Interpretation ID: nht95-3.63
TYPE: INTERPRETATION-NHTSA
DATE: July 31, 1995
FROM: Steven B. Fisher -- Kostow And Daar, P.C.
TO: Phillip R. Recht -- Chief Counsel, NHTSA
TITLE: Re: Motor Vehicle Safety Standard No. 108
ATTACHMT: ATTACHED TO 8/30/95 LETTER FROM JOHN WOMACK TO STEVEN B. FISHER (REDBOOK 2; STD. 108)
TEXT: Dear Mr. Recht:
I am writing you in hopes of obtaining an opinion and/or interpretation concerning Safety Standard No. 108, including but not limited to Table II of such Motor Vehicle Safety Standard.
Pursuant to the above safety standard, with respect to truck, trailer identification lights (red), what is meant exactly by the word "practicable" as used in @@ 5.3.1.1, and 5.3.1.4.
Secondly, whose responsibility is it to assess, or in other words to determine, what is "practicable" and what is not "practicable" relative to the placement and location of rear, identification lamps (red). Is it the manufacturer of the particular i dentification light who provides the trailer manufacturer with tye type of identification light requested or is it the duty of the trailer manufacturer who receives the identification light for incorporation into its trailer to make such determination as they see fit in accordance with No. 108 and in light of the particular design/configuration of the trailer involved?
Third, given the "practicability" term as used in the above standard, combined with the many number of different types of trailers which are made each year and travel the public roadways, is there any way for a manufacturer of a single, rear identific ation light to know for certain, anticipate or otherwise predict where the trailer manufacturer will ultimately place and/or locate the identification lights on any given trailer?
Your cooperation and assistance concerning the above request for an advisory opinion and/or interpretation of the aforementioned standard would be greatly appreciated.
Should you have any questions, please feel free to give me a call. My direct number is 312/474-1404. Thanks again.