Interpretation ID: nht91-7.33

DATE: December 5,1991

FROM: Harvey D. Benson -- Chief Engineer, Landoll Corporation

TO: Richard Carter -- Office of Vehicle Safety Standards, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/3/92 from Paul Jackson Rice to Harvey D. Benson (A39; Std. 121)

TEXT:

I need answers for two questions:

1. Is a HEAVY HAULER TRAILER required to have spring brades? We manufacture tandem and triple axle trailers with capacities up to 12O,OOO GVWR which have load carrying decks less than 40 inches above the ground. Our understanding of 49 CFR Ch V, 571.121 is that spring brakes are not required but there may be other regulations which apply.

I have had customers call stating that they were ticketed for not having spring brakes. I need a definitive statement referencing specific regulations to answer this question.

2. What are the requirements for bulkhead (cab protection) on truck chassis beds? We manufacture slide back beds mounted on single and tandem axle truck chassis. I have not been able to find requirements as to size and impact capacity for cab protecting bulkheads.