Interpretation ID: nht81-2.25

DATE: 05/12/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Gregory Equipment & Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 13, 1981, with respect to placement of identification lamps on the boat trailer you wish to manufacture.

You have informed us that the trailers are not built for transporting boats on the highways and your sales sheet reiterates that point: "These trailers are for in marina use only. Not for over the road use." Under the National Traffic and Motor Vehicle Safety Act, a vehicle that is not manufactured primarily for use on the public roads is not a vehicle subject to our regulations. From your letter and advertising enclosure, it appears that your intent is to build a vehicle that will be used primarily on private property. Therefore, our lighting requirements would not apply to it.

I hope that this answers your question.

SINCERELY,

Gregory Equipment & Manufacturing Co.

April 13, 1981

Chief Consul National Hwy. Traffic Safety Administration

Dear Sir;

I would like a ruling on the 3 cluster light for the rear of trailers. The boat trailer we are starting to manufacture doesn't have a place which such light may be mounted as shown in Picture #1. If lights were placed on the rear they would be jammed into the mud in the bottom of the river as shown in picture #2.

These lights are for the movement of the empty trailers from the plant to the sales designation. These are not built for transporting boats on the highways.

Inclosed is a brouchure. The trailer in this brochure is not equiped with lights because it is our prototype.

If any further information is needed please call me at 319-372-5314.

James E. Gregory