Trailer Brake Requirements

[brian_bp]

A discussion of the requirement for brakes on the trailer started in another topic (Towing prep package - photo request, in the 1998 - 2003 1st Generation Toyota Sienna section), and I think it deserves its own topic here in Towing & Hauling, since it is not specific to any generation.

Here's what add-on equipment is needed for towing a 3000 lbs trailer with a 1999 Toyota Sienna van...

...

A "trailer brake controller" may be needed if the trailer has a pre-installed brake system separate from the Sienna braking system...

Yes, but if the trailer is heavy enough that it qualifies as "heavy duty towing", then the trailer must have its own brakes... so there should be no "if" in this statement. A 3000 lb trailer is certainly "heavy duty" in the Sienna's scale of things, and absolutely needs its own brakes.

My "trailer brake controller" suggestion above is directed to Sienna owners hauling a medium-large camper trailer that is more likely to have the pre-installed brakes. I occasionally use my Sienna with my car trailer to haul a vintage show/race car to meets and races with its combined total weight of approximately 3000 lbs. The car trailer is a basic model and never had a pre-installed brake system, so this is why I do not have the "trailer brake controller" installed.

Only occasionally being unsafe still does not seem acceptable to me. At 3000 lbs and without brakes, this trailer would be illegal in a number of jurisdictions (including here in Alberta) based only on its own weight, it would be illegal in some jurisdictions (including British Columbia) based the ratio of its weight to the tow vehicle, and it is three times the weight allowed by Toyota.

Most trailer manufacturers (travel, cargo, car transporter, boat, etc) equip trailers with brakes as standard equipment if the GVWR is 3000 lb or greater, because most jurisdictions require brakes at that level; in this case the trailer is either overloaded (has a GVWR under the gross weight of 3000 lb) or unusually poorly equipped (lacking brakes despite a GVWR of at least 3000 lb).

Adding brakes to the trailer is easy in many cases, and possible in essentially all cases.

I appreciate the concern expressed by brian_bp, but I drive in a safe manner and run a safe vehicle setup that is fully inspected, approved, and licensed by the Ohio State Patrol police in the state where I live.

Whether a law enforcement officer finds it safe is not of interest to me; I don't consult law enforcement officers regarding vehicle design, or engineers regarding law enforcement. In the provinces that I have seen (and I would guess in states as well), the police are not even the best authorities on the legality of road vehicles; serious equipment enforcement is handled by a specialist commercial vehicle enforcement agency.

So a police officer has examined the combination of the Sienna with a 3000 lb unbraked trailer and found it legal? That surprises me. Frankly, I was expecting to find a 3000 lb unbraked trailer to be borderline legal in Ohio, but it seems worse than that...

This is part of the Ohio Revised Code, TITLE [45] XLV MOTOR VEHICLES -- AERONAUTICS -- WATERCRAFT, CHAPTER 4513: TRAFFIC LAWS -- EQUIPMENT; LOADS

(4) When operated upon the highways of this state, the following vehicles shall be equipped with brakes adequate to control the movement of and to stop and to hold the vehicle, designed to be applied by the driver of the towing motor vehicle from its cab, and also designed and connected so that, in case of a breakaway of the towed vehicle, the brakes shall be automatically applied:

(a) Except as otherwise provided in this section, every trailer or semitrailer, except a pole trailer, with an empty weight of two thousand pounds or more, manufactured or assembled on or after January 1, 1942;

(b) Every manufactured home or travel trailer with an empty weight of two thousand pounds or more, manufactured or assembled on or after January 1, 2001.

If the 3000 lb car transporting trailer was manufactured before 1942, it is legally "grandfathered", but its age does not make it safer. Either the rig in question is not legal in Ohio, or it is antique and unsafe by current standards but allowed by law... or the posted copy of this Ohio regulation is in error, or I have read it incorrectly.



More importantly, legal compliance is not the same as safe and prudent operation. The regulation above does not distinguish between tow vehicles, so a tiny Smart ForTwo could legally tow a trailer heavier than itself (or even a 10,000 lb 1941 trailer) without trailer brakes: is that safe?

Your interpretation of towing safety in Canada may differ from legal rules and regulations enforced here within the United States.

This has nothing to do with federal laws in any country; vehicle equipment regulations are set on the state and provincial level. The fact that different states and provinces do have different requirements proves that those requirements are legal minimums and not sufficient to ensure safety, since pulling a trailer across a politcal boundary does not make it safer or more dangerous.

[Questor]

You forgot to include the rest of my concerns about the use of ABS brakes with non-ABS brakes on trailers. In the future, please include all emails for the full context of the discussion.

If I recall correctly, there have been past problems with synchronizing the Sienna brakes with some trailers that have non-ABS braking systems. I have heard that some add-on trailer braking systems seem to cause more braking problems than they should by locking up the trailer brakes since the Sienna and trailer do not share the same brake cylinder. I wonder how the Sienna's ABS brakes work with non-ABS brakes on trailers with the trailer brake controller. Is uneven trailer braking a mechanic installation error, an ABS/non-ABS brake incompatibility, or a OEM design flaw? I don't know...

I believe the general intent of a Sienna driver should be to safely slow the trailer being pulled, but locking the brakes on the trailer or Sienna could cause the trailer to sway and become unstable. This is why I installed the Air Lite Suspension Air Kit - to enable better handling and stability when driving the Sienna and trailer. Yes, it will likely take a longer distance to slow the Sienna and trailer, but I feel our setup is safe for my needs.

[brian_bp]

You forgot to include the rest of my concerns about the use of ABS brakes with non-ABS brakes on trailers. In the future, please include all emails for the full context of the discussion.

I didn't forget; I intentionally left out material which is not relevant to trailer brake requirements, which is the current topic. I think the lockup/control and ABS concerns deserve their own topic, which is what I suggested in the topic where they were first raised.

Please see Locking trailer brakes causing control issues? in Towing & Hauling.

[brian_bp]

Okay, the brake-locking issue is launched in its own thread... but what about this requirements discussion? Doesn't anybody have an opinion (or a correction of what I have posted, if I misunderstood something) about the legal or technical requirements for trailer brakes?

Previous discussions:
Re: towing decisions
Do I really need brakes on the trailer?
Sienna Towing Experience

[tekman741]

Like most I want to be safe, not just for me and my family but for the person traveling on the highway who is totally clueless about the physics on how to stop that weight in motion. A Sienna with a ton and 3/4 trailer plus the vehicle and cargo is probably just over 4 tons. Traveling with out trailer brakes puts everyone in your immediate area in danger. If you kill somebody because you wanted to save a $$$ on trailer brakes, well have a good life time of guilt. Use common sense. I was told a story of a family traveling in Vermont and the tow vehicle brakes stopped working. Vermont tend to be very hilly not like the Rockies but still a challenge. Any ways they sent a letter to the dealer who installed their trailer brakes. The trailer brakes were able to bring both under control, to a safe stop. I'd hate to see that guy's drivers seat..... What if