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Interpretation ID: aiam2778

Mr. Greg Kreshel, Alloy Trailers, Inc., P.O. Box 19208, Spokane, WA 99219; Mr. Greg Kreshel
Alloy Trailers
Inc.
P.O. Box 19208
Spokane
WA 99219;

Dear Mr. Kreshel: This responds to your February 10, 1978, question whether a trailer i considered newly manufactured under section 571.7(f) of NHTSA regulations if new materials are used except for four running gear assemblies that come from the front and rear of two wrecked trailers and are welded together to form the front and rear tandems of the reassembled full trailer.; It is our understanding that the axles, wheels, braking and suspensio components would be taken from the existing trailers, the identity of one of the existing trailers would be continued in the reassembled trailer, and the two existing trailers would be owned or leased by the user of the reassembled trailer. Assuming that this understanding of the facts is correct, the NHTSA would consider the reassembled trailer to be not newly manufactured under 49 CFR 571.7(f) for purposes of the Act, implementing regulations, and the safety standards.; Sincerely, Joseph J. Levin, Jr., Chief Counsel