Interpretation ID: 77-5.14

TYPE: Interpretation-NHTSA

DATE: December 21, 1977

FROM: Joseph J. Levin, Jr. -- Chief Counsel, NHTSA

TO: Warren M. Heath -- Commander, Engineering Section, Department of California Highway Patrol

TITLE: None

ATTACHMT: Attached to letter dated 12/29/92 from Paul J. Rice to Curtis J. Crist (A40; Std. 108); Also attached to letter dated 12/10/92 from Curtis J. Crist to Paul J. Rice (OCC 8136); Also attached to letter dated 10/8/76 from Frank Berndt (signature by Stephen P. Wood) to Donald I. Reed

TEXT:

This is in reply to your letter of November 14, 1977 asking whether section S4.3.1.3 of Motor Vehicle Safety Standard No. 108 precludes installation of front side marker reflectors and lamps on the trailer tongue.

The answer is no. S4.3.1.3 is an interpretation that such devices need not be mounted on the trailer tongue in order to comply with Standard No. 108's requirements that they be located "as a forward as practicable." Thus, alternate location 4 shown on Supplement 1 REQ BUL - 3A that you enclosed would meet Standard No. 108.

Supplement 1

Fig. 1 Boat trailer equipped with single function clearance and sidemarker lamps front and rear. Complies with Section 25100(b)(7) VC.

(Graphics omitted.)