Interpretation ID: aiam2717
Utility Trailer Manufacturing Co.
P.O. Box 1299
City of Industry
CA 91749;
Dear Mr. Bennett: This responds to Utility Trailer Manufacturing Company's October 6 1977, request for confirmation that the criteria for a bulk agricultural commodity trailer contained in S5.6 and S5.8 of Standard No. 121, *Air Brake Systems*, can be met by a trailer that does not accommodate 'slip-in bottom dump' bulk harvest tubs as well as the 'deck type' harvest tubs used for tomatoe (sic) harvesting. From your description, it is assumed for the purposes of this interpretation that the trailers in question do conform to the criteria in the standard for maximum length and an air line and reservoir arrangement that minimize field damage.; The criterion of 'skeletal construction that accommodates harves containers' can be met by a design that accommodates mounting of deck type bulk harvest tubs by means of removable flooring, whether or not the removal of flooring also permits the mounting of 'slip-in bottom' bulk harvest tubs.; Sincerely, Joseph J. Levin, Jr., Chief Counsel