Interpretation ID: aiam3871
Director of Engineering
Truck Trailer Manufacturers Association
1020 Princess Street
Alexandria
VA 22314;
Dear Mr. Vierimaa: This is in reply to your letter of December 7, 1984, asking ou 'concurrence that the front clearance lamps on a trailer with a low front end or one designed to be equipped with a tarpaulin...may be mounted at the trailer frame level (about 50 inches above the ground), to avoid these lamps reflecting into the driver's eyes by way of the side view mirror.'; You thoughtfully attached a copy of my letter to you of November 10 1981 in which I advised you that 'the determination of practicability is one that is made by the manufacturer of the trailer', and that 'NHTSA will accept a determination that mounting clearance lamps at the top...is not practicable if such lamps are reflected into the driver's eyes by way of the side view mirror.' That remains our view if the configuration of any trailer is such that location of clearance lamps at or near the top of the trailer results in the reflection of the light into the eyes of the driver of the truck tractor.; Sincerely, Frank Berndt, Chief Counsel