Interpretation ID: nht70-1.15

DATE: 10/01/70

FROM: C. A. Baker for R. H. Compton; NHTSA

TO: Barrington Homes of Florida, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 14, 1970, to Mr. Rodolfo A. Diaz, Acting Associate Director for Motor Vehicle Programs, National Highway Safety Bureau concerning clearance lights on mobile homes.

A mobile home moved on its own wheels is a "motor vehicle" under the National Traffic and Motor Vehicle Safety Act, and is categorized as a "trailer".

Federal Motor Vehicle Safety Standard No. 108 requires clearance lamps to be installed on trailers 80 or more inches in overall width. In transit a mobile home towed on its own wheels must therefore be equipped with clearance lamps; however, these lamps may be temporarily installed and removed when the mobile home has reached its destination.

We would appreciate your providing us, if possible, with the names of manufacturers of mobile homes whom you believe to be towing these vehicles without equipping them with lighting devices meeting Standard No. 108. This will assist us in our efforts to insure that all manufacturers meet their obligations under the Act.