Interpretation ID: aiam1684
F.T.E. Industries
Inc.
P.O. Box 7209 Cody Station
4225 Quinlan
Flint
MI 48507;
Dear Mr. Underwood: This responds to your November 11, 1974, question whether th Model-FTE468T42 trailer qualifies as a 'heavy hauler trailer' which is 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 trailer has primary cargo-carrying surface that is not more than 40 inches above the ground in the unloaded condition, and that it would therefore not be required to meet the standard until September 1, 1976.; Yours truly, Richard B. Dyson, Acting Chief Counsel