Discussion thread: reply to the RSA

peasant

In this thread we will collect and discuss all the points that our reply to the RSA needs to address.

In the draft of the letter (see other thread/link) the points will be numbered.
When discussing these points, please use the appropriate number

Niall_G

Point 4 - LHD lights. The commercial testing manual specifically says that beam benders are acceptable when the vehicle is "mainly" driven on the continent. I don't see any tester arguing the "mainly" so that point is probably moot.

I have a slight concern about the rear fog and reversing lights (ie do they need to be switched around) but on a quick read couldn't find anything that specified which side they need to be on. In a worst case scenario that wouldn't be the most difficult job in the world anyway.

peasant

Niall_G wrote: »

I have a slight concern about the rear fog and reversing lights (ie do they need to be switched around)

Point 4) My private car is LHD (with RHD front lights though) and the single rear foglight is on the left.
I have inquired with the NCT, up to now this wasn't an issue and has passed an NCT test twice since

Niall_G

Thanks Peasant. It looks like lights won't really be an issue at all then. Now back to those pesky windows......

peasant

Niall_G wrote: »

Point 4 - LHD lights. The commercial testing manual specifically says that beam benders are acceptable when the vehicle is "mainly" driven on the continent. I don't see any tester arguing the "mainly" so that point is probably moot.

Can you provide a link/copy to where it says that?
Is that in the HGV or LGV manual?

I couldn't find it in the LGV manual, haven't checked the other one yet

Niall_G

Peasant,

It's in the HGV manual, Page 60 (actually page 126 of the PDF), "Headlamp Condition, Notes":

"Headlamp beam converters fitted to right hand dipping headlamps of vehciles which are mainly used on the continent, which effectively mask/deflect the beam are acceptable provided that the pass/fail criteria is met".

Mind you, after your post, I looked at the LGV manual and strangely, the same section makes no mention of this, so maybe we do need to clarify it.

niloc1951

Here are a few of my initial thoughts about issues to be put before the RSA
HGV (over 3,500kg) manual
Test 2
Weights and dimensions plate, while motor caravans have a weight plate they do not have dimensions included on the plate, so the plate will not be 'as specified'
Test 4
Air/Vacuum warning requires visual or audible system to be fitted. Usually such is not part of OE on motor caravans though vacuum (servo) assistance is a feature.
Test 14
Requires such a device (gauge) to be fitted in order that the test can be carried out.
Non compliance is cause for failure in both tests.
Test 8
Mirrors, motor caravans over 3,500kg. unlikely to pass this test.
Test 9
Wipers, motor caravans from Continental manufacturers which are RHD but were built with LHD wipers would fail this test.

There are many tests in the HGV manual which are inappropriate to motor caravans.
The Light Goods Vehicle manual is however quite close and reflects the testing regime required by Directive 2009/40/EC for ALL motor caravans irrespective of shape, size or weight.
Since the recently issued HGV manual specifically does not include motor caravans in the list of vehicle categories to which it applies, the RSA could/should simply add 'motor caravans' to the category of vehicle to which the LGV test applies.

I would also question if the RSA have a hidden agenda as they have backed their conclusions for the discussion document with data from countries with relatively small of motor caravan fleets (which include Cyprus, Malta, Romania, Denmark, The Netherlands and account for less that 5% of motor caravans on the European fleet) and not included others (Germany,France, Belgium and Sweden) who alone account for over 62% of the European fleet and are recognised as being among the most advanced in the world on issues of vehicle and road design and safety.

Surely the answer to the 'windows' question could be found in either the UK, Germany or France. Those countries would be considered to be world leaders in road safety technologies and they DO have for over 714,000 motor caravans of all types and ages certified as roadworthy

peasant

Hi Niloc

Yes, I can see a few issues there. (point 7 in the letter)

A camper that is built on a truck chassis (7.5 ton or more) would be quite a different animal from a camper that is built on a van chassis but rated at 3800 kg or 4200 kg (and so falling into the HGV test category)

Difficult to get the head around though and to put into words for our letter.

We should really press for a camper specific test procedure and not just a badly fitting copy and paste from existing DOE tests

niloc1951

peasant wrote: »

Hi Niloc

Yes, I can see a few issues there. (point 7 in the letter)

A camper that is built on a truck chassis (7.5 ton or more) would be quite a different animal from a camper that is built on a van chassis but rated at 3800 kg or 4200 kg (and so falling into the HGV test category)

Difficult to get the head around though and to put into words for our letter.

We should really press for a camper specific test procedure and not just a badly fitting copy and paste from existing DOE tests

IMHO, we would be best sticking firmly with what is set out in Directive 2009/40/EC. This directive covers ALL road vehicles, divided into six categories. The Directive sets out the same testing criteria for passenger vehicles with not more than eight passenger seats and good vehicles not exceeding 3,500kg.
There is no 'motor caravan' specific test contained in any of the EU directives concerning roadworthiness testing of vehicles
When read in its entirety, the Directive clearly intends that 'motor caravans' be tested as passenger vehicles with not more than eight passenger seats, irrespective of weight, shape or size, the test for goods vehicles not exceeding 3,500kg is exactly the same in the Directive.
It should therefore follow that the RSA should apply the NCT or the LGV testing procedures to 'motor caravans' of all weights, shapes and sizes and stop faffing around about testing according to their HGV manual.

peasant

niloc1951 wrote: »

IMHO, we would be best sticking firmly with what is set out in Directive 2009/40/EC. This directive covers ALL road vehicles, divided into six categories. The Directive sets out the same testing criteria for passenger vehicles with not more than eight passenger seats and good vehicles not exceeding 3,500kg.
There is no 'motor caravan' specific test contained in any of the EU directives concerning roadworthiness testing of vehicles
When read in its entirety, the Directive clearly intends that 'motor caravans' be tested as passenger vehicles with not more than eight passenger seats, irrespective of weight, shape or size, the test for goods vehicles not exceeding 3,500kg is exactly the same in the Directive.
It should therefore follow that the RSA should apply the NCT or the LGV testing procedures to 'motor caravans' of all weights, shapes and sizes and stop faffing around about testing according to their HGV manual.

Yes, you are right ...the ECE directive really has fairly minimal requirements

CATEGORIES OF VEHICLES SUBJECT TO ROADWORTHINESS TESTS AND FREQUENCY OF THE TESTS
Categories of vehicle
Frequency of tests
5. Motor vehicles having at least four wheels, normally
used for the road carriage of goods and with a
maximum permissible mass not exceeding 3 500 kg,
excluding agricultural tractors and machinery
Four years after the date on which the vehicle was first
used, and thereafter every two years
6. Motor vehicles having at least four wheels, used for the
carriage of passengers and with not more than eight
seats excluding the driver’s seat
Four years after the date on which the vehicle was first
used, and thereafter every two years

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:141:0012:0028:EN:PDF

It also only stipulates a bi-annual test

I'll try and squeeze this into the letter once I have my thinking head back on

niloc1951

In the Directive paragraph 20 reads

Member States may, if appropriate, exclude from the scope of this Directive certain vehicles that are considered to be of historic interest. They may also
establish their own testing standards for such vehicles.
However, such a right must not lead to the application of stricter standards than those which the vehicles concerned were originally designed to meet.

Note the last sentence, it could be used to try and deal with the issue of windows in older motor caravans which were obviously acceptable at the time of manufacture but may not meet the RSA's current standards.

niloc1951

niloc1951 wrote: »

Test 4
Air/Vacuum warning requires visual or audible system to be fitted. Usually such is not part of OE on motor caravans though vacuum (servo) assistance is a feature.

Such devices are fitted to some motor caravans, for example those based on MAN chassis where the gauge is part of the OE dash/instrumentation.
It should not be a requirement, irrespective of DGVW, unless it is part of the Original Equipment. For example a 5,000kg. DGVW motor caravan based on a Ducato will not have such equipment.

Aidan_M_M

Peasant.. a sticky NCT tester might not be as lenient on the Fog/Reverse light issue .

Wonder how they'll view swivel seat bases , and rear seatbelts? Not too many motorhomes of a few years old have the paperwork for them.

And probably half the Ducato 2.5's out there will fail the emissions , they were always smokey , especially the pre 95 Turbos.

A-Class campers... some have none OE front seat belt mounts? And the roll over / crash protection will be different to Ducatos/Sprinters/Transits?

One major fear I have is someone taking a coach built , with double rear axle in , something say around 4 tonnes , and it being tested like a 7500kg truck . They'll make a meringue out of the body!

tuppence

Hi coming at with a less technical point of view is it worth on the Point 1 (Costs ) to also emphasise the importance of the motorhome population to the local economy as a vital source of income into local tourism in a time when this industry needs investment.

Any process that increases safety is to be welcomed but it should be affordable and not disincentivise the tourism industry.

peasant

Very good points Aidan

most of it goes back the the type approval thing that I mentioned previously (somewhere)

Provided that these vehicles haven't been fitted with homemade bodge jobs or fettled with by cowboys and still are in good working order ...they should cxomply to the criteria that were valid when they first hit the road (smoke on old diesels) and they should have had type approval (and thus were raod legal) when they first came out.

It can not happen that the RSA/DOE retrospectively makes something illegal which had european approval at the time ...be that certain emissions or a swivel base. We need to point that out to them ...somebody might take them to the European court otherwise

Can you elaborate some more on your concerns re the twin axle ALKO-chassied Duc and the HGV test? What exactly do they do that could damage it?

I'm off to bed now ...had enough for today

Aidan_M_M

peasant wrote: »

Can you elaborate some more on your concerns re the twin axle ALKO-chassied Duc and the HGV test? What exactly do they do that could damage it?

I'm off to bed now ...had enough for today

Haha sleep well Sir!

AFAIK , some trucks get clamped down and they put torsional forces to the chassis , to check the strength.. I really hope I'm wrong about that , but will speak to someone who knows ASAP.

wonderworm

according to the consultation document, motorcaravans are already tested??? does anyone know about this?

peasant

BTW ...anyone any ideas what the main motorhome clubs are doing about this?

Would be a pity if we were found to torpedo each other's work.

peasant

wonderworm wrote: »

according to the consultation document, motorcaravans are already tested??? does anyone know about this?

They were supposed to be tested ...only no one ever told anyone about this or did anything about it.

According to EU regulations trailers and motorbikes shouldn't be going untested either ...I guess they'll be next on the list. (and an even biggger headache for the RSA to shoehorn into the existing NCT/DOE test structure)

wonderworm

peasant wrote: »

They were supposed to be tested ...only no one ever told anyone about this or did anything about it.

that's what I thought, interesting that in the consultation document it says they will continue to be tested!

wonderworm

peasant wrote: »

BTW ...anyone any ideas what the main motorhome clubs are doing about this?

Would be a pity if we were found to torpedo each other's work.

I was contacted by Bill or whatever his name is from the Motorcaravan Club in Meath/Kildare last year about this and he was totally against anything being introduced. I've no idea what their stance is on it now as I don't have anything to do with the Club.

niloc1951

wonderworm wrote: »

according to the consultation document, motorcaravans are already tested??? does anyone know about this?

FACT, motor caravans are NOT included in the categories of vehicles required to be roadworthiness tested in S.I. 771 of 2004. Check it out yourself

Currently there is no statuary requirement on the Irish statute books that motor caravans must be presented to the RSA, or any other body, for testing. Part of the current process will have to include a further S.I extending the scope of S.I. 771 to include 'motor caravans' in the list of categories of vehicles subject to its provisions.

niloc1951

wonderworm wrote: »

I was contacted by Bill or whatever his name is from the Motorcaravan Club in Meath/Kildare last year about this and he was totally against anything being introduced. I've no idea what their stance is on it now as I don't have anything to do with the Club.

The Republic of Ireland is currently out of step with the rest of the EU, 'motor caravans' must be tested, it's just that when our current legislation covering vehicle testing was being drafted by our civil servants they forgot to include 'motor caravans' or else didn't know they were a unique category of vehicle on their own and required separate mention

peasant

niloc1951 wrote: »

The Republic of Ireland is currently out of step with the rest of the EU, 'motor caravans' must be tested, it's just that when our current legislation covering vehicle testing was being drafted by our civil servants they forgot to include 'motor caravans' or else didn't know they were a unique category of vehicle on their own and required separate mention

..and it looks like that the proposed test for motorcaravans is a typical Irish solution for an Irish problem ...arra, sure, it'll do

Well, whether it will or won't do really depends on the testers. They will be supplied with test criteria that were not specifically written for motorhomes and they will find bits and bobs on a motorhome that aren't covered in their manual or they won't find items that according to the manual should be there.
See also issue 8 in the letter

Not a very satisfactory situation really.

Slidey

Aidan_M_M wrote: »

Peasant.. a sticky NCT tester might not be as lenient on the Fog/Reverse light issue .

Wonder how they'll view swivel seat bases , and rear seatbelts? Not too many motorhomes of a few years old have the paperwork for them.

And probably half the Ducato 2.5's out there will fail the emissions , they were always smokey , especially the pre 95 Turbos.

A-Class campers... some have none OE front seat belt mounts? And the roll over / crash protection will be different to Ducatos/Sprinters/Transits?

One major fear I have is someone taking a coach built , with double rear axle in , something say around 4 tonnes , and it being tested like a 7500kg truck . They'll make a meringue out of the body!

TBH for a turbo to fail the emissions it has to be bad, we would only fail a handful of them every year. The tolerance on turbos of that age is 3.0 A standard Isuzu Trooper of the same age would probably blow below 2.0 and a new sprinter might blow 0.09

Roll over/ crash protection has nothing to do with the DoE test. So long as the body looks secure and has no structural corrosion.

If a camper is presented for test and its dgvw is under 3500kg it will have its brakes calculated to 55% of its weight on the day.

If it is over 3500 kg then each axle will be individually chained down (or chassis point close to axle depending on design) to its gross weight and then the brake test will be conducted. The overall brake readings are worked out using the vehicles DGVW and a result of 45% must be obtained. Further more an emergency brake reading of 22.5% must also be recorded.

Unless the motorhome is a total shed it should take this weight in its stride.

niloc1951

Slidey wrote: »

If it is over 3500 kg then each axle will be individually chained down (or chassis point close to axle depending on design) to its gross weight and then the brake test will be conducted.

WAAAAAAAAAA, :mad::mad::mad::mad:
you can't do that to an AL-KO chassis/axle assembly. Its a very technically sophisticated piece of engineering to achieve the highest strength/load bearing capability for minimum materials/weight. Fixing anything which adds stress, other than AL-KO approved bits to AL-KO approved positions, IS NOT ALLOWED.

Slidey

Sorry to put your nose out of joint but that is bullschit.

If Fiat decide that the 2 rear axles on their ducato can take 1700kg of a static load and the vehicle comes in with 1200 on them, that means I will chain it down with an extra 500kg. That is 250kg a chain.

Trust me on this, if you were to drive down the road and had your vehicle fully laden and bouncing on a rough road, far greater forces would be exerted on your axles.

2 stroke

niloc1951 wrote: »

when our current legislation covering vehicle testing was being drafted by our civil servants they forgot to include 'motor caravans' or else didn't know they were a unique category of vehicle on their own and required separate mention

Or was Motorcaravan category created at this time, to reduce the specs of equiptment in NCT centers, while still holding onto high VRT. Up till the time NCT testing legislation was being drafted, motorcaravans were road taxed as private cars and calls to reduce this motortax, fell on deaf ears. At that time, if they turned around and sent campers to doe centers, the lynch mobs would have been out. So the easy way out was to give the clubs more than they had hoped for and a new vehicle category was created. My road tax came down something like £300/year. I don't think anybody complained that we took a different path to the rest of europe, until recently.

peasant

Slidey wrote: »

Trust me on this, if you were to drive down the road and had your vehicle fully laden and bouncing on a rough road, far greater forces would be exerted on your axles.

Where would you fix the chain to though?

These chassis are a bit flimsy, you wouldn't want to just hook the chains into one of the cutouts

picture from AL-KO website

Slidey

I can't remember the exact suspension set up but if it was like below I would put it as close to the front shackle on the spring.



The reason it is chained down is to stop the wheel from locking the rollers before its full braking force is achieved.

peasant

Most AL-KO chassis come with torsion beams, so no beefy springs to sink your chain into. Some ham-fisted tester might be tempted to just sling it through one of the cutouts.



Fired off a mail to AL-KO anyway to see what they know about this (I bet the test is the same in other countries) and if they have recommended anchor points on their chassis.