Interpretation ID: 1985-02.14

TYPE: INTERPRETATION-NHTSA

DATE: 04/16/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. John L. Strickland

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. John L. Strickland J.S. Welding Rt. 5 Box 496 Denham Springs, Louisiana 70726

Dear Mr. Strickland:

I am responding to your February 20, 1985 request for information regarding Federal regulation of trailer manufacturing.

There is no Federal Licensing requirement for the manufacture of trailers, which are considered motor vehicles under Federal law. As a manufacturer of a motor vehicle, however, you must submit identification information to the National Highway Traffic Safety Administration under 49 CFR Part 566, Manufacturer Identification. You must also certify that each trailer complies with all applicable Federal regulations. The procedure is specified in 49 CFR Part 567.

At this time, the only safety standards applicable to all trailers are Safety Standard No. 108, Lamps, reflective devices, and associated equipment, Safety Standard No. 120, Tire selection and rims for motor vehicles other than passenger cars, and Safety Standard No. 115, Vehicle Identification Number-Basic Requirements. The content requirements for the vehicle identification number are found at Part 565. Trailers with certain braking systems also must meet Safety Standard No. 106, Brake hoses, Safety Standard No. 116, Motor vehicle brake fluids, and Safety Standard No. 121, Air brake systems. These standards are found in Part 571 of 49 CFR.

I am enclosing an information sheet that explains how you can obtain copies of these regulations. If you have any further questions, please feel free to contact me.

Sincerely,

Original Signed By

Jeffrey R. Miller Chief Counsel Enclosure

February 20, 1985

National Hwy. Traffic Safety Admin. Office of Chief Council 400 7th Street Washington, D.C. 20590

Dear Sirs:

I need all information on what I need to obtain the necessary manufacturing license for this operation.

The trailers will range from approximately 6' long by 6' wide; 1 axle - gross weight of 750 to 1500 pounds - to 20' long by 6' 6' wide; 3 axles - gross weight of 20,000 pounds.

As it stands in our business at the present we will be building between 10 and 20 trailers a year.

We are new in this field, if you need more information please contact me.

Yours truly,

John L. Strickland J. S. Welding Rt. 5 Box 496 Denham Springs, Louisiana 70726 504 - 6644593