Interpretation ID: GF003171
Mr. Timothy C. Murphy
Vice President, Engineering
Peterson Manufacturing Company
4200 East 135th Street
Grandview, MO 64030-2896
Dear Mr. Murphy:
This responds to your April 8, 2005, letter asking about clearance lamp location requirements for trailers equipped with outboard fenders.
Your letter and accompanying diagrams show a dual axle trailer equipped with outboard fenders each extending approximately 10 inches from the main body of the trailer. The outer edges of the fenders are the widest part of the trailer. Specifically, the main body of the trailer measures 81 inches, and the distance between the outer edges of the trailer measured at the fenders is 102 inches. You intend to install both front and rear clearance lamps on the top of each fender, instead of on the main body of the trailer. You ask whether this is permissible under Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices and Associated Equipment.
Table II of FMVSS No. 108 specifies that for a trailer with an overall width of 80 inches or more, the front and rear clearance lamps must be located "to indicate the overall width of the vehicle . . . and as near the top thereof as practicable."
As explained in our March 4, 1996, letter to Mr. Jerry Clay, when the widest part of a trailer is the outer edge of the fender, locating the front and rear clearance lamps on the fender satisfies the requirements of FMVSS No. 108 because the lamps would indicate the overall width of the trailer (see also, our September 4 letter to John W. Cook). By contrast, locating the clearance lamps on the main body of the trailer would not adequately indicate the overall width of the vehicle.
If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.
Sincerely,
Jacqueline Glassman
Chief Counsel
NCC-112:Gfeygin:mar:5/13/05:62992:OCC 003171
Cc: NCC-110 Subj/Chron, Redbook (2), interp 108
U:\NCC20\INTERP\108\GF003171.doc