Interpretation ID: aiam0281
Plant Manager
Honiron
P.O. Box 3140
Honolulu
HI 96802;
Dear Mr. Lowry: This is in reply to your letter of June 17, 1971, concerning the notic published April 14, 1971 (36 F.R. 7054) amending the Certification regulations (49 CFR Part 567) and establishing regulations governing 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568). You ask whether as a trailer manufacturer you need comply only with the requirements of S 567.4(g)(1) at present, and need not comply with S 567.4(g)(2) through 567.4(g)(7) until October 1, 1972. The answer to this question is no. The amendment to the regulations on which your question is based merely added the requirements of S 567.4(g)(1)(iii), 567.4(g)(3), and 567.4(g)(4) to existing requirements that have been in effect since September 1, 1969 (copy enclosed). Thus, the requirements of S 567.4(g)(1)(i) and (ii), and 567.4(g)(2), (g)(5), (g)(6) and (g)(7) (as they appear in the notice of April 14, 1971) have been in effect since September 1, 1969. Of the new provisions, S 567.4(g)(1)(iii) did become effective June 1, 1971. The effective date of the other new provisions has been corrected to January 1, 1972, by a notice published April 27, 1971 (36 F.R. 7855), a copy of which is also enclosed.; You are correct in interpreting 'gross vehicle weight rating' as i applies to trailers, to exclude the weight of the tractor or other towing vehicle. It includes, as you state, only the weight of the fully loaded trailer. You are also correct in interpreting 'gross axle weight rating' as it applies to trailers to apply to only the weight applied to the axle of the trailer. It does not include the weight applied to any part of the towing vehicle.; If you have further questions, please let us know. Sincerely, Lawrence R. Schneider, Acting Chief Counsel