Interpretation ID: nht70-2.1

DATE: 04/01/70

FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA

TO: Baker Equipment Engineering Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter to the Director, U. S. Department of Transportation dated February 19, 1970, concerning the mounting of identification lamps on your reel type trailers has been referred to this office for reply. A thorough review of our correspondence files indicates no record of our receipt of your letter of January 12, 1968, on this matter.

Federal Motor Vehicle Safety Standard No. 108 requires that all trailers (except pole trailers and trailer converter dollies), which are 80 or more inches in overall width, be equipped with rear identification lamps in accordance with Tables I and II of the standard. The standard contains no provision for exemption of specially designed trailers such as your reel type models and we have to authority to provide relief for individual manufacturers.

Identification lamps mounted on the axle of your trailer would appear to meet the mounting location requirements of Standard No. 108.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comment is for your information only and in no way relieves the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.