Interpretation ID: aiam2040
Strick Corporation
U.S. Highway No. 1
Fairless Hills
PA 19030;
Dear Mr. Barkan: This responds to your July 17, 1975, question whether a used runnin gear assembly can be combined with a new platform to qualify as a 'repaired' trailer that would not have to conform to the requirements for air brake systems on newly-manufactured trailers (Standard No. 121, *Air Brake Systems*). I have enclosed an interpretive letter which should clarify this matter for you. Briefly, the answer is no, if the 'platform' includes the main frame members.; You also asked whether the vehicle must conform to the safety standard if it is assembled for the manufacturer's own use or if it is leased to a third party. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits not only the sale, but also the introduction or delivery for introduction in interstate commerce of vehicles which do not comply with all applicable safety standards in effect on the date of manufacture. Therefore the answer to your question is yes if the vehicle is ever operated on the public streets or highways.; Sincerely, Frank Berndt, Acting Chief Counsel