Interpretation ID: aiam4188
Vice-President
Engineering
The Grote Manufacturing Company
2600 Lanier Drive
Madison IN 47250;
Dear Mr. Newman: This is in reply to your letter of December 10, 1985, asking for a interpretation regarding two proposed locations for clearance lamps. As you know, our response has been delayed because the original letter lacked one of the two drawings necessary for us to reply to your questions.; You have paraphrased S4.3.1.1.1 of Standard No. 108 as stating 'in par that clearance lamps need not be mounted on the front or rear and at such a location need not be visible at 45 degrees inboard.' That is not exactly what that section permits. It states that 'Clearance lamps may be mounted at a location other than on the front and rear if necessary to indicate the overall width of a vehicle, or for protection from damage during normal operation of the vehicle, and at such a location they need not be visible at 45 degrees inboard.' Your first request for an interpretation concerns a 'fixed body with additional equipment mounted on the box,' and depicts clearance lamps that are mounted on the front of a structure behind the cab, and yet are not visible at 45 degrees inboard. You have asked whether this meets the intent of S4.3.1.1.1. The plan view diagram in your letter indicates that the clearance lamps if mounted on the front (i.e., the cab) would not be located to indicate the overall width of the vehicle. But when mounted on the structure behind the cab, they appear located so as to indicate the overall width of the vehicle. You have not mentioned mounting height, but we assume that they are 'as close to the top as practicable' in accordance with the requirements of Table II of Standard No. 108. Therefore the exception permitted by S4.3.1.1.1 would apply.; Your second request covers a 'side mounted clearance lamp, and state that 'Because of box construction and box size, a side mounted clearance lamp is a better location.' In this location, the inboard visibility requirements would not be met. You asked whether this would meet the intent of S4.3.1.1.1.; The intent of S4.3.1.1.1 is that the alternate location indicate th overall width of the vehicle. If we judge compliance by the plan view of the diagram, then the location on the second diagram is acceptable. But in this location the inboard angle of visibility would be even less than in the first diagram, and the overall width of the vehicle would be less apparent to an incoming (sic) driver. Given the fact that you have presented us with alternative means by which you may meet S4.3.1.1.1 we cannot conclude that the location shown in the second diagram complies with Standard No. 108.; Sincerely, Erika Z. Jones, Chief Counsel