Interpretation ID: nht73-3.45

DATE: 03/23/73

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

TO: Seminole Trailer Manufacturing Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 6, 1973 to this agency asking whether it is permissible under Standard No. 108 to locate boat trailer identification lamps on the first crossmember forward of the rearmost crossmember. You believe that the identification lamps will have a longer life span in this location.

The general locational requirement that a lamp be "on the front" or "on the rear" was never intended to specify that it be at the extreme front or rear of a vehicle. Clearance and identification lamps required to be "on the front" are generally mounted on a truck cab or body, for instance. Therefore your proposed location is acceptable to meet the requirements of Table II of the Standard. However, identification lamps, wherever located, must meet the visibility requirements of paragraph S4.3.1.1, and if they do not meet them in your proposed location the trailer will not comply with Standard No. 108.