Interpretation ID: aiam1672
Jr.
President
Tag-a-Long Trailers
Inc.
P.O. Box F
Centreville
MD 21617;
Dear Mr. Martin: This responds to your November 12, 1974, question whether th Tag-a-Long Models 105A-15 & 18, 105A-21, BBFD-25, BBSB-15, and BBSB-25 trailers qualify as 'Heavy hauler trailer(s)' which are not subject to the requirements of Standard No. 121, *Air brake systems*, until September 1, 1976. 'Heavy hauler trailer' is defined in S4. of the standard as follows:; >>>'Heavy hauler trailer' means a trailer with one or more of th following characteristics:; (1) Its brake lines are designed to adapt to separation or extension o the vehicle frame, or; (2) Its body consists only of a platform whose primary cargo-carryin surface is not more than 40 inches above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent 'front-end structure' as that term is used in S 393.106 of this title.<<<; From the description you enclosed, it appears that the five models yo describe have primary cargo-carrying surfaces that are not more than 40 inches above the ground in the unloaded condition, and that they would therefore not be required to meet the standard until September 1, 1976.; I have enclosed a copy of the August 5, 1974, notice you requested. Yours truly, Richard B. Dyson, Acting Chief Counsel