Interpretation ID: nht75-6.28

DATE: 07/18/75

FROM: WALTER C. BURVILLE -- MANAGER UNDERWRITING SURVEY DEPARTMENT CHUBB/PACIFIC INDEMNITY GROUP

TO: ASSOCIATE ADMINISTRATOR FOR MOTOR VEHICLE PROGRAMS NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: COMPLIANCE WITH FEDERAL MOTOR VEHICLE SAFETY STANDARD 121.

ATTACHMT: ATTACHED TO LETTER DATED 8/18/75 FROM FRANK BERNDT OF NHTSA TO WALTER C. BURVILLE -- MANAGER, UNDERWRITING SURVEY DEPARTMENT CHUBB PACIFIC INDEMNITY GROUP; N40-30

TEXT: Gentlemen:

In the hustle of various interpretations following the inactment of 121, I am getting contradicting information. We are insurers of several trailer manufactures in this area. Most of them maintain that actual road tests of complete units is not necessary to conform with Section 55.3.2 "Stopping Capability-Trailers."

In discussing this with NHTSA in Seattle in March, they stated that in their opinion, a company would have to take a typical unit of each variety manufactured and test it under the most adverse conditions according to Section 56 "Conditions", and this means an actual road test.

Would you provide an interpretation on this, if available. Will a road test be necessary and will routine tests or only the initial test be sufficient?

Very truly yours,