Interpretation ID: nht74-2.12

DATE: 11/14/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Truck Trailer Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your October 23, 1974, question in behalf of Steadman Containers, Ltd., asking if Standard No. 121, Air brake systems, applies to the Steadman "liftainer", which is described as a semi-trailer frame capable of carrying 20- and 40-foot cargo containers that are loaded by means of cranes mounted at each end of the semi-trailer. The vehicle is used to move containers in terminal areas and is used on the highway only in relocation to another terminal.

The "liftainer" is a motor vehicle as that term is defined in the National Traffic and Motor Vehicle Safety Act of 1966, because it uses the highway on a necessary and recurring basis to move between work sites. A discussion of the motor vehicle definition is enclosed for your information. As a motor vehicle, it is subject to the requirements of Standard No. 121 for trailers, effective January 1, 1975.

I have also enclosed a discussion of Standard No. 121's applicability to vehicles purchased by Canadians for use between Canadian and United States points. The standard would apply to Steadman trailers if they are purchased for use on U.S. highways.

Yours truly,

ATTACH.

October 23, 1974

James B. Gregory -- National Highway Traffic Safety Administration, Department of Transportation

Dear Dr. Gregory:

Could you please furnish us with an interpretation in connection with the enclosed described equipment and its relationship with the anti-skid devices to be placed on equipment by January 1, 1975?

You will note that Steadman containers indicates that "The Liftainer Container handling unit is not intended, nor used, as a highway unit, but is used in terminals where it is moved by means of a conventional highway tractor. Its highway use is limited only to possible occasional re-positioning from one yard to another. As its width in the closed, unfolded condition, is in excess of 8', road movement always involves use of special permits."

We will appreciate your consideration and response to the above.

Sincerely yours, Charles J. Calvin -- President