Interpretation ID: nht78-3.34

DATE: 04/03/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Alloy Trailers Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 10, 1978, question whether a trailer is considered newly manufactured under section 571.7(f) of NHTSA regulations if new materials are used except for four running gear assemblies that come from the front and rear of two wrecked trailers and are welded together to form the front and rear tandems of the reassembled full trailer.

It is our understanding that the axles, wheels, braking and suspension components would be taken from the existing trailers, the identity of one of the existig trailers would be continued in the reassembled trailer, and the two existing trailers would be owned or leased by the user of the reassembled trailer. Assuming that this understanding of the facts is correct, the NHTSA would consider the reassembled trailer to be not newly manufactured under 49 CFR 571.7(f) for purposes of the Act, implementing regulations, and the safety standards.