Interpretation ID: nht91-1.9

DATE: January 3, 1991

FROM: Jim Holperin -- State Representative, 34th Assembly District

TO: Taylor Vinson -- Legal Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2-26-91 from Paul Jackson Rice to Jim Holperin (A37; Std. 108)

TEXT:

I write today on behalf of LeRoy E. Mueller, President of the Wisconsin Trailer Company, Inc. in Phelps, Wisconsin. Mr. Mueller's company recently submitted a bid to the Wisconsin Department of Natural Resources for two tilt-deck trailers based on the enclosed specifications.

As Mr. Mueller is concerned that if he builds the trailers exactly to specifications that they will be in violation of Title 49, Section 571-108 and, by cross reference, in violation of relevant SAE requirements.

Kevin Cavey recommended I direct this correspondence to you and request a determination from the NHTSA regarding whether our DNR's trailer specifications comply with Title 49 and relevant SAE codes. I am also enclosing a letter from Mr. Mueller indicating his primary concern lies with what appears from the specifications to be a permanent, stationary ramp which Mr. Mueller believes might obscure a clear view of the trailer's tail lights from a 45 degree angle as required by Title 49 and SAE codes.

I would appreciate it if you could take time to review the enclosed material and determine whether Mr. Mueller's concerns regarding an obstructed view of the tail light are legitimate or not. Thank you for giving this request your consideration and, of course, if there is additional information you need please do not hesitate to contact me by letter or phone.

Attached to a map of the 34th Assembly District (Text omitted)

Attachment Specification 8 SPECIFICATION

TYPE: (2) Two 26,000 lb. minimum payload capacity "over the wheel" tilting platform trailer.

DELIVERY: The successful bidder shall deliver all units ordered, after final inspection and approval by DNR personnel, to DNR, Neil H. LeMay Forestry Center, 518 West Somo Ave., Tomahawk, WI 54487, and to arrive during regular working hours - Monday thru Friday, 7:45 a.m. to 11:45 a.m. and 12:30 p.m. to 4:30 p.m. Advance notice of at least one day shall be given. The successful bidder shall arrange for and pay transportation costs for the delivery of all units ordered.

USE: Trailer will be used to transport medium sized crawler tractors with fire plows, heavy duty wheel tractors, and farm-type machinery, both on and off the road, maximum highway speed will be 55 MPH.

A. CAPACITY: 26,000 lb. minimum payload capacity. When unloaded, there shall be sufficient tongue weight to enable the unit to be towed without fish-tailing.

OUTLINE DRAWING - T-D169-401 Issue 02

B. PLATFORM: Length - 20 feet Width - 94" minimum - 96" maximum Height - 38" maximum fully loaded

FRAME: Steel shall be designed with ample safety factor and electrically welded where steel meets steel. All crossmembers are to be in line, fully welded on top, sides, and bottom, both on the inside and outside of the main frame.

DECK: Full 2 inch thick treated apitong wood deck. The entire rear 7 feet of the trailer to be ribbed traction bed with 3.75" x 2" x 3" angle steel ribs replacing the wood deck planking. Ribs to be spaced 7" on center with the 3" leg facing the front of the trailer. All wheel well openings shall be covered. Area around wheel wells shall be reinforced to support deck.

ANGLE IRON LOADING GUIDES: Locate three removable angle iron guides on top of deck per outline drawing.

Stake pockets, footholds, expanded metal walkway, tie-down slots per outline drawing.

LOADING RAMPS: 0.50" thick steel formed loading ramps per outline drawing.

PLATFORM LOCK: Shall be heavy duty screw type, self adjusting for wear, and shall hold the platform tight and rattle free in the closed position, The end of the screw shall be wedge shaped for ease of engagement.

OPERATION: Deck to tilt open or closed with 150 lb. weight, allowing loading or unloading of equipment. Loading angle shall not exceed 15 degree incline. Zerk type grease fittings shall be on all platform tilt pivot points.

SPECIFICATION

CUSHIONING DEVICE: One (1) 4" hydraulic cylinder with 1.25" diameter rod, or two (2) 2.5" hydraulic cylinders with 1" diameter rod (all minimum dimensions) designed to cushion the opening and closing the platform. When cylinders are completely open, the bed of trailer shall be capable of tilting 4" minimum below ground level in the tiltbed position.

C. SUSPENSION: Single point spring suspension - Neway USR 444, or equal - able to maintain equal ground pressure while traveling over uneven terrain.

AXLE LOCATION: Distance from center of axles to front of trailer bed to be approximately 10 feet.

TIRES: Nine (9) 7.5 x 15 L.R. "F" (12PR) low platform trailer tube type tires and rims capable of meeting load and speed requirements of this specification as noted in item A. One (1) tire to be mounted on spare rim. Valve extensions required on inside tires.

WHEEL: Budd disc wheels. Stemco oil wheel seals shall be furnished on all axles.

AXLES: Full width through type axles with one (1) hubometer.

D. BRAKES: Full air complete with all lines, breakaway control valve, and air reservoir tank with 1,000 cubic inch minimum capacity. Air brake hoses to extend a minimum of 24" ahead of the pintle eye and shall be complete with couplings. Air lines shall not be interchangeable. Left gladhand shall be the emergency air line Velvac #55B-13. Right hand gladhand shall be the service air line Velvac #55B-14. Brake system shall meet SAE and DOT requirements. All wheel brakes to be 12.25" x 7.5" minimum. Gladhand holders are required for brake lines when they are not in use, and are to be mounted near tongue. Include piggy back parking with mechanical release and mechanical release tool.

E. ELECTRICAL SYSTEM: Shall be per writing diagram T-AO86-701 furnished as a part of this specification.

WIRING: Shall meet all SAE, ICC, and DOT requirements. All wires shall be in loom, heavy jacket, or conduit and mounted in a protected position. Where wires pass through steel, they shall be protected with rubber grommets. Two (2) feet of conductor wire, ahead of pintle, shall be installed in the female plug for connection to the towing vehicle. No aluminum rivets for grounds are allowed.

LIGHTS: Lights shall meet SAE, ICC, and DOT requirements. Lights shall be in protected recesses or with protective base around lights. All lights shall be of the plug-in type.

SIX POLE PLUG: Vel Vac #59P-6 (6 way male plug) with replaceable interior, or equal.

Attached to drawings and photos of Lid Trailer (Text and graphics omitted)