Interpretation ID: nht69-1.11

DATE: 01/27/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: THE NEW YORK AIR BRAKE COMPANY

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 30, 1968, regarding location of reflex reflectors and side marker income relative to trailer envelope dimensions. From your subsequent phone conversation on October 18, 1968, with Mr. Zolley of our office, I understodd that you are concerned about the possible obstruction of visibility of those devices by the trailer body.

Federal Motor Vehicle Safety Standard No. 168 specifies that side marker lamps must be in accordance with SAS Standard(Illegible Words) to end reflect reflectors in accordance with SAS Standard JS94c. These standards specify photo-metric requirements for side marker lamps at angle 45o to the right and left of the lamp vertical axis and for reflex reflectors at angles 20o to the right and left of the reflector vertical axis.

Although Standard No. 108 does not specify that these devices provide the test photometrics when installed on the vehicle, it should be noted that Tables II and IV of the standard do require that the devices be located "on the side" of the car vehicle. Therefore, devices that are recessed to an extent that would impair their effectiveness would not(Illegible Words) the requirements of Standard No.(Illegible Words).

Section S3.1.1.S of Federal Motor Vehicle Safety Standard No. 108, as amended effective January 1, 1989, specifics that for trailers less than 89 inches overall wide and less than 30 feet overall length, the photometric requirements specified in SAE J502, why be(Illegible Words) or inboard less points at a distance of 15 feet from the vehicle and on a vertical plane that is perpendicular to the longitudinal axis of the vehicle and located midway between the front and rear side marker lamps. For vehicles less than 20 feet in overall length, this establishes a point less than 45o on one side of the side marker lamps. This is the only sets of relief from the requirements of SAS J592b.

I trust this information will be helpful to you. If you should have my further questions concerning safety standards, I would be most happy to discuss them with you.

Sincerely,

September 30, 1968

Office of Motor Vehicle Performance Service National Highway Safety Bureau

Attention: Bruce A. Kelley --

Room 8213A Subject: Federal Motor Vehicle Safety

Standards - May, 1968

Dear Sir

In reply to my letter concerning an interpretation of the Federal Motor Vehicle Safety Standards, Mr. John A. Hanson, Regional Federal Highway Administrator suggested that I contact your office.

The point that I would appreciate clarification on is as follows:

1. Table IV, under Columns 2 and 4, for trailers less than 80" overall width clearly defines the location of the Reflex Reflectors and Side Marker Lamps as to vertical height above the road surface and that they appear on a horizontal level plane.

2. The question arises in determining the location of said lights in relation to the trailer envelope dimensions.

Mr. Kelley suggested that SAE Standards J594c and 592b are more specific and may answer my question.

Any comment you may have to clarify this situation would be greatly appreciated.

Very truly yours,

KINNEY VACUUM DIVISION,

The New York Air Brake Company --

D. F. Rusconi --

Project Engineer