Interpretation ID: nht72-2.21
DATE: 01/17/72
FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA
TO: Truck Body and Equipment Association, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This is in reply to your letter of December 21, 1971, to Lawrence R. Schneider requesting an interpretation on the mounting of front identification lamps.
Standard No. 108 requires that identification lamps be mounted "as close as practicable to the top of the vehicle" (Table II). The "vehicle" is the vehicle as completed, and not the incomplete vehicle. Therefore, if the "top" of the vehicle, i.e., the highest point, is a location other than the cab, the identification lamps must be mounted at the "top", and not on the cab, if it is practicable to do so. Generally, manufacturers of van-body vehicles have found it practicable to mount identification lamps on the van body. Modified lighting diagram 0-1 which you enclosed originally depicted the correct location of identification lamps for a truck with a van body.
If the manufacturer of the cab portion of a truck has placed identification lamps on the cab, the lamps need not be removed when the lamps necessary for conformance are added at the "top."
Sincerely,
December 21, 1971 Mr.
Lawrence R. Schneider, Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION U. S. Department of Transportation
Subject: REQUEST FOR INTERPRETATION ON MOUNTING HEIGHT OF FRONT IDENTIFICATION LAMPS.
Re: Lamps, Reflective Devices, and Associated Equipment Federal Motor Vehicle Safety Standard No. 108
The above referenced FMVSS No. 108, becoming effective January 1, 1972, establishes the location and mounting heights of the front identification lamps by stating-----
" . . . as close as practicable to the top of the vehicle . . ."
"On the front only-- and No part of the lamps or mountings shall extend below the top of the vehicle's windshield."
Insofar as trailers are concerned, identification lamps are not required on the front of the trailer. The reasoning for this is that the identification lamps stop the truck tractor will serve the requirement.
We shall use a typical van body truck as an example. (See attached Lighting Diagram O-1.) It is our contention that if identification lamps are mounted on top of chassis-cab vehicles--i.e. incomplete vehicles--as supplied by the chassis manufacturers, it is permissible to leave these lamps in place. We contend that it is not necessary to remove these chassis supplied lamps, nor is it necessary to add an additional set of identification lamps at the top of the body. Of course we realize that if there are not any identification lamps on top of the cab (vehicles 80 or more inches overall width), we would be held responsible to equip the truck with front identification lamps (as close as practicable to the top of the vehicle) as required by FMVSS No. 108.
Please advise us in writing if our interpretations are correct and in full compliance with FMVSS No. 108.
Your earliest response will be appreciated.
Very truly yours,
TRUCK BODY AND EQUIPMENT ASSOCIATION --
Paul A. Tatarski
Manager Engineering Services
Enclosure:
(Graphics omitted)
FOR VEHICLES OF 80 OR MORE INCHES OVERALL WIDTH
RECOMMENDED LAMP AND REFLECTOR LOCATIONS IN ACCORDANCE WITH THE FEDERAL MOTOR VEHICLE SAFETY STANDARD NO. 108
(DRAWING IS NOT TO SCALE)
The general areas indicated for lamps and reflectors are acceptable to the U.S. Department of Transportations National Highway Traffic Safety Administration and the Bureau of Motor Carrier Safety. Consult Federal MVSS No. 108 and the applicable tables therein for exact requirements such as: mounting height limitations lamp combinations and alternative locations.
LEGEND
1. Headlamps (2)-white (4 optional)
2. Front side-marker lamps (2)-amber
3. Front side reflectors (2)-amber
4. Front turn-signal lamps (2)-amber
4a. Front turn-signal lamps (2)-amber (optional location)
5. Front identification lamps (3)-amber 5a. Front identification lamps (3)-amber (optional location)
6. Front clearance lamps (2)-amber
7. Rear side-marker lamps (2)-amber
8. Rear side reflectors (2)-red
9. Rear identification lamps (3)-red
10. Rear clearance lamps (2)-red
11. Rear reflectors (2)-red
12. Rear stop-tail & turn-signal lamps (2)-red
13. Rear licence plate lamp (1)-white
14. Rear backup lamp (1)-white (location optional provided optical requirements are met)
15. Intermediate side-marker lamps (2)-amber (if vehicle is 30' or more overall length)
16. Intermediate side reflectors (2)-amber (if vehicle is 30' or more overall length)
NOTE
LAMPS AND REFLECTORS MAY BE MOUNTED AT OTHER PRACTICABLE LOCATIONS PROVIDED LOCATION AND VISIBILITY REQUIREMENTS OF FEDERAL MOTOR VEHICLE SAFETY STANDARD NO. 108 ARE MET.
Lighting Diagram
Supplement 1/1/71