I have a question’s about brake requirements. A truck tractor pulling a Mobile home 16 feet wide by 80 feet long operating with an oversized permit 6 axles on trailer and an estimated weight 20,000lbs – 50,000lbs. Manufacturer has made the chassis with brakes on some of the axles but not all axles. Example-There are electric brakes on 2 of the 6 axles, some mobile homes only have 1 axle with electric brakes. The trailer chassis is part of the house. The mobile homes are transported from the manufacturer to the mobile home community or purchaser.

Does this operation fall under Driveaway-Towaway Operation?

Driveaway-towaway operation means an operation in which an empty or unladen motor vehicle with one or more sets of wheels on the surface of the roadway is being transported:
(1) Between vehicle manufacturer's facilities;
(2) Between a vehicle manufacturer and a dealership or purchaser;
(3) Between a dealership, or other entity selling or leasing the vehicle, and a purchaser or lessee;
(4) To a motor carrier's terminal or repair facility for the repair of disabling damage (as defined in this section) following a crash; or
(5) To a motor carrier's terminal or repair facility for repairs associated with the failure of a vehicle component or system; or
(6) By means of a saddle-mount or tow-bar

This operation is connected to truck tractor by ball hitch.

Does this require breakaway device?
Does this operation require to have functioning brakes on all axles ?
If only 2 of 6 axles have brakes, are the 2 axles with brakes required to be operational?

Under 393.42( brakes required on all wheels). I saw the exception under 393.42(b)(2). On roadside I am not sure how I would know if the combination would meet the 393.52 brake performance requirements.

I am looking for guidance for enforcement. I have received different answers as to whether it meets the definition of a driveway/towaway. If the manufacturer equips the mobile home with brakes on two axles, Is it then expected that those brakes have to work to meet 393.52?

As soon as possible

Individuals in the committee shared information based on discussions had with the issuer prior to the meeting. The purpose of the issue request was to seek an opinion from the committee on how to handle these mobile home trailers. The committee agreed the brake performance referenced in 393.52 is like a hidden component because the roadside inspector cannot check brake performance roadside without a PBBT. Due to its size, this type of combination cannot be checked on a PBBT.

The vehicle committee agreed the combination meets the definition of a driveaway/tow-away, and thus exempted from the braking requirements, which includes the breakaway requirement. Therefore, functional brakes are not required on the trailer. If it is equipped with 2 brakes, they are not required to be operational per 393.48. Absent a PBBT, a roadside inspector would not have the ability to verify compliance with 393.52. If the manufacturer equips the vehicle with brakes, they are not required to be operational due to the exemption in 393.42 & 393.48.