Interpretation ID: nht93-9.15

DATE: December 15, 1993

FROM: Ted H. Richardson -- Fleet Coordinator, Priefert Manufacturing Company, Inc.

TO: Office of Chief Counsel, NHTSA (National Highway Traffic Safety Division)

TITLE: None

ATTACHMT: Attached to letter dated 4/12/94 from John Womack to Ted H. Richardson (A42; Std. 120; VSA 102(3))

TEXT:

Please forward opinion on "FMVSS No. 120" concerning new trailers with used tires. Per a conversation that I had with Mr. Walter Myers on 12/13/93, he felt that with the description of our product (over the phone) it would not apply. I am enclosing a product catalog that contains pictures and descriptions of the two pieces of equipment in question. I also request a copy of your definition of a trailer and a copy of FMVSS #120.

Thank you and please handle as expeditiously as possible.