Interpretation ID: nht87-1.11

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: A.L. Bragg

TITLE: FMVSS INTERPRETATION

TEXT:

Ms. Erika Jones Chief Counsel UNITED STATES DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 7th Street Southwest Washington, D.C. 20590

Subject: INTERPRETATION OF PARAGRAPH S4.1.1.3 WHICH STATES: "INTERMEDIATE SIDEMARKER DEVICES ARE NOT REQUIRED ON VEHICLES LESS THAN 30 FEET IN OVERALL LENGTH"

Dear Ms. Jones:

We would appreciate it if you could clarify the above referenced section of 108 as it pertains to both tables 2 and 3 which state that trailers, both under 80 and over 80 inches, require intermediate side marker lamps. However, a footnote in both of thes e tables points out paragraph S4.1.1.3 which does not require intermediate sidemarkers on vehicles less than 30 feet in overall length. Our question is in regard to the proper interpretation of vehicles less than 30 feet in overall length. In the case of trailers, does this mean just the trailer as it sits by itself or does it include the power unit that may be pulling the trailer? In the case of straight trucks, that is, trucks in which the power unit and the trailer are not separable, our understanding is that the overall length refers to everything between the front and the rear bumpers.

Thank you for your comments. Please feel free to contact us if there are any questions.

Sincerely,

TRUCK-LITE CO., INC. A.L. Bragg Laboratory Manager

ALB/bme

cc: B. Yorks J. Swanson J. Latona B. Maternowski

Mr. A. L. Bragg Laboratory Manager Truck-Lite Co., Inc 310 East Elmwood Ave. Falconer, NY 14733

Dear Mr. Bragg:

This is in reply to your letter of October 14, 1986, in which you ask how the overall length of vehicles is calculated in determining whether they are to be equipped with intermediate side marker lamps.

With respect to trailers, you ask whether overall length includes the towing unit. No, the overall length to be calculated is only that of the trailer.

As for trucks, you assume that overall length "refers to everything between the front and rear bumpers." I assume that you are including the bumpers in the quoted phase, and that would be correct.

If you have any further questions we would be pleased to answer them.

Sincerely,

Erika Z. Jones Chief counsel