FWIW- I ran a US GEAR standard ex breake on my 01 for about 60k, towing about 12-13k and on my 03 for 30k towing about 8-10k.
I liked it fine, but I'm a dealer so I thought I'd see what was up with the US GEAR superduty ex brake.
So I installed one on my 03 and it makes a bunch of difference overe the std brake. What's unique about the SD is that rather than bleed off air with an orifice in the blade or a partially closed blade, they have a "bypass tunnel" in the casting with it's own smaller blade and wastegate. What this means is you build max pressure without buzzing the motor/downshifting etc and it makes use of the brake much more easy, works faster, over a broader rpm range and with less noise.
Check it out, very much exceeded my expectations.
I'm not going to say it would work acceptably for 40 k gross, but I'm betting it would be a lot more useful based on it's design and my experience with it.