Interpretation ID: aiam2230
Director of Trailer Design
Lufkin Industries
Inc.
P.O. Box 848
Lufkin
TX 75901;
Dear Mr. Colburn: This responds to your February 6, 1976, questions whether Lufki Industries may, as an incomplete vehicle manufacturer, build 'incomplete chassis trailers' that do not have brakes installed that comply with Standard No. 121, *Air Brake Systems*, and whether Lufkin may tow the 'incomplete chassis trailers' over the highway to the final-stage manufacturer without brakes that conform to Standard No. 121.; Lufkin's activities are regulated by Part 568 of Title 49 of the Cod of Federal Regulations, if the 'incomplete chassis trailers' qualify as 'incomplete vehicles.' A copy is enclosed for your information. Part 568 does not require the incomplete vehicle to meet all applicable safety standards, but S 568.4 does require a statement of the status of an incomplete vehicle's conformity with all applicable standards.; In answer to your second question, the NHTSA permits the use of a incomplete vehicle on the public highways for the purpose of transit between the incomplete vehicle manufacturer and subsequent manufacturers, but for no other purpose, until such time as the vehicle complies with all Federal motor vehicle safety standards applicable to it as completed. This ruling by the NHTSA does not relieve the manufacturer or shipper from any applicable requirement imposed on the incomplete vehicle by other Federal, State, or local authority.; Sincerely, Frank Berndt, Acting Chief Counsel