Interpretation ID: nht81-1.4

DATE: 01/22/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Davis Trailer Mfg. Co.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 7, 1980, letter to Mr. Kratzke of my staff, in which you requested information concerning the legality of using welded mobile home axles and mobile home tires on trailers.

We have no regulations concerning the axles which may be used on trailers. However, the use of mobile home tires on new trailers would violate Federal Motor Vehicle Safety Standard No. 120 (49 CFR @ 571.120). For your information, I have enclosed a copy of this standard. Section S5.1 of the standard requires all new trailers equipped with tires for highway service to use tires that comply with either Standard No. 119, New Pneumatic Tires for Use on Motor Vehicle Other Than Passenger Cars, or Standard No. 109, New Pneumatic Tires -- Passenger Cars. Tires which have the label "For Mobile Home Use Only" have been expressly exempted from the performance requirements of Standard No. 119. Because of the exemption, these tires may only be used on mobile homes. Therefore, the use of these tires on new trailers would render the trailers in violation of Standard No. 120. A manufacturer using these tires on a new trailer would face a fine of up to $ 1,000 for each mobile home tire used, pursuant to the provisions of sections 108 and 109 of the National Traffic and Motor Vehicle Safety Act as amended (15 U.S.C. 1397 and 1398). If you are aware of any such violations, the agency would appreciate any information you could supply.

As I have stated above, we have no regulations specifying performance requirements for the axles on trailers. If you have any further questions or need any further information on this subject, please contact Mr. Kratzke at (202) 426-2992.

Sincerely,

Enclosure

ATTACH.

DAVIS TRAILER MFG CO

NOVEMBER 7, 1980

(Illegible Words)

Dear Sir:

In regards as to our conversation on 11.5.80 I am asking for information on using Mobile Home (Illegible Word) cut into, welded back together an (Illegible Word) to the Public. As you might know on some axles & all mobile home tires are stamped these words. For Mobile Home use only.

If you will mail me some paper work on this matter I will surely appreciate it any information on trailers as to the law of the land. I want to know about it. My competers around me are about to put me out of business using this sort of luck

Hoping to hear from you soon.

Yours truly

Charlton C Davis -- OWNER, Davis Trailer Mfg. Co