Mr. John Hrabosky
Earth Tool Company LLC
Post Office Box 3
Oconomowoc, WI 53066

Dear Mr. Hrabosky:

This responds to your letter of April 9, 1996, addressed to Walter Myers of my staff, in which you ask what "D.O.T. safety standards [do you] need to be aware of" in producing a vehicle you refer to as a "winch trailer."

You enclosed pictures of your winch trailer, which can be described as a single-axle enclosed trailer whose dimensions are estimated to be approximately 6 to 8 feet long, 5 feet wide, and 4 feet high. The metal enclosure is equipped with side hatches and a back door that open to provide access to the winch and associated tools and equipment mounted inside. The pictures show the trailer hitched to a pickup truck in preparation for towing. You state that the purpose of the winch trailer is "to aid in utility replacement." You also state that the trailer is equipped with electric brakes, has a gross vehicle weight of approximately 4,000 pounds, and has a tongue weight of approximately 250 pounds.

In response to your question about applicable standards, we are enclosing a fact sheet entitled "Federal Requirements for Manufacturers of Trailers," which lists the standards and regulations applicable to trailers. Copies of the listed standards and regulations may be obtained by following the instructions in the enclosed fact sheet entitled "Where to Obtain NHTSA's Safety Standards and Regulations." A copy of the cover of the volume you will need is attached to this fact sheet. The cost of the volume is approximately $40.00.

In addition, we are enclosing the following pertinent information for motor vehicle manufacturers:

a. Chapter 301 of Title 49, U.S. Code (the statutory provisions under which NHTSA has issued its safety standards and regulations); and

b. Fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."

Should you have any further questions or need additional information, feel free to contact this office at the address shown above or at (202) 366-2992, FAX (202) 366-3820.


Samuel J. Dubbin Chief Counsel


Ref:VSA d:5/9/96