Interpretation ID: nht75-3.47

DATE: 06/13/75

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

TO: Truck Body and Equipment Association

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your request for a determination whether a mobile water tower trailer equipped with air brakes would be subject to the requirements of Standard No. 121, Air brake systems.

The answer to your question is yes. From the description supplied to you by Klein Products, the trailer does not appear to qualify for exclusion from the standard.

I would like to advise you that the National Highway Traffic Safety Administration recently proposed exclusion of this vehicle type from Standard No. 121, and we invite the submission of comments from the Truck Body and Equipment Association or Klein Products on our proposal.

Yours truly,

April 9, 1975

Stan Haransky -- Truck Body and Equipment Association

Dear Stan:

Enclosed is a brochure with a brief description of our Klein Porto Tower which I discussed with you by telephone today.

I would appreciate your help in obtaining a clarification of the Federal Safety Standard #121 in regard to the application of the anti-skid system on this unit or whether this type of equipment is exempt.

This tank is set up on a construction site and uses the highway system only for a movement from job site to job site. It is not capable of carrying a load when being transported.

Thank you very much for your help in this matter.

Very truly yours,

KLEIN PRODUCTS, INC. -- Ray Foote, Sales Manager

Enc.

SPECIFICATIONS

(Graphics omitted) Model Gallon Capacity Approx. Empty Weight Approx. Length KPT-80 8,000 10,000 lbs. 25 ft. KPT-120 12,000 18,000 lbs. 29 ft. KPT-160 16,000 21,000 lbs. 40 ft.

TIRES - 12 ply

SIZE 8.25 x 15

4 1/2 HP air-cooled engine to drive hydraulic system

All prices include a rust-resistant plastic coating on the interior of tank and the exterior painted one color of the customer's choice.

All prices and specifications subject to change without notice

KLEIN PORTO-TOWER -- COMPLETELY MOBILE

* Can be towed anywhere in down position as a conventional trailer. KPT-80 with tow hitch-eye KPT-120 and KPT-160 demi with king pin

* Legal dimensions and weight for highway transportation without a permit (in MOST States).

* Hydraulically erected and lowered by self-contained gasoline engine driven pump.

* One man can elevate and insert pins in 5 to 8 minutes -- completely stable in up position with 13' ground clearance from down-spout.

12 1/4 x 5 1/2 air brakes.

QUICK LOADING AND DISCHARGE

* 4" inlet float controlled valve (Model K-7140) is standard equipment on KPT-120 and KPT-160 3" control valve on KPT-80. 6" -- 12" inlet valves are available on request.

* 14" down spout and control valve for quick discharge -- up to 7500 gallons per minute. Standard equipment on KPT-120 and KPT-160: 10" down spout -- up to 3000 GPM on KPT-80 -- optional up to 20".

* 24" man hole with safety grate.

Specifications subject to change without notice

Economical On or Off-the-road Water Supply

KLEIN PRODUCTS, INC.

SOLD AND SERVICED BY:

Klein Porto - Towers

8,000 to 16,000 Gallon Capacity

A KLEIN EXCLUSIVE!

-- developed and engineered by Klein to fill an acute need for the construction industry.

-- patented by Klein (Patent No. 3,160,171).

Model KPT-120

The Porto-Tower is another example of the advanced developments in low cost water transportation and supply by Klein Products, Inc. This mobile water tower can be moved, elevated and lowered by one man -- no crane required. It is erected and lowered by a self-contained engine driven hydraulic pump. This unique equipment has a fast discharge, with rates up to 7,500 gallons per minute. The tank loads quickly with automatic float control assembly. No permit is required for transporting on the highway.

(See complete specifications on the back)