Interpretation ID: aiam0511
Engineering Manager
Truck Trailer Manufacturers Association
1413 K Street
N.W.
Washington
DC 20005;
Dear Mr. Grey: This is in reply to your letter of November 11, 1971, concerning th application of GVWR and GAWR (49 CFR Parts 567, 568) to semitrailers.; Your position is that the term 'gross vehicle weight rating' is no meaningful when applied to semitrailers because the amount of cargo a semitrailer can carry depends upon the tractor that pulls it. You request that a different expression, 'rating based on load-carrying capability' be used 'for purposes of certification' (assumedly on the certification label). If that alternative is found unsatisfactory you request our concurrence with the following: 'For semitrailers, GVWR shall be taken to mean the structural capability of the vehicle when supported by the king-pin and axles with the load uniformly distributed throughout its length.' You also mention that gross vehicle weight rating has particular industry meaning and note that confusion' will certainly arise when state and Federal governmental authorities are using the same term to mean two different things.'; As we indicated in our meeting with you of November 4, 1971, we do no agree that the concept of GVWR is meaningless when applied to a semitrailer. The definition of GVWR, 'the value specified by the manufacturer as the loaded weight of a single vehicle' (49 CFR S 568.3), can be applied to a semitrailer without considering the load-carrying ability of a tractor. The fact that certain tractors should not be attached to a particular semitrailer loaded to its GVWR does not mean that the trailer cannot be so rated.; With regard to your first question, 'rating based on load-carryin capability,' while we do not grant your request that this language be substituted on the label, we believe that a GVWR based on operational load- carrying capability, as long as the weight of the vehicle is included, would be within the definition of GVWR in 49 CFR 568.3. Similarly, your other statement, 'For semitrailers, GVWR shall be taken to mean the structural capability of the vehicle when supported by the king-pin and axles with the load uniformly distributed throughout its length' is likewise consistent with the definition of GVWR. With reference to your claim concerning confusion of State and Federal regulation, we believe that if problems in this regard are properly presented to State government, any ambiguities can be satisfactorily resolved.; You also ask, with reference to Gross Axle Weight Rating, whether spee limitations can be included on the certification label. The regulation does not allow such weight limitations to be included within the listing of the required information, although it may be placed on the vehicle in any other location.; Sincerely, Richard B. Dyson, Assistant Chief Counsel