Interpretation ID: nht73-1.37

DATE: 11/19/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Crane Carrier Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 7, 1973, to Mr. Schneider asking whether Standard No. 108 permits four identification lamps.

It does not. The purpose of the three-lamp system is that vehicles 80 inches or more in overall width be clearly identified as large vehicles, and only the three-lamp system specified by the standard is permissible. Standard No. 108, however, allows some latitude in mounting. The system need not be mounted on the vertical centerline of the vehicle if the manufacturer determines that is impracticable. Since you appear to have made such a determination, the front identification lamp system should be placed "as close as practicable to the vertical centerline" with height and spacing requirements in accordance with Standard No. 108.

Yours truly,

NHTSA Office of Chief Counsel

Attention: Larry Schnieder

Dear Sir:

In regards to trucks of 80 or more inches, are the three (3) lamps for front identification a minimum requirement?

The front loader equipment requires a bumper guard across the center of the windshield over the cab which would obscure the center lamp. Would four (4) identification lamps be permissible, i.e., 2 on each side of the center?

I would appreciate any advice or reference to a standard.

Thanking you in advance.

Very truly yours,

Crane Carrier Company --

Darrell Gambill,

Standards Engineer