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Interpretation ID: nht88-2.73

TYPE: INTERPRETATION-NHTSA

DATE: 07/14/88

FROM: DERRAL T. CRANCE -- AUTOMOTIVE ENGINEER, SALT RIVER PROJECT

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 04/03/89, FROM ERIKA Z. JONES -- NHTSA TO DERRAL T. CRANCE, REDBOOK A33 (2), STANDARD 121

TEXT: Dear Ms. Jones:

Recently Salt River Project ordered sixteen material/reel trailers and two transformer oil trailers. The trailers were built in 1987 by an out of state manufacturer and delivered to Salt River Project via a local vendor representing the manufacturer. A description of the two types of trailers is as follows:

A. Material/Reel Trailer

GVWR - 20,000 lbs.

Drawbar - Lunette eye

Length - 211 inches overall

Width - 92 inches

Height - 90 inches

Deck - 30 inches from ground

Axles - Tandem 10,000 GAWR each

Brakes - S-Cam air actuated

Parking Brakes - Spring applied air released

B. Transformer Oil Trailers

GVWR - 22,000 lbs.

Drawbar - Lunette eye

Length - 244 inches

Width - 90 1/2 inches

Height - 102 inches

Bottom of Tank - 24 inches from ground Axles - Tandem 12,000 GAWR each

Brakes - S-cam air actuated

Parking Brakes - Spring applied air released

I have attached a copy of a vehicle data record for a tank trailer and a photo of a material/reel trailer for clarification of the two types of trailers. Salt River Project's interpretation is that the trailers need to conform to Motor Vehicle Safety St andard No. 121 Air Brake System (as amended through Docket 79-03; Notice 4 - issued June 9, 1980). Our concerns specifically are in the reservoirs and the required protection system as set forth in FMVSS 121.

Please issue an interpretation to clarify the following items:

1) Are the trailers as outlined above required to conform to MVSS 121 (as amended through Docket 79-03; Notice 4 - issued June 9, 1980)?

2) If conformance to 121 is required, then is a protected reservoir for parking brake release required?

3) If conformance to 121 is required, then is it a requirement that the service reservoirs be protected by check valves or equivalent?

Sincerely,

Attachment

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(PHOTOGRAPH OF TRAILER OMITTED)