Interpretation ID: aiam2367
Executive Director
Truck Equipment & Body Distributors Association
602 Main Street
Cincinnati
OH 45202;
Dear Mr. Pieratt: This responds to your July 28, 1976, request for confirmation that boat-carrying trailer which has a primary cargo-carrying surface less than 40 inches from the ground qualifies as a 'Heavy hauler trailer', and that such trailers are not required to meet the requirements of Standard No. 121, *Air Brake Systems*, until September 1, 1977.; '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 boat-carrying trailer which you describe as having a bed height o 18 3/4 inches would qualify for exemption until September 1, 1977.; Yours truly, Frank Berndt, Acting Chief Counsel