Interpretation ID: nht72-2.11

DATE: 11/21/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Mobile Aerial Towers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to the questions you asked in your letter of October 24, 1972, to Mr. Wells of the Federal Highway Administration concerning compliance with Standard No. 108 of trucks to which mobile aerial towers are mounted.

"1. The aerial tower is considered a load rather than part of the vehicle to be included in determining the overall length. Correct?"

Correct.

"2. Are amber intermediate side marker lights and/or reflectors required on the body?"

If the overall length of the vehicle is 30 feet or more, intermediate side marker lamps and reflectors are required, and they must be located at or near the midpoint between the front and rear side marker lamps and reflectors.

"3. Are amber side marker lights and/or reflectors required on the body?"

Front amber side marker lamps and reflectors are required to be mounted as far to the front as practicable on a vehicle. Generally, this is somewhere on the front fender, though in some configurations a manufacturer might determine that a location on the truck body is as far to the front as practicable.

"4. Are amber clearance lights and/or reflectors required on the front of the body?"

Yes. Front clearance lamps are required to indicate the overall width of the vehicle and to be mounted "as close to the top [of the vehicle, exclusive of load] as practicable."

"5. If a unit is over 30 ft. long, will amber side marker lights and reflectors suffice also as amber intermediate side marker lights and reflectors?"

No, they will not. As the above answers indicate, the location requirements are different for front and intermediate side markers.