Interpretation ID: aiam2534
President
Bertolini Engineering Co.
Inc.
Butler Professional Center
1375 Route 23
Butler
NJ 07405;
Dear Mr. Bertolini: This responds to your March 7, 1977, letter asking whether you proposed remanufacture of 573 trailer chassis would constitute the manufacture of new chassis which would be required to conform to Standard No. 121, *Air Brake Systems,* or any other applicable regulation.; According to the remanufacture proposal you describe, Seatrain Line will be the user of the chassis both before and after the remanufacture, although it will no longer own any of them. Fruehauf Corporation will become the owner of all of the chassis, whereas it currently owns none.; The NHTSA regulations pertaining to the remanufacture of chassis ar found in 49 CFR Part 571.7. In that regulation the agency states that the chassis must be owned or leased by the same entity both before and after remanufacture. Since Seatrain is the current user of the vehicles (as owner and lessee) and will continue to be the user after remanufacture (as a lessee), it appears that the remanufactured vehicle will not be one that requires certification with motor vehicle safety standards.; It should be pointed out that if the transaction you describe fo achieving remanufacture becomes a large-scale practice in the trailer industry, the agency will be compelled to reconsider the meaning of 'manufacture' under its regulations.; Sincerely, Frank Berndt, Acting Chief Counsel