Interpretation ID: nht88-1.15
TYPE: INTERPRETATION-NHTSA
DATE: 01/13/88
FROM: L.F. ROLLIN -- COMMANDER COMMERCIAL AND TECHNICAL SERVICES SECTION DEPARTMENT OF CALIFORNIA HIGHWAY PATROL
TO: THOMAS A. COZ -- LAW DEPARTMENT NORTH AMERICAN VAN LINES
TITLE: NONE
ATTACHMT: ATTACHED TO LETTER DATED 08/24/89 FROM STEPHEN P. WOOD -- NHTSA TO THOMAS A. COZ -- NORTH AMERICAN VAN LINES; REDBOOK A34; STANDARD 108; LETTER DATED 04/28/89 FROM THOMAS A. COZ -- NORTH AMERICAN VAN LINES TO NHTSA, RE HIGH MOUNTED TRAILER STOP LAMPS/TURN SIGNALS; OCC 3469
TEXT: Dear Mr. Coz:
This is in response to your December 30, 1987, letter requesting an "Experimental Devices Permit" for high mounted stop lamp/turn signals which are installed on some North American Van Lines trailers.
No experimental device permit is necessary since these supplemental lamps are currently permitted by the California Vehicle Code. However, these lamps are in violation of Federal Motor Vehicle Safety Standard 108 (FMVSS 108). FMVSS 108 specifies mounti ng heights for brake lights (not less than 15 inches nor more than 72 inches) and turn signals (not less than 15 inches nor more than 83 inches) above the level roadway surface. Both the trailer specifications and the trailer picture you provided show t he lamps to be mounted above the mounting heights specified in FMVSS 108.
The National Highway Traffic Safety Administration (NHTSA) confirmed that all brake lights and turn signals installed by a manufacturer of vehicles must conform to the FMVSS 108 mounting requirements. NHTSA does not differentiate between required or "su pplemental" lights on trailers. The FMVSS 108 restrictions on mounting do not apply to equipment installed by the owner.
If you have any questions, please contact Mr. Ellis Hirst our staff engineer for clarification.
Very truly yours,