Interpretation ID: aiam1919
Truck Trailer Manufacturers Association
2430 Pennsylvania Avenue
N.W.
Washington
DC 20037;
Dear Mr. Meiselman: This responds to the Truck Trailer Manufacturers Association March 28 1975, request that the National Highway Traffic Safety Administration (NHTSA) review its position that building a trailer from new materials in combination with the running rear of an existing trailer constitutes the manufacture of a new vehicle subject to applicable safety standards. You also request confirmation that modification of the barrel of a tank trailer to replace compartments or to add to its volume does not constitute manufacture of a new vehicle.; NHTSA has already reconsidered its interpretation of what constitute the manufacture of a new truck in cases where components from an existing vehicle are used. Based on the high value of the drive train components found in powered vehicles, NHTSA has proposed an amendment of Part 571 that would supplant its earlier interpretation that, to constitute repair, the chassis of the existing vehicle must as a minimum be used in the new vehicle. The proposed amendment would establish that, in the assembly of a truck, a new vehicle is manufactured for purposes of compliance with and certification to applicable safety standards, unless the engine, transmission, and rear drive axles (as a minimum) of the rebuilt vehicle are not new, and at least two of these components were taken from an existing vehicle whose identity is continued in the rebuilt vehicle with respect to model year, vehicle identification number, and any other documentation incident to the vehicle's remanufacture and registration.; Our interpretation of what constitutes manufacture of a new traile (when use of components from an existing vehicle is involved) parallels our present interpretation of truck rebuilding in this area. We regret any confusion in our use of the term 'chassis', but we have made clear that the running gear and main frame of an existing vehicle, must, as a minimum, be used in the rebuilding of a vehicle to be considered a repair. I enclose copies of two letters which establish this point.; NHTSA does not view the manufacture of trucks and trailers a sufficiently similar to justify attempting to apply our newly-proposed position on truck rebuilding to trailer manufacture. The primary consideration of extremely high value of drive train components found in powered vehicles is not applicable to trailer manufacture. NHTSA also concludes that the economic considerations which discourage avoidance of Standard No. 121, *Air brake systems*, in truck manufacture do not operate in trailer manufacture.; In regard to tank trailer modifications where the tank serves th purpose of and replaces the frame rails, we would not consider replacement of compartments in the tank to be manufacture of a new vehicle. Similarly, the addition of volume in response to the new weight limits would not constitute manufacture of a new vehicle.; Sincerely, James C. Schultz, Chief Counsel