CVIAQ has been providing input on behalf of CVIAA to the Federal Administrator of Vehicle Standards on draft Circular 0-3-6 “Certification Procedures for Trailers” November 2008.
Following circulation of the draft a number of members expressed serious concerns. Had the draft been adopted it would have resulted in new categories for Over Dimension and Over Mass units causing confusion in the marketplace. The Circular also treated all trailers that were capable of operating over dimension or over mass as non standard even though they were not OD or OM in their normal configuration (extendable trailers and widening trailers). Other issues were Quality Assurance, record keeping requirements and individual approval for non standard trailers.
The latest draft (available here) of the circular meets the requirements set out in the CVIAA response and will be circulated to Members for their comment. |