Interpretation ID: 8992
President
Sierra Products, Inc.
1113 Greenville Road
Livermore, CA 94550
Dear Mr. Moore:
We have received your letter of August 12, 1993, "requesting a legal clarification detailing where FMVSS 108 requires a Clearance Light to be mounted." It is clear from your letter that it is the lateral spacing of clearance lamps that concerns you as you believe that it is not uncommon to see them mounted as much as 6 to 8 inches "'inside' the side extremities of huge vehicles."
With respect to lateral spacing, Table II of Standard No. 108 requires clearance lamps to be mounted "to indicate the overall width of the vehicle . . . ." The standard does not require the lamps to be mounted at the widest point of the vehicle, nor does it require them to be mounted as far apart as practicable. We believe that manufacturers generally try to mount clearance lamps to "indicate" the overall width of the vehicle, but we recognize that there may be certain circumstances and/or configurations that require mounting of the lamps at something less than the widest point.
Sincerely,
John Womack Acting Chief Counsel
ref:108 d:11/16/93