OOSC, Part II, Item 1. Brakes, d. Trailer Breakaway and Emergency Brakes (2)

What constitutes an appropriate attachment for the breakaway brake system on electric brake or surge brake systems. There are two situations that have come up recently regarding the attachment of a breakaway cable to the towing unit. First, a breakaway cable was attached to the pintle hook that was bolted on to the towing unit, Since the pintle hook was bolted to the towing vehicle, does this mean that the pintle hook is permanently attached to the pulling unit and therefore, can the breakaway device be attached to a portion of the pintle hook rather than the actually power unit? Secondly, there was the breakaway cable attached to the towing unit by using a bread tie (not strong enough to activate the breakaway in all likelihood).

Add language to the OOS Criteria to provide clarity as to whether the breakaway can be attached to hitches that are permanently attached to the power unit. Also, if possible, guidance on what would be acceptable to attach a cable to the permanently mounted item on the towing unit. Would it be something of equal strength as the cable?

Add the following wording to the OOSC under Part 2(d)(2): (2) A breakaway system not directly attached to a towing vehicle or a permanently mounted item on the towing vehicle (e.g., bolted on hitching system). (393.43(d)) Also, guidance on the strength of the attachment of the breakaway cable to towing unit, if possible.