You are all correct in saying trailers require trailer brakes in CA. Here is the CVC definition of a trailer:
A “trailer” is a vehicle designed for carrying persons or property on its own structure and for being drawn by a motor vehicle and so constructed that no part of its weight rests upon any other vehicle. As used in Division 15 (commencing with Section 35000), “trailer” includes a semitrailer when used in conjunction with an auxiliary dolly, if the auxiliary dolly is of a type constructed to replace the function of the drawbar and the front axle or axles of a trailer.
A TOAD does not meet this definition.
As for it being safer, do you have any evidence or experience that proves this? I've never seen an accident caused due to a TOAD not having a braking system.
All of the links you have posted are from independent websites including one selling brakes. None of them cite a law requiring brakes.
While I agree that brakes arent going to make things worse and if anything will make it safer, I am looking for where it is a requirement. Every RV forum and FB page etc has people saying it is required and that no braking system and cheap tow bars are dangerous, yet there is no proof that I've seen of any of this.
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