Interpretation ID: nht72-2.18

DATE: 10/03/72

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

TO: Schlen Body and Equipment Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 22 to Mr. Ed Leysath of this Office regarding Interpretations of FMVSS No. 108 on required mounting of marker lights on your dump trailers.

In answer to your first problem, a combination front clearance and side marker lamp must meet the requirements for both; therefore, the full 180-degree visibility is required. If you determine that it is not practicable to mount the combination lamp in your alternate location, because of a greater possibility of damage, then separate lamps should be considered.

In answer to your second problem, because of the configuration and end use of your dump semi-trailers, your interpretation that rear clearance lamps mounted in a light box just below the rear trailer crossmember are as high as practicable is correct.