28’ Van Trailer Harness System

NORTH AMERICAN
STANDARDS &
SPECIFICATIONS
SECTION OBJECTIVES
1. Federal Requirements
2. Proper Light Specification
3. Common Legal Questions
4. ID Codes
5. Regulation Charts

1. Federal Requirements

Who’s who when it comes to lighting regulations?

DOT is the Department of Transportation. This

functions as a large governmental umbrella for anything
dealing with transportation, including the NHSTA,
FHWA, etc. The DOT lettering is often put on lights to
show that they conform to all government regulations.

NHTSA is the National Highway Traffic Safety

Administration. They regulate lighting requirements for
all new road vehicles, with the exception of pole trailers
and converter dollies. Their regulations take precedence
over state regulations and they have the power to
implement fines, recalls, and new regulations. State
Enforcement agencies often use the NHTSA regulations
for their light requirements.

FMCSA is the Federal Motor Carrier Safety

Administration. They issue Federal Motor Carrier Safety
Regulations (FMCSR). These rules regulate vehicles
over 80” wide, such as commercial vehicles and buses.
Some of these deal with lighting and wiring. Most states
inspect vehicles using these standards.

FMVSS 108 is the Federal Motor Vehicle Safety

Standard No. 108. This is the federal code (law) that
regulates lighting and performance requirements, as
well as the numbers and locations of lights on vehicles.
NHTSA publishes the 108 regulations.

CMVSS 108 is Canada’s analogous regulation

code, which is very similar to FMVSS 108. The primary
differences are that the CMVSS 108 requires daytime
running lamps and allows European headlamps, while
FMVSS 108 does not.

Transport Canada is the department of the

Canadian government which is responsible for
developing regulations, policies, and services of
transportation in Canada.

2. Proper Light Specification

When it comes time to order your next heavy-duty

vehicle, there are many decisions to consider. With so
many costs coming into play with applications other
than vehicle lighting, it is easy to justify cheaper, lesser
quality equipment. Despite being marginally cheaper
at the time of the initial purchase, purchasing basic
equipment is often more expensive in the long run.
To fully utilize industry improvements, to be sure your
vehicle meets all legal requirements, and to ensure that
the vehicle meets the expectations of maintenance staff
and vehicle operators, it is important to properly specify
the products being ordered for your vehicle.

There are two important points of interest that should be

considered prior to “spec’ing” a vehicle order.
Fleet Vehicle Maintenance History and
Review
It’s important that Fleet and Maintenance Managers
review their fleet’s vehicle maintenance and warranty
data before specifying a new vehicle build. This data
can provide key insight into any specific areas of
concern, as they relate to your particular fleet’s vehicles.
An appropriate investigation can yield weak areas on
the vehicles, or areas that require special attention.
With this data in hand, Truck-Lite Sales and Engineering
Representatives can be called upon to provide
additional information in terms of product resources
that may aid in achieving your fleet’s best lighting in an
efficient full systems approach.

Once a specification has been ordered, it can be

beneficial to have your supplier present at the first
vehicle build to ensure that the specified equipment has
been installed, is installed properly, and will optimize the
benefits it offers.

Review Industry Developments

With the growing number of new LED technologies
being developed that enhance safety, improve product
efficiency and productivity, and provide greater
functionality than ever, it’s important that time is taken
to review the latest offering.

Haitz’s Law states that every decade, the amount of

light generated per LED package increases by a factor
of 20. This has proven true since Truck-Lite’s LED
offering that dates back to the early 1990s. Due to the
energy efficiency of LED lamps vs. incandescents—a
whopping 90% reduction—the U.S. Department of
Energy has provided additional funding to accelerate
the implementation of LED lighting. This has led to the
development of LED options for work lighting, interior
lighting, auxiliary lighting, and many more offerings
that had previously not been possible. As development
grows, lamp offerings become possible, smaller profiles,
sizes, and applications. Make sure you are taking
advantage of all of the technological advancements that
are available to your fleet.

3. Common Legal Questions

What lights do I need?

Browse the NHTSA charts (shown later in this section).
Truck-Lite Tech Support (888.562.5012.) can be reached
for additional questions. Note that states cannot require
different specifications than what is in 108, but they can
add regulations.

The vehicle has everything needed for 108, but the

State Police still gave me a ticket.
States can regulate anything not covered by 108, for
example, any accessory lights or lights in addition to
those in 108. Generally, the problem lies in these areas,
though sometimes, they simply make a mistake. If it is
the latter, Truck-Lite Technical Support can often write a
letter to clarify the issue.

Is it all right to mount a light at some angle? That is,

not “square” on the vehicle?
“Maybe.” You need to contact Technical Support for a
test in that position; otherwise, it can be questioned by
the NHTSA or enforcement groups.
Can I ever use the Model 40 with the reflex reflector
ring legally?
Yes, on any vehicle under 80” wide, as an “extra” light
on vehicles over 80” (reflex is legal), or on vehicles made
in 1991 or earlier.

Is it okay to use a light for “side turn” that isn’t listed

for that function?
It is perfectly fine, because side turns are NOT legally
required. That said, be careful that it doesn’t violate
some state laws regarding color or location. If it is also
used as a side marker, that function must be listed on
the lens code.

Is SAE or DOT lettering required on lights?

No lettering is required by the NHTSA (108) except for
headlights and conspicuity tape. The Federal Motor
Carrier Safety Manual mentions that some lights should
be marked SAE but this is not enforced. Truck-Lite
marks all of their lights with SAE and/or DOT markings.

What is a combination marker/clearance light and

how do I mount it?
Simply put, it is one light doing the work of two. It must
be at a 45-degree angle (on corners) to be legal. It also
needs to be marked PC in the lens code. If there is a
question, contact Technical Support.

Are there special lighting requirements for vehicles

hauling flammable or explosive materials?
There are no special Federal requirements as 108
covers all over-the-road vehicles. Some states or
municipalities have regulations, but these cannot
supersede 108—they can only add to it. FMCSR and
the NFPA (National Fire Protection Association) publish
requirements for wire protection, as well.

Truck-Lite’s sealed lights and wiring systems have been

tested to all known standards and certification. Reports
are available from Technical Support.
108 says that some lights must be mounted as “high
as practicable or as far apart as practicable.” What
is “practicable?”
The NHTSA has stated that the vehicle manufacturer
has the responsibility to choose the best mounting
location “in light of the particular design/configuration of
the vehicle involved” and they will not contest it unless
it is “clearly erroneous.” Recently, Canada has started
to enforce the word practical as meaning “capable of
being done.” In the case of clearance markers, not more
than six inches from the edge of the vehicle is practical.

I want to add some auxiliary lights like illuminate

signs, deceleration lights, or decorative lights. Are
these legal?
Yes, provided they do not render inoperative any
device in compliance with 108, negatively affect the
performance of required equipment, or create confusion
or misunderstanding of lighting signals. Always contact
the Technical Support if you have any questions.

What is the “12-Square Inch Rule”?

On December 1, 1991, the NHTSA made effective the
final ruling regarding the 12-Square Inch Rule. This
ruling requires that the total luminous lens area for a
stop and turn lamp must not be less than 75 square
centimeters (11.625 square inches) when used on
vehicles over 80” wide.

It must be noted that the Model 40 reflex reflector ring

cannot be counted as square inch lens area. When the
reflex ring is subtracted from the total 12-inch lens, it
leaves less than the 12-square inches that are required.
4. Explanation of ID Codes

The SAE J759 Lighting Identification Code can be

difficult to interpret regarding clearance and marker
applications. This additional information may be helpful.

P2: Clearance Sidemarker and Identification Lamps

This marking is currently used for both “over” 80-
inch and “under” 80-inch vehicles. It has become the
standard for vehicles under 80-inches, but government
specifications (FMVSS-108) have never called out
increased requirements for the larger width. P2 is the
minimum standard for clearance, side marker, and
identification lights. All Truck-Lite devices meet this
standard, even if they are marked PC, P3, etc.

PC: Combination Side Marker and Clearance Lamp

or Identification for vehicles over 80-inches wide
To be used as a combination light, devices must be
mounted on a 45° bevel at the corner of a vehicle.
This allows clearance and side marker functions to
be combined in one light, and eliminates the need
for a second device. A PC light can always be used
anywhere a P2 light would have been used, but the
reverse is not true.

P3: Clearance, Sidemarker or Identification lights for

use on vehicles over 80-inches wide
A P3 designated lamp has higher light outputs than a
P2 rated lamp. It is legal wherever a P2 light would be
used. Because the federal regulations (FMVSS-108)
have yet to adopt P3, many manufacturers have not
made lights to meet the standard. Some of Truck-
Lite’s lamps do not meet this standard, and are marked
accordingly.
PC2: Combination Side Marker and Clearance or
Identification lights used on a vehicle over 80 inches
wide
PC2 Lamps meet an increased angle output, and
are designed as combination lamps. When used
as combination lamps, they must be mounted on a
45° beveled corner. Because the federal regulations
(FMVSS-108) have yet to adopt P3, many manufacturers
have not made lights to meet the standard. Some of
Truck-Lite’s lamps do not meet this standard, and are
marked accordingly.

Additional Points of Concern:

• Currently, the FMVSS-108 standard has recognized
only the standards that call for P2 or PC markings. The
other markings are for SAE recommended practices.
• The PC or PC2 lights offer the widest patterns of
visibility.
• FMVSS-108 does not require any of these lens
markings, with the exception that they accept DOT
lettering as certifying legal compliance.
• A good rule of thumb is to only buy lighting that has
the manufacturer’s name engraved on the lens and has
the SAE/DOT Identification Codes on lamps.
Lighting ID Codes:

A Reflex reflectors
A2 Wide angle reflex reflectors
C Motorcycle auxiliary front lamps
D Motorcycle and motor-driven cycle turn signal lamps
E Side turn signal lamps—vehicles 12m or more in length
E2 Side turn signal lamps—vehicles less than 12m in length
F Front fog lamps
F2 Fog tail lamps
G Truck cargo lamp
H Sealed beam headlamp
HG Discharge forward lighting (headlamp)
HH Sealed beam headlamp housing
HR Replaceable bulb headlamp
I Turn signal lamps
13 Turn signal lamps spaced from 75 mm to less than 100 mm
from headlamp
14 Turn signal lamps spaced from 60 mm to less than 75 mm
from headlamp
15 Turn signal lamps spaced less than 60 mm from headlamp
16 Rear mounted turn signal lamps and front mounted turn
signal lamps mounted 100 mm or more from the headlamp,
for use on vehicles 2032 mm or more in overall width
17 Front mounted turn signal lamps mounted less than 100
mm from the headlamp, for use on vehicles 2032 mm or
more in overall width
J590 Turn signal flasher
J945 Hazard warning signal flasher
J1054 Warning lamp alternating flasher

K Front cornering lamps

K2 Rear cornering lamps
L License plate lamps
M Motorcycle and motor-driven cycle headlamps—
motorcycle type
N Motorcycle and motor-driven cycle headlamps—motor
driven cycle type
O Spot lamps
P Parking lamps
P2 Clearance, sidemarker, and identification lamps
P3 Clearance, sidemarker, and identification lamps for use on
vehicles 2032 mm or more in overall width
PC Combination clearance and sidemarker lamps
PC2 Combination clearance and sidemarker lamps for use on
vehicles 2032 mm or more in overall width
Q Turn signal operating units—Class A
QB Turn signal operating units—Class B
QC Vehicular hazard warning signal operating unit
R Backup lamps
S Stop lamps
S2 Stop lamp for use on vehicles 2032 mm or more in overall
width
T Tail lamps (rear position lamps)
T2 Tail lamps (rear position lamps) for use on vehicles 2032
mm or more in overall width
U Supplemental high-mounted stop and turn signal lamps
U2 High-mounted stop lamps for trucks 2032 mm or more in
overall width
U3 Center high-mounted stop lamp for passenger cars, light
trucks, and MPVs
W Warning lamps for emergency, maintenance, and service
vehicles
W2 Warning lamps for school buses
W3 360 degree emergency warning lamps
W4 Emergency warning device

Continued on next page

Lighting ID Codes:

W5-1 360 degree gaseous discharge lamp—Class 1

W5-2 360 degree gaseous discharge lamp—Class 2
W5-3 360 degree gaseous discharge lamp—Class 3
Y Driving lamps
Y2 Daytime running lamps
Z Auxiliary low beam lamps