Interpretation ID: nht72-2.13

DATE: 11/20/72

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

TO: The Grote Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 18, 1972, to Mr. Schneider asking for an interpretation of paragraph S4.3.1.3 of Motor Vehicle Safety Standard No. 108. You have enclosed photographs of boat trailers marked to show your understanding of the language "as far forward as practicable" and ask for our views.

Table II and Table IV of Standard No. 108 require that front side reflex reflectors and lamps on trailers, including boat trailers, be located as far to the front as practicable, Recognizing that a literal interpretation of the standard would require that these devices be installed on the trailer tongue and that in many instances it would be impracticable to do so, the NHTSA added paragraph S4.3.1.3 to allow a location as far forward as practicable exclusive of the trailer tongue." The intent of the regulation is that the device be mounted as far to the front of the vehicle as the manufacturer determines is practicable, and a definition of "trailer tongue" is immaterial for this purpose. If the angled portion of the frame is deemed "practicable", and the device is located there, it must be mounted, as you suggested, in a position such that it meets the photometric requirements at the specified angles with respect to the vehicle.