Interpretation ID: nht94-6.33

DATE: April 14, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Ray Paradis -- Manufacturing Manager, Dakota Manufacturing Co.

TITLE: None

ATTACHMT: Attached to letter dated 3/28/94 from Ray Paradis to John Womack (OCC 9823)

TEXT:

We have received your letter of March 28, 1994, with respect to whether an intermediate side marker lamp is required on a 24-ton ramp trailer whose "overall length is 30'8" in transport position."

We interpret the term "transport position" to mean the position that the ramp is in when the trailer is in operation, the configuration depicted by the upper drawing in the sheet you enclosed. Because the overall length of the trailer exceeds 30 feet, Table I of Standard No. 108 requires that it be equipped with an intermediate side marker lamp.

We note your remarks that competing trailers are not equipped with this lamp, and have referred the matter to our Office of Vehicle Safety Compliance.