Interpretation ID: aiam1732
President
Gindy Mfg. Corporation
Downingtown
PA 19335;
Dear Mr. Hindin: This responds to your November 25, 1974, request for our approval o Gindy's plans to establish the date of completion of manufacture of highway trailers for purposes of compliance with Standard No. 121, *Air brake systems*, which became effective January 1, 1975.; Unfortunately there is no simple formula for a determination in advanc that a trailer is complete. For example, your determination that a vehicle is roadworthy does not establish that it is complete.; We set out what we believe are straightforward criteria in a recen letter to a person concerned with essentially the same problem as you. A copy is enclosed. It can be seen that painting, and the installation of decals, tires, or rims can be accomplished after the date of manufacture. As for special lining arrangements, or the mounting of refrigerator units, this requires a determination by you of whether the trailer is substantially complete without these fixtures.; We do appreciate your efforts to meet the requirements of the standar in good faith, as evidenced by your timely request for guidance and submission of plans. Thank you for your interest in motor vehicle safety.; Yours truly, Richard B. Dyson, Acting Chief Counsel