Interpretation ID: nht73-5.17

DATE: 04/04/73

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

TO: Truck Trailer Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 19, 1973, asking whether a towbar dolly must be included in determining the overall length of semitrailers for compliance with Federal Motor Vehicle Safety Standard No. 108.

The answer is no. Standard No. 108 is a manufacturing standard, and semitrailers are not manufactured with dollies attached. 49 CFR @ 390.7, to which you refer, is a definition of the Bureau of Motor Carrier Safety which regulates the operation of certain motor vehicles, and since trailers often use converter dollies, it is understandable that that agency would deem a trailer with a dolly a "full trailer."

TRIAD SERVICES INC.

March 10, 1981

National Highway Traffic Safety Administration 400 7th St. S.W. Washington, D.C. 20590

Attn: Chief Counsel

This letter is to formally request your review and interpretation of Federal Motor Vehicle Safety Standard 108 as it relates to the placement of a clear lens cover in front of a motorcycle headlamp. The attached drawings demonstrate the specific concept in question.

Information contained in SAE standards referenced in Table III of FMVSS 108 indicates that a specific prohibition exists regarding a headlamp lens cover for passenger cars, multipurpose vehicles, trucks and busses. The SAE Motorcycle Headlamp Standard (SAE J584) contains no such prohibition. It is our understanding that a component configuration such as the one illustrated would not conflict with SAE referenced requirements.

Another section of FMVSS 108 which could relate to this issue is Paragraph S4.1.3 which states that "No . . . . automotive equipment shall be installed that impairs the effectiveness of lighting equipment required by this standard." If, when the secondary lens in question is in place, the photometric requirements of FMVSS 108 can be met or exceeded, the lens cover would then be compatible with the standard.

2

Detailed review of FMVSS 108 and the other Federal Motor Vehicle Safety Standards have revealed no other requirements germane to this issue.

Your review of our analysis will be most appreciated. We feel that the proposed concept is in keeping with the spirit as well as the letter of the law. Hopefully your review will confirm our opinion. Should you have any questions on this matter please do not hesitate to contact me.

Stephen W. Matson

[Enclosure Omitted.]