Interpretation ID: nht89-1.83
TYPE: INTERPRETATION-NHTSA
DATE: 04/28/89
FROM: THOMAS A. COZ -- SENIOR ATTORNEY NORTH AMERICAN VAN LINES
TO: OFFICE OF THE GENERAL COUNSEL DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION
TITLE: HIGH-MOUNTED TRAILER STOP LAMPS/TURN SIGNALS
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 01/13/88 FROM L.F. ROLLIN -- DEPARTMENT OF CALIFORNIA HIGHWAY PATROL TO THOMAS A. COZ -- NORTH AMERICAN VAN LINES
TEXT: Dear Sir or Madam:
The purpose of this letter is to request an opinion regarding North American Van Lines, Inc. ("NAVL") use of high-mounted stop lamps/turn signals on some of our interstate highway trailer fleet. I raise this question in light of Federal Motor Vehicle Safety Standard No. 108 ("FMVSS 108") which specifies mounting heights for brake lights and turn signals on interstate motor carrier equipment.
To assist you in rendering your opinion, I enclose a photograph of a NAVL trailer which has been retrofitted with high-mounted stop lamps/turn signals on both sides of the trailer. In addition, I enclose a copy of "Final Specs," dated January 19, 198 7, pursuant to which NAVL ordered 50 trailers from the Kentucky Manufacturing Company. NAVL has received these new trailers from Kentucky Manufacturing, and they all have the high-mounted stop lamps/turn signals specified in Item 14 of the three-page "F inal Specs" sheets. Finally, I enclose a copy of a VHS-type videocassette which shows the operation of high-mounted stop lamps/turn signals on the highway.
NAVL believes these supplemental high-mounted stop lamps/turn signals are permitted under FMVSS 108. For purposes of clarity, however, NAVL hereby requests your written opinion on this question. Please send your written opinion in response to this l etter to me at the address listed above.
If you have any questions or if you need further clarification of what NAVL is asking you to do, please contact me directly. My telephone number is (219) 429-2224.
Thank you for your assistance in this matter.
Sincerely,
ENCLOSURES