Interpretation ID: nht94-4.89

TYPE: INTERPRETATION-NHTSA

DATE: November 28, 1994

FROM: Melinda Dresser -- Manager Contracts/Transportation, Carlin Manufacturing, Inc.

TO: Philip R. Recht -- Office of Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: Attached to 1/9/95 letter from Philip Recht to Melinda Dresser (A43; Std. 108)

TEXT: Carlin Manufacturing, Inc. designs and manufactures mobile kitchens and specialty vehicles for organizations such as Pizza Hut, Burger King, McDonald's, Salvation Army, and California Department of Forestry. We also build units for off-premise caterers, fire fighters, emergency service organizations, and all branches of the armed forces.

As a vehicle manufacturer, (license #23791) our vehicles conform to applicable federal and California standards, including, but not limited to, California Department of Motor Vehicles, California Code of Regulations, and National Highway Traffic Safety A dministration.

We are currently in the final manufacturing stage for six (6) driveable "Wienermobiles" for Oscar Mayer. Since the outside structure is not a typical configuration, we are asking for a ruling determining the requirements for exterior lighting, as per 49 C.F.R. Part 571 section 108. Please review the attached drawings showing the location of the exterior lighting; including headlights, tailights, side and front markers.

Please advise at your earliest convenience, whether our application of exterior lighting for the "Wienermobile" will meet Federal Motor Vehicle Safety Standards and Regulations. Our "Wienermobile" program is on HOLD pending your determination. Since th ree of the Oscar Mayer "Wienermobiles" are scheduled for a nationwide rollout January 1, 1995, your prompt reply to this project will be greatly appreciated.

If you should have any questions, please feel to call contact our Project Engineer, Anton Holty, at 209/276-0123, for further clarification.

Thanking you in advance,

Sincerely,