Interpretation ID: nht87-1.46

TYPE: INTERPRETATION-NHTSA

DATE: 03/06/87

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: JOHN GRIFFIN -- PRESIDENT FRAZER, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 11/17/86 FROM JOHN GRIFFIN TO TAYLOR VINSON, OCC 1443

TEXT: Dear Mr. Griffin:

This is in reply to your letter of November 17, 1986, to Taylor Vinson of this Office with respect to the status of identification and clearance lamps on emergency medical service vehicles (ambulances).

You believe that Federal requirements often present a conflict with respect to installation of these lamps at locations specified by the Standard. As an example you have cited "a light bar above the double rear doors may be placed as high as possible an d thereby give no room for identification lights." You have asked for a clarification of Federal requirements.

You are correct that Standard No. 108 does not exempt emergency-type motor vehicles from compliance; further, it contains no special provisions for them. This means that the final-stage manufacturer of such vehicles must meet the same requirements as the manufacturers of other vehicles whose overall width exceeds 80 inches, and give priority in lamp placement to fulfilling the locational requirements of Table II of Standard No. 108. The requirements for clearance and identification lamps are expressed in terms of practicability, however, and the determination of whether a certain location is "practicable" is initially that of the manufacturer who installs them. There may be State laws governing the placement of lightbars, or practical considerations that may necessitate placing identification and clearance lamps at a position other than "as close as practicable to the top of the vehicle", and in these instances the lamps may be located at a lower height than they would be were the lightbar absent. The lamps, however, cannot be omitted and the agency retains the right to review the determinations of the manufacturer.

I hope that this provides the guidance that you seek. If we may be of further help, please let us know.

Sincerely