Interpretation ID: aiam2244
Assistant Manager
Titan Trailer Corporation
1202 East Kentucky
P.O. Box 1517
Woodland
CA 95695;
Dear Mr. Tucker: This responds to Titan Trailer Corporation's March 2, 1976, questio whether certain bulk grain and feed meal trailers manufactured by Titan qualify as bulk agricultural commodity trailers that are permitted until June 30, 1976, to meet emergency and parking brake requirements other than those specified in S5.6 and S5.8 of Standard No. 121, *Air Brake Systems*.; Sections S5.6 and S5.8 provide that a trailer manufactured before Jun 30, 1976, that is designed to transport bulk agricultural commodities in off-road harvesting sites and to a processing plant or storage location, as evidenced by skeletal construction that accomodates (sic) harvest containers, a maximum length of 28 feet, and an arrangement of air control lines and reservoirs that minimizes damage in field operations, is entitled to a specified option.; From the descriptive material enclosed, it appears that the Tita models 92 and 24 are designed for field use and conform to the criteria of skeletal construction that accomodates (sic) a harvest container, despite the fact that the container is permanently attached to the frame that surrounds it. It is not clear that the trailers are not more than 28 feet in length, or that the design positions air lines and reservoirs to minimize field-related damage. Assuming that the length, air lines, and reservoirs do meet these criteria, it appears that the trailers would qualify for the manufacturer option under S5.6 and S5.8.; Yours truly, Frank Berndt, Acting Chief Counsel