Interpretation ID: aiam1718
Marketing Manager
Barns (sic) Lumber and Manufacturing Co.
2813 Lombardy Lane
P.O. Box 20160
Dallas
TX 75220;
Dear Mr. Gill: This responds to your November 21, 1974, request for a determinatio that the Barnes Models RTY, RT-XF, RTDF, RTCF, RTA, and GWPHD trailers all qualify as 'Heavy hauler trailers' and, as such, are not required to meet the requirements of Standard No. 121, *Air brake systems, until September 1, 1976.; 'Heavy hauler trailer' is defined in the standard as follows: >>>'Heavy hauler trailer' means a trailer with one or more of th following characteristics:; (1) Its brake lines are designed to adapt to separation or extension o the vehicle frame, or; (2) Its body consists only of a platform whose primary cargo-carryin surface is not more than 40 inches above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent 'front-end structure' as that term is used in S 393.106 of this title.<<<; The TRY, (sic) RT-XF, RTDF, RTCF, and RTA models appear to have brak lines that are designed to adapt to extension of the vehicle frame.; We would consider the cargo-carrying surface to the GWPHD to be th horizontal portion of the frame rails, and that it therefore would have a bed-height of less than 40 inches.; I would like to emphasize that your vehicles appear to qualify for thi exemption, but that it exists only until September 1, 1976. Each vehicle manufactured after that date must conform to the requirements of the standard.; Yours truly, Richard B. Dyson, Acting Chief Counsel