Interpretation ID: nht94-4.38

TYPE: INTERPRETATION-NHTSA

DATE: September 29, 1994

FROM: Samson Helfgott -- Helfgott and Karas

TO: John Womak, Esq. -- Acting Chief Counsel, NHTSA

TITLE: Re: Our Ref. No.: 12.065

ATTACHMT: ATTACHED TO LETTER DATED 12/8/94 FROM PHILIP R. RECHT TO SAMSON HELFGOTT (A42; REDBOOK 2; STD. 108)

TEXT: I received your letter of July 20, 1994 for which I thank you (a copy of which is enclosed for your reference). At the time we had requested information with respect to the utilization of the red and amber lighting arrangement to be placed along the sid e of trucks and other vehicles. At the time, you indicated that we did not state the number and candela of the lamps and how they would be arranged along the side of the vehicle.

I now enclose an information sheet with respect to the lighting indicating what we have in mind for placement on the sides of the vehicle. The side front of the vehicle will have only yellow lights and the side rear only red. The red and yellow ligh ts will be placed in conjunction along the center of the side of the vehicle. The running lights are to be in keeping with NHTSA and/or EEC specifications.

As we previously explained, during normal vehicle operation the amber (yellow) side lamps of the system would be activated. When the brake pedal is applied, the amber (yellow) lights are extinguished and the required stop lamps and red side lamps of the system would be activated.

I would appreciate your comments whether you believe this system would be in violation of any of the Standards. I look forward to receiving your reply.

ENCLOSURE

TANKER TRAILER SIDE SAFETY SIGNALIGHT SYSTEM IN CONJUNCTION WITH NHTSA THREE LIGHT STANDARD 108 RS (RIGHT SIDE) MAJORITY OF IMPACTS LS (LEFT SIDE) BALANCE

Auxiliary Lighting System designed for sides of HAZMAT Tankers to comply or accomplish a no objections from NHTSA Standard 108

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