Interpretation ID: aiam1688
Silver Eagle Manufacturing Company
10505 N.E. 2nd Ave.
Portland
OR 97211;
Dear Mr. Nottingham: This responds to your November 8, 1974, question whether permanently-attached steerable axle on a trailer is required to meet the parking brake requirements for trailer converter dollies or those for all other vehicles.; In answer to your question, the permanently-attached steerable axle yo 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.; I would like to add that, although S5.8 does not presently specif emergency braking capability for steerable axles on trailers, we intend to issue a proposal in the near future to require such performance on these axles. Your redesign plans may wish to take this upcoming proposal into consideration.; Yours truly, Richard B. Dyson, Acting Chief Counsel