Interpretation ID: nht95-2.80

TYPE: INTERPRETATION-NHTSA

DATE: May 12, 1995

FROM: Robert C. Maltzahn -- Attorney At Law

TO: John Womack Esq -- Acting Chief Counsel, NHTSA

TITLE: Re: Jet Edge Mobile Equipment

ATTACHMT: ATTACHED TO 6/27/95 LETTER FROM JOHN WOMACK TO ROBERT CHARLES MALTZAHN (A43; VSA 102(3))

TEXT: Dear Mr. Womack:

I am corporate counsel for Jet Edge, a company that manufactures ultra-high pressure waterjet cutting and cleaning equipment in Minneapolis, Minnesota. Jet Edge sells the equipment throughout the United States and internationally and some of the equi pment is manufactured as a mobile trailer. I have included a piece of literature from Jet Edge which shows one of the older pumps, but the newer pumps, which are now designated as 36-250D's, are very similar and weigh approximately the same amount.

The equipment is manufactured for use in the construction industry for hydrodemolition and cleaning and for industrial use or for the rental markets where the end user does not wish to purchase the equipment. The equipment is mobile so as to be towed from job to job or from industrial site to industrial site but is not used primarily on the roadways and highways of the United States.

My question is: does the mobile equipment meet the definition of a trailer set forth in 49 CFR sec. 571.3 so as to come under the Federal Motor Vehicle Safety Standards and Regulations and thus require a vehicle identification number (VIN) which would require us to meet the specifications and regulations and the content requirements for the VIN. We would prefer, obviously, because of the nature of the equipment, not to have to establish a VIN and the content requirement thereof.

Therefore, I would request from you a short letter statement as to your opinion as whether the equipment, as described, does or does not require a VIN so that I might in turn give my opinion to those infrequent individuals that so request from us. I might point out that there are less than 50 of these units manufactured per year and the total number in existence at the time of this letter is, to the best of my knowledge, less than 250 worldwide.

If you have any questions with reference to the above, please contact my office.

Enclosure - Brochure omitted.