Interpretation ID: aiam2396
Jr.
Pullman Trailmobile
200 East Randolf Drive
Chicago
Il 60601;
Dear Mr. Lungren: This responds to Trailmobile's August 13, 1976, question whether trailer would be considered to be newly manufactured for purposes of compliance with applicable safety standards if it is assembled from all new materials except for axles (axle beams, spindles and brakes, and associated brake drums, wheels, seals, and bearings) from an existing trailer whose identify and ownership would be continued in the reassembled trailer.; The answer to this question is yes. The assembly of a trailer entirel from new materials except for the trailer axles does not qualify as a 'repair' under NHTSA regulations (49 CFR S 571.7(f). This regulation states that such trailers will be considered newly manufactured unless, 'at a minimum, the trailer running gear assembly (axle(s), wheels, braking, and suspension) is not new ...' In the case you describe, the suspension would be new.; Sincerely, Frank Berndt, Acting Chief Counsel