Interpretation ID: nht95-2.1

TYPE: INTERPRETATION-NHTSA

DATE: March 14, 1995

FROM: Donnell W. Morrison

TO: Honorable Ricardo Martinez, Administrator, NHTSA

TITLE: RE.-49CFR571.108-S4, Table 1, 49CFR571.108-S4, Table 11

ATTACHMT: ATTACHED TO 4/10/95 LETTER FROM PHILIP RECHT TO DONNELL W. MORRISON (A43; STD. 108)

TEXT: Dear Administrator Martinez:

This in in further reference to my February 14, 1995 letter regarding the cited sections of the Code of Federal Regulations. As of this date I have not received a reply to my inquiry. A copy of the February 14 letter is enclosed.

As I indicated in my February 14 letter I am working on a project and need to know if the cited sections of the CFR have been amended to allow the rear identification lamps and the rear clearance lamps to be mounted at a location other than specified in the tables mentioned above. In other words can both the rear identification and the rear clearance lamps be mounted at bed level. The tables in Standard 108 indicate the rear lamps mentioned are to be mounted as high as practicable.

A timely response to my inquiry would be very much appreciated.

ENCLOSED LETTER:

D. W. Morrison Engr. Consultant

1005 Dr innon Drive

Morristown, Tenn. 37814

615-587 0534

February 14, 1995

Honorable Ricardo Martinez, Administrator

National Highway Traffic Safety Administration

Washington, D.C. 20590

Re:49CFR571.108-S4, Table 1 49CFR571.108-S4, Table 11

Dear Administrator Martinez:

I am doing some research on a project and need to know if your organization has amended the cited sections of the CFR.

The question has been raised since I notice many semi-trailers in operation on the highway with all of the rear lighting devices down at bed level. If I understand the wording of the cited sections correctly the identification lamps are to be mounted as close as practicable to the top of the vehicle and on the vertical center line.

If the standards have been amended I would appreciate your furnishing me with a copy of the rule making action. Notice of Proposed Rule Making and the Final Rule.

Sincerely,

DONNELL W. MORRISON