I was about to say there are a good few tools smaller than that on my system, but I was one hundred percent wrong.
# zsh glob for regular files that are smaller
print -l /usr/bin/*(.L-39731) # Some ~500 results
# Not interpreted or using system libraries
file /usr/bin/*(.L-39731) | egrep -v '(script|dynamically)' # 0 results
Turns out there are only smaller things if you accept big caveats.