Interpretation ID: nht71-4.28

DATE: 10/22/71

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of October 14 you ask whether reflex reflectors on the tail gate of a pick-up truck, as shown in Figure 1 of the drawings you enclosed, meet the requirements of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

Standard No. 108 requires, in part, that reflex reflectors be mounted "on the rear" of a vehicle. Compliance with the requirements of Standard No. 108 is judged with the vehicle in its normal road operating condition. In our view, a pick-up truck is normally operated with the tail gate in a closed position, and the reflex reflectors mounted as shown in Figure 1 appear to meet the rear reflector location requirements of Standard No. 108.