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Interpretation ID: aiam1996

Mr. Richard A. Fisher, Wenger Corporation, Owatonna, MN 55060; Mr. Richard A. Fisher
Wenger Corporation
Owatonna
MN 55060;

Dear Mr. Fisher: This responds to your July 10, 1975, question whether an air-brake trailer which was begun before the effective date of Standard No. 121, *Air brake systems*, can be completed after the effective date of the Standard without complying with the requirements of the standard.; Section 571.7 of Title 49, Code of Federal Regulations, establishes th point at which the Federal motor vehicle safety standards apply to the manufacture of motor vehicles and states in part: '. . . each standard . . . applies according to its terms to all motor vehicles or items of motor vehicle equipment the manufacture of which is completed on or after the effective date of the standard.' Therefore, the trailer you describe must conform to the requirements of Standard No. 121 if it is completed after January 1, 1975.; I have enclosed a copy of a *Federal Register* notice that concerns th manufacture of air-braked trailers, and which explains that a trailer may be certified as conforming as a completed vehicle when it is substantially completed. You should be able to determine if the trailer in question was substantially completed prior to January 1, 1975, for purposes of certification.; Sincerely, Frank Berndt, Acting Chief Counsel