Interpretation ID: nht80-4.26

DATE: 12/09/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Iveco Trucks of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 30, 1980, asking questions with respect to the term "overall vehicle width" contained in Federal Motor Vehicle Safety Standard No. 108.

You have first asked whether door handles are a part of the vehicle to be included in the definition. The answer is that they need not be included. The definition in 49 CFR 571.3(b) excludes outside rearview mirrors and other equipment items in computing "overall vehicle width." Although the definition does not list door handles among the equipment to be excluded in determining the nominal design dimension of the widest part of the vehicle, they are substantially similar in character to outside rearview mirrors and the other equipment items listed and may be deemed included.

Your second question is whether vehicles, whose tolerances are such that they are less than 80 inches in overall width, must nevertheless be equipped with clearance and identification lamps if the basic vehicle design is such that the "nominal design dimensions of the widest part of the vehicle" is 80 inches or greater. The answer is yes. If the engineering drawings, etc. of the basic vehicle design posit an overall vehicle width of 80 inches or more, all vehicles manufactured on the basis of that specification must be equipped with clearance and identification lamps even if an occasional vehicle is produced whose overall width may be slightly less than 80 inches due to the tolerances involved.

Iveco Trucks of North America, Inc.

October 30, 1980

The Office of the Chief Counsel National Highway Traffic Safety Administration

Attn: Frank Berndt

Subject: FMVSS108 Interpretation

File: S203.108

Dear Mr. Berndt:

IVECO Trucks of North America is a wholly owned subsidiary of IVECO, (Industrial Vehicles Company) B.V. of Amsterdam, Holland. As such we act as importers into the United States of two lines of trucks. One of these lines is the new IVECO Z Range built in Brescia, Italy. It is with regard to this vehicle that we have some questions concerning FMVSS108 and request an offical interpretation. In particular, FMVSS108 makes a basic division of vehicle lighting requirements by "overall vehicle width" defined in 40 CFR, Part 571.3, Definitions. The current definition to the best of our knowledge is: "Overall vehicle width means the nominal design dimension of the widest part of the vehicle, exclusive of signal lamps, marker lamps, outside rearview mirrors, flexible fender extensions, and mud flaps, determined with doors and windows closed and the wheels in the straight ahead position."

With regard to this definition:

1) Are door handles to be considered as a part of the vehicle to be included in the "overall vehicle width" or is the intent of the definition to take into account only the major body structure as would seem to be indicated by the list of exceptions?

2) If a vehicle were designed such that the "nominal design dimensions of the widest part of the vehicle" was above 80 inches, but the tolerance was such that specific vehicles might in reality be manufactured below 80 inches.

a) Do such vehicles, which physically measure under 80 inches, require the marker/identification lamps per greater than 80" width requirements or should they more properly meet the lighting requirements for vehicles under 80"?

In affect, what is the meaning of "nominal design width" and how does it relate to compliance of vehicles which physically meet one criteria while technically appear to meet another.

These questions are of great concern to us, therefore we would appreciate as prompt an interpretive reply as possible. If clarification or additional information is required, please do not hesitate to call me at the above address and phone number. If a meeting is deemed necessary, I am likewise available. Thank you for your assistance.

Carl G. F. Pedersen

cc: N. GOODWIN