Interpretation ID: aiam2483
5272 River Road
Suite 400
Washington
D.C. 20016;
Dear Mr. Humphreys: This responds to your November 24, 1976, letter in which you as whether a draft certification label and owner's manual (submitted along with your letter) that are designed to accompany a camper would comply with Standard No. 126, *Truck-Camper Loading*.; The camper you describe uses a third axle which can support varyin amounts of the 'total cargo weight' of the caper, as this term is used in the standard. Although this camper falls within the definition of a slide-in camper, the NHTSA concludes that the requirements of Standard No. 126 are not appropriate and were not intended for this type of camper. Campers employing third axles as part of their support pose loading problems which Standard No. 126 does not adequately address. The required statements and figures in S5.1.2(c) and (e) of the standard address the concept of 'center of gravity' not 'effective center of gravity' to which you refer in your letter.; Although we have interpreted the requirements of Standard No. 126 to b inappropriate and inapplicable to the camper you describe, we recognize a need to provide the purchaser with sufficient information to ensure that the load capabilities of trucks will not be exceeded and that the 'effective center of gravity' of the camper will correspond to the center of gravity of the truck. The information detailed in your letter should aid the purchaser in the safe installation of the camper. Without this information improper installation could more easily occur, which would affect the overall safety of the vehicle.; At this time, we are not able to make ny comments regarding potentia handling problems that may arise because of the additional axle. The NHTSA will, therefore, continue to study the use of campers with third axles. If the agency identifies problems in this configuration or discovers accidents resulting from improper installation of the camper, we would consider amending Standard No. 126 to include appropriate requirements for campers with third axles.; Sincerely, Frank A. Berndt, Acting Chief Counsel