Interpretation ID: nht73-6.5

DATE: 11/14/73

FROM: E. T. DRIVER -- NHTSA; SIGNATURE BY CHARLES A. BAKER

TO: Browning-Ferris Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 26 to Mr. J. E. Leysath of this office concerning marker and signal lights on your Mack trucks.

Federal Motor Vehicle Safety Standard No. 108 requires that front clearance and identification lamps be located as close as practicable to the top of the vehicle. Mounting these lamps on the top of the vehicles described in your letter does not appear to be practicable because of possible damage to the lamps. If mounting the lamps on the front vertical surface near the top is, in your determination, "as close to the top as practicable," then you have met the requirements of Standard No. 108. Mounting an additional side marker lamp (which you have identified as a corner clearance lamp) on each side of the cab, near the front and top of the cab, would not be prohibited by Standard No. 108.

Turn signal lamps and hazard warning signal lamps mounted on the rear of the vehicle may be either red or amber. The color of these lamps was addressed in a Notice of Proposed Rule Making published in the Federal Register on October 25, 1972, (Docket 69-19; Notice 3). It was proposed that amber be eliminated as an optional color for these lamps, but no final decision has been made.