OOSC, Part II, Item 1. Brake Systems, h. Air Brake Hose/Tubing (7) - Disconnected Gladhand

The new addition regarding inoperative brakes on a trailer when the service gladhand is not connected creates the potential of a trailer now being placed OOS when 20% brake criteria is not met and the vehicle or combination would not have been placed OOS prior to this new criteria.

New OOS criteria for when an electric brake trailer has inop brakes due to the electrical cord being unplugged is appropriately placed within the 20% criteria. For the OOS to apply, all brakes on the trailer must be inoperative AND 20% criteria is met. When it comes to air brakes, the addition was not put into the 20% section. It is now possible that the trailer would be placed OOS when it wouldn't have been prior to this new criteria. The most common example would likely be an A-trailer consisting of a 3-axle tractor, 1-axle trailer, 1-axle converter dolly and 1-axle trailer. If the gladhand to the last trailer was not connected, it would be OOS since 1.h.(7) is not in the 20% section nor does the criteria mention that it has to result in at least 20% of brakes being defective.

The criteria for service gladhand not connected should be moved into 1.a. with other 20% criteria, similar to the electrical cord not being connected. as much of a pain as it may be to renumber, it may be best as 1.a.(2) so it is found immediately after the inoperative brake section. The other option would be to keep it where it is but change the wording to "All required air brakes on towed vehicle(s) inoperative due to service gladhand not connected to the trailer(s) and results in at least 20% of the brakes required to be on the vehicle combination being defective."