Interpretation ID: aiam3384
Davis Trailer Mfg. Co.
Rte 1
Highway 78E
Loganville
Georgia 30249;
Dear Mr. Davis: This responds to your November &, 1980, letter to Mr. Kratzke of m staff, in which you requested information concerning the legality of using welded mobile home axles and mobile home tires on trailers.; We have no regulations concerning the axles which may be used o trailers. However, the use if mobile home tires on new trailers would violate Federal Motor Vehicle Safety Standard No. 120 (49 CFR S571.120). For your information, I have enclosed a copy of this standard. Section S5.1 of the standard requires all new trailers equipped with tires for highway service to use tires that comply with either Standard No. 119, *New Pneumatic Tires for Use on Motor Vehicles Other Than Passenger Cars*, or Standard No. 109, *New Pneumatic Tires--Passenger Cars*, tires which have the label 'For Mobile Home Use Only' have been expressly exempted from the performance requirements of Standard No. 119. Because of the exemption, these tires may only be used on mobile homes. Therefore, the use of these tires on new trailers would render the trailers in violation of Standard No. 120. A manufacturer using these tires on a new trailer would face a fine of up to $1,000 for each mobile home tire used, pursuant to the provision of section 108 and 109 of the national Traffic and Motor Vehicle Safety Act as amended (15 U.S.C. 1397 and 11398). If you are aware of any such violations, the agency would appreciate any information you could supply.; As I Have stated above, we have no regulations specifying performanc requirements for the axles on trailers. If you have any further questions or need any further information on this subject, please contact Mr. Kratzke at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel