Interpretation ID: aiam1662
President
Truck Trailer Manufacturers Association
2430 Pennsylvania Avenue
N.W.
Washington
DC 20037;
Dear Mr. Calvin: This responds to your October 23, 1974, question in behalf of Steadma Containers, Ltd., asking if Standard No. 121, *Air brake systems*, applies to the Steadman 'liftainer', which is described as a semi-trailer frame capable of carrying 20- and 40-foot cargo containers that are loaded by means of cranes mounted at each end of the semi-trailer. The vehicle is used to move containers in terminal areas and is used on the highway only in relocation to another terminal.; The 'liftainer' is a motor vehicle as that term is defined in th National Traffic and Motor Vehicle Safety Act of 1966, because it uses the highway on a necessary and recurring basis to move between work sites. A discussion of the motor vehicle definition is enclosed for your information. As a motor vehicle, it is subject to the requirements of Standard No. 121 for trailers, effective January 1, 1975.; I have also enclosed a discussion of Standard No. 121's applicabilit to vehicles purchased by Canadians for use between Canadian and United States points. The standard would apply to Steadman trailers if they are purchased for use on U.S. highways.; Yours truly, Richard B. Dyson, Acting Chief Counsel