Interpretation ID: aiam1483
Project Engineer
American Trailers
Inc.
5702 E. Admiral Place
15708 Admiral Station
Tulsa
OK 74115;
Dear Mr. Zajic: This responds to your April 12, 1974, question whether a permanentl attached steerable axle on a trailer is required (1) to meet the S5.3.2 stopping distance requirement with no uncontrolled lockup of any wheel above 10 mi/h, and (2) to meet the parking brake requirements for trailer converter dollies or for all other vehicles.; The answer to your first question is yes. The steerable axle(s) of an trailer must meet the stopping distance requirements of S5.3.2 with no uncontrolled lockup of wheels above 10 mi/h.; In answer to your second question, the permanently attached steerabl axle you describe is not a separate vehicle which would qualify as a trailer converter dolly. Therefore the axle is simply part of a trailer which must meet the parking brake requirements of either S5.6.1 or S5.6.2. Neither of these options specifies that there be parking brakes on steerable axles, although in satisfaction of S5.6.2 (grade holding), the manufacturer could utilize parking brakes on the steerable axle.; Yours truly, Richard B. Dyson, Chief Counsel