Interpretation ID: nht71-4.16

DATE: 09/20/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Patton; Blow; Verrill; Brand & Boggs

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 12, 1971, concerning the Certification regulations, as amended April 14, 1971 (36 F.R. 7054). The questions you ask in your letter are dealt with individually below.

1. You request a ruling that, in the case of boat trailers, would allow the "type classification" of the vehicle (@ 567.4(g)(7)) to be stated as "trailer". The use of the word "trailer" in the case of boat trailers will satisfy the requirement.

2. You ask that NHTSA initiate rulemaking to exempt boat trailers from the requirement of specifying the GAWR (@ 567.4(g)(4)). You state as the basis for this request that the gross axle weight rating of a boat trailer is meaningless as it can vary depending upon the load distribution. We must deny your request. The purpose of requiring both GAWR and GVWR is to distinguish between the weight of a fully loaded vehicle and the weight on each particular axle of the vehicle. This distinction is important in the case of a single axle trailer, as the GVWR and GAWR may differ due to the distribution of the GVWR between the axle of the trailer and some component of the towing vehicle. By specifying values for both GVWR and GAWR that he deems appropriate, the manufacturer, rather than providing a meaningless figure, will be providing figures that represent an appropriate distribution of a load between the trailer and the towing vehicle.

3. You also ask whether, in cases where a tire size option exists, a GVWR can be stated on the label for each tire size. The question is presently under consideration as part of action being taken on petitions for reconsideration of the regulations that have been received. Accordingly, we will deal with this question in our action on the petitions pursuant to 49 CFR 553.37.