Interpretation ID: nht95-2.53

TYPE: INTERPRETATION-NHTSA

DATE: April 25, 1995

FROM: Donnell W. Morrison

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

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

ATTACHMT: ATTACHED TO 5/19/95 LETTER FROM JOHN WOMACK TO DONNELL W. MORRISON (A43; STD. 108)

TEXT: Dear Mr. Recht:

This responds to your April 10, 1995 reply to my February 14 and March 14, 1995 letters regarding the cited sections of the CFR.

If I understand your response the above cited sections of the CFR have not been amended since I left the DOT in March 1980. I therefore must conclude that the rear identification lamps required by 49CFR571.108 must be mounted as close to the top of the vehicle as is practicable.

My inquiry of March 14, 1995 mentioned the fact that I have seen many semitrailers on the highway with all the rear lights at bed level. By all lights I mean clearance, identification, stop, tail and turn signal lamps.

If the FMVSS108 has not been amended to allow all the rear lighting devices to be mounted at bed level has the NHTSA issued an interpretation to allow such mounting. If such an interpretation has been issued would it be possible for you to furnish me a copy.

I need to know where the rear lights have to be located to be able to finish my project and would appreciate a prompt response.