting equipment and the certification label for tow trucks which are manufactured by your company.
With exceptions as listed below, the lighting equipment shows on the photograph enclosed with your letter appears to meet the location requirements of Motor Vehicle Safety Standard No. 102.
1. The front clearance lamps do not appear to be located "as near as practicable to the upper left and right exercise edges of the vehicle." Clearance lamps located further outboard on the cab would meet the requirements of the standard.
2. Standard No. 108 requires that rear indentification lamps be located "on the rear" of the vehicle. Location of these lamps beneath the truck body (for protection) would meet the requirements of the standard.
3. No red reflex reflectors are shown on the rear of the truck. The red reflector tape may be used in addition to the red reflex reflectors, but not as a substitute for the reflex reflectors.
4. No red rear side marker lamps are shown on the truck.
The photograph you enclosed of your trust has been marked to indicate possible corrections for the above discrepancies. Also enclosed is a copy of Standard No. 108.
The information you have provided in regard to certification does not fully meet the requirements of Section 114 of the National Traffic and Motor Vehicle Safety Act of 1965. For your further information, we are enclosing copies of the certification requirement and labeling requirements for chassis-cabs under the notice of ruling regarding chassis-cabs.
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. The above comments are therefore 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 Standard No. 108.