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Interpretation ID: nht94-4.33

TYPE: INTERPRETATION-NHTSA

DATE: September 20, 1994

FROM: Ed Irvine -- Midwest Conservation Systems, Inc.

TO: Phillip Recht -- Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: Attached to 1/11/95 letter from Philip R. Recht to Ed Irvine (A43; Std. 121)

TEXT: IS IT A REQUIREMENT OF COMMERCIAL UTILITY TRAILERS, THAT FOR EXAMPLE MAY HAVE A BACKHOE TRACTOR, LEAVE THE NEW TRAILER MANUFACTURER WITH A EMERGENCY BREAKAWAY SYSTEM? (SECTION [ILLEGIBLE WORD]) WE HAVE A CORPORATE CUSTOMER WHO IS PURCHASING NEW TRAILERS FROM A MANUFACTURER THAT CLAIMS THEY MUST BE EQUIPPED WITH THEIR BREAKAWAY SYSTEM WHICH IS BASICALLY ONLY A BATTERY IN A BOX. MOST GENERALLY THIS TYPE OF SYSTEM IS NOT CHECKED BY THE OPERATOR AND MOST GENERALLY DEAD WHEN [ILLEGIBLE WORD]. THE CORPORAT E CUSTOMER WOULD LIKE TO BUY THE TRAILERS WITH OUT THEIR BREAKAWAY SYSTEM SO THEY CAN OUTFIT THE TRAILERS WITH OUR SOLAR ENERGIZED BREAKAWAY SYSTEMS. THANKS! ED

Enclosure (Brochure omitted.)