Interpretation ID: aiam1648
Sales Manager
Columbia Body & Equipment Co.
123 N. E. Oregon Street
Portland
OR 97232;
Dear Mr. Hansen: This responds to CBE's October 24, 1974, question whether a traile equipped with a telescoping drawbar that varies the distance between axles to conform to various State regulations would qualify as a 'Heavy hauler trailer' as that term is defined in Standard No. 121, *Air brake systems*:; >>>'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 answer to your question is no. The extension of the drawbar is no an 'extension of the vehicle frame.' This characteristic is intended only to describe trailers whose function necessitates a highly specialized configuration that significantly interferes with brake design. In contrast the telescoping drawbar is not related to the trailer's function, but simply permits the vehicle to conform to State highway regulations.; Yours truly, Richard B. Dyson, Acting Chief Counsel