Interpretation ID: aiam1063

Paul K. Wilson, Staff Engineer, Truck Trailer Manufacturers Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20031; Paul K. Wilson
Staff Engineer
Truck Trailer Manufacturers Association
2430 Pennsylvania Avenue
N.W.
Washington
DC 20031;

Dear Mr. Wilson: This is in reply to your letter of March 19, 1973, asking whether towbar dolly must be included in determining the overall length of semitrailers for compliance with Federal Motor Vehicle Safety Standard No. 108.; The answer is no. Standard No. 108 is a manufacturing standard, an semitrailers are not manufactured with dollies attached. 49 CFR S390.7, to which you refer, is a definition of the Bureau of Motor Carrier Safety which regulates the operation of certain motor vehicles, and since trailers often use converter dollies, it is understandable that that agency would deem a trailer with a dolly a 'full trailer.'; Yours truly, Richard B. Dyson, Assistant Chief Counsel