Interpretation ID: aiam2332
Executive Engineer
Peterbilt Motors Company
38801 Cherry Street
P.O. Box 404
Newark
CA 94560;
Dear Mr. Riggs: This reponds (sic) to Peterbilt Motor Company's June 9, 1976, question whether Standard No. 121, *Air Brake Systems*, contains a permanent exclusion for 'auto transporters' and whether 'auto transporter' would include a truck-trailer vehicle combination that includes a dromedary forward of the fifth wheel to hold empty tin cans that are loaded by means of the trailer. I would like to note that I am unaware of 'discussion and interpretive rulings suggested through telephone contact' with this office.; Your interpretation is not correct that the exclusion for 'aut transporters' is permanent. Some confusion may arise from the words in S3 to describe the exclusion until September 1, 1977. The phrase 'or to any vehicle which' that appears at the end of the second sentence in S3 will shortly be modified to 'or that' to improve the structure and clarity of the sentence.; Your question whether a 'can hauler' qualifies as an 'auto transporter appears to be based on the proposed wording of this definition that was modified in final form. As defined in the standard, 'auto transporter' means:; >>>. . .a truck and a trailer designed for use in combination t transport motor vehicles, in that the towing vehicle is designed to carry cargo at a location other than the fifth wheel and to load this cargo only by means of the towed vehicle.<<<; It is clear from this definition that a 'can hauler' would not qualif as an 'auto transporter' subject to the exclusion.; Sincerely, Frank Berndt, Acting Chief Counsel