Interpretation ID: nht67-1.20

DATE: 10/02/67

FROM: AUTHOR UNAVAILABLE; George C. Neild; NHTSA

TO: Patton, Blew, Verrill, Krand and Boggs

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of August 10, 1967, you requested clarification of the application of Motor Vehicle Safety Standard No.(Illegible Word) to boat trailers.

Although a boat trailer does in some respect resemble a "pole trailer," it does not completely conform to the definition of a "pole trailer," as stated in Section 235.3 of the Initial Federal Motor Vehicle Safety Standards. This section states in part that a "pole trailer" is for transporting long or irregularly shaped loads such as poles, pipes, or structural members capable generally of sustaining themselves as(Illegible Word) between the supporting connections. The single load (a boat) on the boat trailer does not appear to meet these stated provisions of the definition.

The primary purpose of clearance and identification lights is to identify a vehicle that is 80 or more inches in overall width, regardless of the height of the vehicle. It should be noted, in this respect, that a "height-above-road-surface"(Illegible Word) for location of the lights is not specified in Standard No.(Illegible Word). Nevertheless, we have initiated a study to further determine the applicability of identification lights to best trailers.

With regard to your several questions on the use and location of side marker lights, it appears that each trailer model must be considered individually, particularly with respect to the front side marker lights. As you suggested, the extreme rear of the transverse marker provides a possible location for the rear side marker light. On those trailer models having a long transverse marker, it appears possible to locate the front side marker light on the extreme front side of the transverse marker. For those models having an extremely short transverse marker, it appears that a location as far forward as possible, exclusive of the trailer tongue, would meet the requirements of the standard.

Thank you for your interest in the motor vehicle safety standards.