Interpretation ID: aiam1862

Mr L. Steenbock, Engineering Department, FWD Corporation, Clintonville, WI 54929; Mr L. Steenbock
Engineering Department
FWD Corporation
Clintonville
WI 54929;

Dear Mr. Steenbock: This responds to your March 11, 1975, question whether the exceptio category of 'no cargo-or passenger-carrying capacity' found in S3 of Standard No. 121, *Air brake systems*, includes a vehicle designed to carry a driver and a second person to operate the vehicle's specialized equipment.; The answer to your question is yes. We use the word 'passenger' in thi context to mean a person who does not help to operate the vehicle or its equipment, *i.e.*, who is not part of an operating crew. Positions for the crew necessary to operate a vehicle's specialized equipment would not disqualify a vehicle under the passenger-carrying criterion.; Yours truly, Richard B. Dyson, Assistant Chief Counsel