Interpretation ID: aiam1823
American Trailers
Inc.
1500 Exchange Avenue
Box 26568
Oklahoma City
OK 73126;
Dear Mr. Zajic: This responds to your February 19, 1975, request for confirmation tha the building of a trailer with some used components constitutes the manufacture of a new vehicle for purposes of meeting all applicable safety standards, unless the running gear and bottom rails, at a minimum, are from an existing trailer. You also ask for confirmation that parking brakes are not required on a steerable front axle of a full trailer.; The answer to both of your questions is yes. I enclose a copy of letter interpretation which sets out our position on the extent to which a vehicle can be 'repaired' before it becomes the manufacture of a new vehicle.; In answer to your second question, a full trailer, like all othe air-braked trailers, must meet the requirements of S5.6 *Parking brake system*. Section S5.6 permits the manufacturer the option of meeting the requirements of S5.6.1, *Static retardation force*, or S5.6.2, *Grade holding*.; If you choose to meet S5.6.1, you are not required to equip the fron steerable axle with a parking brake system. If you choose to meet S5.6.2, you may use whatever combination of parking brake systems will meet the grade-holding requirement, and such a combination may or may not include a parking brake system on the front steerable axle.; Because Standard No. 121 does not specify a secondary means of brakin on the steerable axle, the Bureau of Motor Carrier Safety requirement for automatic application of the brakes upon breakaway remains applicable to the axle (49 CFR S 393.42(d)).; Yours truly, Richard B. Dyson, Assistant Chief Counsel