Interpretation ID: nht70-2.6

DATE: 04/30/70

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

TO: Tradewind Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 15, 1970, concerning the location requirements for lamps and reflectors as specified in Federal Motor Vehicle Safety Standard No. 108.

In answer to your first question, intermediate side marker lamps and intermediate side reflex reflectors are not required on trucks that are 60 inches or more in overall width and less than 30 feet in overall length.

In answer to your second question, front clearance lamps are not required on the truck body, provided the clearance lamps on the truck cab indicate the left and right extreme edges of the vehicle. For the vehicle shown on your drawing no. 130003A, it would appear that clearance lamps must be mounted on the truck body to provide an indication of the extreme edges of the vehicle. With clearance lamps on the body, duplicate lamps would not be required on the cab.

In answer to your third question, Table II of Standard No. 108 specifies that intermediate side marker lamps and reflectors be located at or near the midpoint between the forward and(Illegible Word) side marker lamps or reflectors, respectively. For side marker lamps the mounting height above the road surface is "not less than 15 inches." For side reflex reflectors the mounting height is "not less than 15 inches nor more than 60 inches." With this flexibility in mounting requirements, we are not aware of any truck body designs that would require installation of these devices "on the upper edges of the sides" of the truck bodies. Again, intermediate side marker lamps and reflectors are not required on vehicles that are less than 30 feet in overall length.

Removable sides (stakes) of farm and commercial stake-type bodies are not considered to be a permanent part of the vehicle.

Therefore, lamps and reflectors mounted on the platform bed of the body will meet the location requirements of Standard No. 108.

The alternative locations of lamps and reflectors on farm grain trucks and dump trucks, as suggested by your Drawing No. 130003A, are in conformance with Standard No. 108, except for location of front and rear clearance lamps. If such vehicles have permanent sides, the clearance lamps should be mounted "as near as practicable to the upper left and right extreme edges of the vehicle." The wording "as near as practicable" was purposely chosen to provide the vehicle manufacturer with a degree of flexibility in mounting clearance lamps on special purpose vehicles to insure that these lights will not be obscured or otherwise rendered ineffective in operation. Since certain vehicles may be covered with tarpaulins, this requirement may be met by mounting the clearance lamps as high as practicable and yet allow space for the use of tarpaulins,

Your concern for assuring compliance with the requirements of Standard No. 108 is greatly appreciated.