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Interpretation ID: aiam1607

Mr. B. J. Smith, President, Nabors Trailers, Inc., P.O. Box 979, Mansfield, LA 71052; Mr. B. J. Smith
President
Nabors Trailers
Inc.
P.O. Box 979
Mansfield
LA 71052;

Dear Mr. Smith: This responds to your August 21, 1974, question whether a 'logging pol trailer', which consists of a beam to which an axle-mounted bolster can be clamped at different points to accomodate (sic) different log lengths, qualifies as a heavy hauler trailer as that term is defined in Standard No. 121, *Air brake systems*:; >>>'Heavy hauler trailer' means a trailer with one or more of th following characteristics:; (1) Its brake lines are designed to adapt to separation or extension o the vehicle frame, or; (2) Its body consists only of a platform whose primary cargo-carryin surface is not more than 40 inches above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent 'front-end structure' as that term is used in S 393.106 of this title.<<<; This also acknowledges receipt of your September 5 and September 17 1974, letters on the same subject.; The logging pole trailer you describe is a heavy hauler trailer, and a such, Standard No. 121 does not apply to this trailer until September 1, 1976. The beam or 'reach', together with the bolster, constitutes the frame of the trailer, and the brake lines are designed to adapt to extension of the bolster element along the beam.; This arrangement differs from the standard highway van which has one-piece frame with an adjustable tandem axle. The purpose of this sliding arrangement is unrelated to an extension of the frame itself to accomodate (sic) the transportation of heavy or oversize loads.; Yours truly, Richard B. Dyson, Acting Chief Counsel