Interpretation ID: nht94-6.11

DATE: April 25, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Richard Kreutziger -- Executive Director, New York State Bus Distributors Ass'n.

TITLE: None

ATTACHMT: Attached to letter dated 4/13/94 from Richard Kreutziger to John Womack (OCC-9865)

TEXT:

This responds to your request of April 13, 1994, for an interpretation of Motor Vehicle Safety Standard No. 108.

You reference paragraphs S5.5.7(a) and (b) which apply to vehicles of less than 80 inches overall width and ask whether there are similar requirements for wider vehicles.

Paragraph S5.5.7(a) requires that "(w)hen the parking lamps are activated, the tail lamps, license plate lamps, and side marker lamps shall also be activated." There is no similar requirement for vehicles whose overall width is 80 inches or more because these vehicles are not required to have parking lamps (see Table I of Standard No. 108).

Paragraph S5.5.7(b) requires that "(w)hen the headlamps are activated in a steady-burning state, the tail lamps, parking lamps, license plate lamps and side marker lamps shall also be activated." Paragraph S5.5.3 requires tail lamps on all vehicles, regardless of width, to be activated when the headlamps are activated in a steady burning state. As noted in the preceding paragraph, wide vehicles are not required to have parking lamps.

This leaves the question of license plate lamps and side marker lamps. As you have surmised, there is no specific requirement in Standard No. 108 that these lamps be simultaneously activated with the headlamps on vehicles whose overall width is 80 inches or greater. However, we understand that it is industry practice to wire its large vehicles in this manner. We also believe that those who do not wire the side marker lamps to operate with the headlamps include them in the separate switch that activates the clearance and identification lamps.