Interpretation ID: nht71-4.48

DATE: 11/16/71

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Barber-Greene Company

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive our delay in responding to your letter of August 27, 1971, asking if Department of Transportation safety equipment applicable to trailers is required for portable asphalt mixing machinery.

It is our current position that portable asphalt mixing machinery is a "trailer" and must be equipped with the lamps and reflectors required by Motor Vehicle Safety Standard No. 108. I am enclosing a copy for your information. A temporary lighting harness is an acceptable means of conformance. Mud flaps, incidentally, are not required under the Federal motor vehicle safety standards.