Interpretation ID: nht74-1.34

DATE: 01/10/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Trailmobile Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of October 25, and December 14, 1973. I regret that your earlier letter did not arrive.

You stated that your customer wishes to mount rear identification lamps at the same height from the ground as the rear turn signal, stop, tail and clearance lamps, and that, because of the shallowness of the rear header area it is not "practicable" to mount them there.

Although it may not be "practicable" to mount the Grote #272 lamp, specified by your customer, in the header area, there may be other conforming lamps that it would be "practicable" to mount in that location in a three-lamp identification array. If such lamps are available, then Standard No. 108 takes priority over contractual specifications, especially since the clearance lamps will be mounted at a point other than "as close as practicable to the top of the vehicle".

Yours truly,

ATTACH.

TRAILMOBILE TECHNICAL CENTER

December 14, 1973

Lawrence Schneider, Chief Counsel -- Dept. of Transportation

Dear Mr. Schneider:

Please find enclosed a copy of a letter dated October 25, 1973 in which I requested a ruling on the lowering of the identification lamps on the rear of a trailer under certain conditions of shallow header depth.

Today I talked with Mr. T. Vinson of your office and was advised that the letter must have been lost as he had not seen the request and further advised that I resubmit a copy of the original request.

Sincerely,

Evan Hammond -- Manager - Central Engineering

Encl.

cc: R. J. Deller; J. E. Cook; E. E. Lungren - Chicago

October 25, 1975

Lawrence Schneider, Chief Counsel -- Department of Transportation Dear Mr. Schneider:

Please find enclosed a sketch of a trailer rear end lighting arrangement, on which we are requesting a ruling with respect to conformance to M.V.S.S. no. 108.

In this particular case the customer is specifying a higher than normal rear door opening to facilitate easier loading and unloading of palatized cargo. Accomplishment of this end necessitates that the rear frame header be 2-5/8" deep. At the same time, the customer is specifying a Grote #272 lamp for the rear identification lamp function. It is not possible to mount these lamps on the shallow header in any "practicable" manner to (Illegible Word) the overall height of the trailer. We respectfully request that we may be allowed to mount the lamps to a lower level (same level as the turn signal, stop, tail and rear clearance lamps), this being "as close as practicable to the top of the vehicle" in this case.

We believe that the proposed installation is not in conflict with the intent of the safety standard as it will provide an easier and more reliable installation with simpler maintenance and at the same time, the rear lamp configuration is identical to thousands of platform trailers and container chassis safety in operation today on our highways.

A prompt reply to this request will be greatly appreciated.

Sincerely,

Evan Hammond -- Manager - Central Engineering

Encl. to all

cc: R. J. Deller; J. E. Cook; E. E. Lungren - Chicago

(Graphics omitted)

PROPOSED TRAILER REAR END LAMP CONFIGURATION WITH "SHALLOW HEADER" REAR FRAME