Interpretation ID: nht71-3.33

DATE: 07/14/71

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Airstream Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 25, 1971, to Mr. Douglas W. Toms, Acting Administrator, National Highway Traffic Safety Administration, concerning lamp locations proposed for your 1972 Airstream trailer.

Federal Motor Vehicles Safety Standard No. 108, as amended October 31, 1970 and February 3, 1971, effective January 1, 1972, requires that clearance lamps be mounted to indicate the overall width and as near the top as practicable. Paragraph S4.3.1.5 permits optional mounting height of rear clearance lamps when the rear identification lamps are mounted at the extreme height of a vehicle.

The front and rear clearance lamps mounted as shown on your drawing 10033, revision C, do not appear to meet these location requirements. These lamps could be mounted higher than shown and still indicate the overall width of the trailer at locations other than the upper right and left corners, perhaps as high as the front and rear windows.

In addition, the side reflex reflectors are to be located as far to the front and rear of the vehicle as practicable. Neither the front nor rear side reflex reflectors shown on the subject drawing appear to meet this requirement.