Interpretation ID: aiam1737
Senior Engineer
FMC Corporation
1180 Coleman Avenue
Box 580
Santa Clara
CA 95052;
Dear Mr. FitzMaurice: This responds to your December 17, 1974, request for confirmation tha FMC Corporation's air-braked tilt-bed trailer, which has a primary cargo-carrying surface less than 40 inches from the ground, qualifies as a 'Heavy hauler trailer' and, as such, is not required to meet the requirements of Standard No. 121, *Air brake systems*, until September 1, 1976.; 'Heavy hauler trailer' is defined in 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.<<<; The tilt-bed trailer, which you describe in detail in your November 14 1974, letter, has a bed height of less than 40 inches and therefore qualifies for exemption until September 1, 1976.; Yours truly, Richard B. Dyson, Acting Chief Counsel