Interpretation ID: nht73-1.31

DATE: 12/04/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Young Daybrook, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 16, 1973 asking about the proper location of indentification lamps on one-man truck-tractor cabs that are offset from the vertical centerline of the vehicle. In your view "when the Law is applied to one (1) man cabs, the possibility exists that oncoming traffic would interpret the truck as not being in its proper traffic lane."

As you have pointed out, front identification lamps are required by Table II of Standard No. 108 to be "as close as practicable to the tope of the vehicle . . . as close as practicable to the vertical centerline. . . ." The "vertical centerline" is that of the vehicle which is usually that of the cab as well. However, an identification lamp arrangement around the vertical centerline of an offset cab is considered to meet the standard.

We are not aware that an actual safety problem is presented by the current practice of mounting identification lamps around the centerline of offset cabs, and the fact that you produce less than 1,000 vehicles per year does not relieve you of the requirement of providing these lamps.

Yours truly,

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Young Daybrook Inc.

November 16, 1973

U.S. DEPARTMENT OF TRANSPORTATION -- NATIONAL HIGHWAY SAFETY ADMINISTRATION

Gentlemen:

We request your assistance in interpreting FMVSS #108; Lamps etc., as applied to the vehicles we manufacture under the "OTTAWA" name and illustrated in the attached brochure #30-2500-4/73. These vehicles are all over 10,000# GVW; all over 80" in width; and all have one (1) man cabs, either 37" or 48" wide; located left of centerline of the vehicle.

The Law requires all truck tractors to have three (3) amber identification lamps "As close as practicable to the verticle centerline". When the Law is applied to one (1) man cabs, the possibility exists that oncoming traffic could interpret the truck as not being in its proper traffic lane.

Your earliest possible response would be appreciated and should it be pertinent, we produce fewer than 1000 trucks per year.

Very truly yours, James H. Swinghammer -- Assistant Chief Engineer

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