Interpretation ID: nht93-3.11

DATE: April 21, 1993

FROM: Steve Reeder -- President & General Manager; Trails West Manufacturing of Idaho Inc.

TO: Taylor Vinson -- Legal Counsel, U.S. Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5-28-93 from John Womack to Steve Reeder (A41; Std. 108)

TEXT: I am writing your office for clarification of national standards for motor vehicle lighting equipment. We are a manufacturer of livestock trailers, and in reviewing the regulations that apply to our industry, I am confused on a couple of issues.

First, would our products be considered to be over 80 inches wide inasmuch as the box itself is 78 inches, but when you add the fenders to the box, it then exceeds 80 inches. Safety Standard Part 571; S-108 refers to table 2, a copy of which is enclosed, wherein clearance lamps are required on the front and rear of the vehicle to indicate overall width if it is over 80" wide. At the point where clearance lamps would be installed, the vehicle is less than 80 inches in width, but as stated earlier, the overall width including fenders does exceed the 80 inches.

Also, in regards to side marker lamps, would table 2 apply wherein there is no height restrictions, or would table 4 apply (copy enclosed) which requires rear side marker lamps to fall between 15 inches and 60 inches. In regards to the length of a trailer for purposes of determining the need for intermediate side marker lamps is the gooseneck or 5th wheel portion of the trailer which extends over the tow vehicle to be included in calculating overall length. Also, would front clearance lights be required where the gooseneck or 5th wheel portion of the trailer extends over the tow vehicle.

The second issue I am concerned about relates to safety chains. Could you provide our company with current regulations for safety chains as they relate to the products we manufacture. It is my understanding that safety chains are not required where a 5th wheel hookup is used, but are required on products such as ours where the attachment point is typically inside the box of a pickup or light duty truck bed and the method of attachment is a ball and coupler.

It seems inconsistent that a recreational type vehicle such as a travel trailer which utilizes a 5th wheel connection on a pickup or a light duty truck would not require safety chains, but a stock trailer which we refer to as a gooseneck that utilizes a ball and coupler and attaches similarly in the bed of a pickup or light duty truck would require safety chains.

I am enclosing a brochure of our products for your information. If the clarification I am asking for is not clear, could you please call me at the office number of (208) 852-2200 at your convenience. We appreciate any help and insight you are able to provide.

Attachments:

- Motor Vehicle Safety Standard No. 108 -- Lamps, Reflective Devices, and Associated Equipment -- Passenger Cars, Multipurpose Passenger Vehicles, Trucks, Buses, Trailers, and Motorcycles (Docket No. 69-18) (S1.-S5.1.1.4)

- Table II -- Location of Required Motor Vehicle Lighting Equipment

- Table IV -- Location of Required Equipment

(Text omitted.)