DoE testing - The Last Word

niloc1951

Irishgoatman wrote: »

My apologies. My post on this subject was looking at it from a narrow personal point of view as I only have a small one campervan.


nailer8's original post contained the draft proposals for the new regulations and was asking for views/opinions to be submitted by the 17th of June, therefore those who feel that they will be affected have 18 days to try and get these ammendments changed.

As it was a letter to stakeholders, I would have thought that all of us who wrote to the RSA regarding the testing of 'vans should have received this letter.

I know of at least one stakeholder when the testing was being sorted out, but who has got nothing about the proposed new regulations.

Irishgoatman

niloc1951 wrote: »

I know of at least one stakeholder when the testing was being sorted out, but who has got nothing about the proposed new regulations.

Exactly my point.

I was one of the stakeholders for the testing documentation and received items from the RSA addressed to "Dear Stakeholder", I can only assume that this ammendment went out to commercial vehicle owners only, forgetting, as I did, that it will also affect owners of large campervans.

nailer8

In our case we operate a DOE (VTN/CVR) centre so that is why we got the letter.
I don't know what other "stakeholders" were informed.

Re what manual is used what i am told (again there seems to be some uncertainty) is as follows:
.5t GVW 2 Axle - LGV Lane - LGV Manual
>3.5t GVW 2 Axle - HGV Lane - LGV Manual
3 Axle Campers - HGV Lane - HGV Manual

I suspect legislating for campers is extremely hard as there are so many shapes and sizes of vehicles registered as campers. I have seen 27T horse box trucks registered as campers. Also 18t trucks sometimes with a rally car in the back registered as campers. Obviously these need to be treated as HGV's and have proper brake tests etc.

niloc1951

nailer8 wrote: »

In our case we operate a DOE (VTN/CVR) centre so that is why we got the letter.
I don't know what other "stakeholders" were informed.

Re what manual is used what i am told (again there seems to be some uncertainty) is as follows:
.5t GVW 2 Axle - LGV Lane - LGV Manual
>3.5t GVW 2 Axle - HGV Lane - LGV Manual
3 Axle Campers - HGV Lane - HGV Manual

I suspect legislating for campers is extremely hard as there are so many shapes and sizes of vehicles registered as campers. I have seen 27T horse box trucks registered as campers. Also 18t trucks sometimes with a rally car in the back registered as campers. Obviously these need to be treated as HGV's and have proper brake tests etc.

ALL motor caravans are subject to the same test as N1 vehicles, there appears to be no legal basis for testing them as HCV's which they are not.
In what way are motor caravans over 3,500kg GVW treated differently to those not over the figure

Horse boxes and race trucks are not supposed to be tested as 'motor caravans' and if so are in breach of the Roadworthiness Test regulations.
Such vehicles are categorised as 'living vans' and are subject to the same testing procedures and frequencies as commercial vehicles.

Circular RSA VI 02/12 says
Vehicles with living accommodation which are also used for transporting goods, i.e. vehicles fitting the description of a ‘living van’ are, for test purposes, goods vehicles and all goods vehicle test items are applicable. In this case the Motor Tax classification of the vehicle has no relevance to how the vehicle is tested i.e. the vehicle may have a Motor Tax classification of Motor Caravan but should be classed for testing as a “living van”. The definition of a living van in the above regulations is “a vehicle whether mechanically propelled or not which is used as living accommodation by one or more persons and which is also used for the carriage of goods or burden (including livestock and more than one motor cycle) which are not needed by such one or more persons for the purpose of their residence in the vehicle”.

Irishgoatman

As a stakeholder I've just received an email regarding the draft ammendments to the testing manuals. I presume that others will get one as well. I'm pasting, below, a reply that I intend to send off to the RSA in a day or two. Please let me have any comments/corrections to it. If you feel as I do, I would suggest everyone bombards them with emails.


Dear Ms. Barry,

Thank you for the apology for Motor caravan stakeholders being omitted from the circulation of the above draft notice.

The one thing that I fail to understand though is why we need to be included in the circulation of the above draft which states that it is for proposed changes to the manuals for HCV and LCV.

My Campervan is shown on the Registration Certificate as a private vehicle and I object most strongly to it being treated in any way as a Heavy Commercial Vehicle or a Light Commercial Vehicle.

When I, and many others, became involved in the formulation of a long overdue test procedure it was in the belief that, although the same centers as commercial vehicles would be used, the testing of Motor caravans/ Campervans would be done using a separate manual. If some testing procedures are the same as for commercial vehicles then so be it, they have to be repeated in the manual.

There is no logical reason, in my view, for a tester to use the LCV manual to test my small 2 berth PRIVATE Campervan and I hope that other owners of similar vehicles will feel the same.

My personal grumble with the manual is listing factory jacking points as a recommended stipulation for the suspension test. As mine are made of folded tin and only an eejit would try to lift a 19 year old 2 ton vehicle on them.
I'm happy include your grievance in my response email.

Irishgoatman

Sir Liamalot wrote: »

My personal grumble with the manual is listing factory jacking points as a recommended stipulation for the suspension test. As mine are made of folded tin and only an eejit would try to lift a 19 year old 2 ton vehicle on them.
I'm happy include your grievance in my response email.

Sorry but I'm not sure that I understand your last line.

My suggestion was that all others who receive this email from the RSA should reply with their own points of view. The more objections they receive the better.

My reply reads the way it does because, so far, I have no complaints with the way my camper has been tested. But, if they have to start testing in accordance with commercial test manuals, which I don't believe that the centre which I use does, then things might change, and that thought I do not like.

I think I'm basically in agreement although admittedly I'm a little confused what you may be trying to achieve by having a separate manual for campers.

Correct me if I'm wrong but aren't most coach builds based on a luton body chassis which for all intents and purposes would not their superstructure safety and integrity be covered by a LCV test? Mine is a self-build so I've no problem running her through on LCV specifications.

Does a separate camper manual not invite standardising a camper living quarters, which may involve certification of gas and similar paraphernalia? Thus making it harder again to reach a benchmark with much clerical ordeal.

I am not in any way trying to suggest that there ought to be an allowance for unsafe practices or lack of maintenance, as it is in my own inherent interest, self-preservation and consideration for other road-users that I keep my ship in good stead. What concerns me is the general direction Ireland is taking towards "generating jobs for the boys" by making everything taxable and certifiable at cost to the applicant.

I received same email you refer to and intend to reply my own points of view. Specifically as I mentioned my vehicle having sub-standard listed jacking points. Whereby I would have no problem letting any half decent mechanic lift my vehicle by any of many sturdy points ie. the suspension mounts, axles or chassis rail sub-frame at their discretion. I think listing a jacking point as a suggested test parameter is foolhardy and would be rather annoyed by a tester crushing my under-body paneling and then failing me also for jagged edges or the like without liability. Let's face it after 15 years most vehicle jacking points are worse for wear and the sensible option is not hard to find. I do not think this is a roadworthiness issue because the members are supported by box rail under the tin frame after the crushable 4 inches and the jack carried by the vehicle is a suitable hydraulic trolley jack accompanied by a stand.

Having said all this, what I meant was I'd be happy to copy and paste some of your post and niloc's into my reply to the RSA along with some other minor matters of concern to me, as the more objection there is to this the higher likelihood there is to amend it.

Irishgoatman

Everything you have said is fine if that's how you feel.

Perhaps I shouldn't have invited comments/corrections in my original post. I just thought, wrongly, that it might have drawn suggestions from people who had not received the email.

When testing in DOE centres first raised it's head so many people on here were concerned about the way their camper would be treated. People were concerned that campers would be shaken to pieces, that belongings inside would end up all over the place, crockery would be broken etc.

This is why I believed that we would have our own manual which would make allowances for this. And I still firmly believe that as it's a seperate class of vehicle it should have its own manual and if parts of the other manuals apply then they should be copied in.

If you don't feel the way I do then that's fine, just reply to the email with your comments.

Thank you for the offer of including my comments/views in your email but I fail to see why, as the first person to bring up this issue of replying and the only person to give others a preview of the letter I intend to send I should then allow any of my comments to go under another persons name.

Niloc's post does concern me. There's plenty of vehicles out their that can be up/down rated without modification. For example the twin axle Iveco Daily luton body can be changed from 3.5ton to 7.5ton without modification according to Iveco.

The only benefit I see of classifying a camper as a private vehicle for test purposes is perhaps an unlikely reduction of testing fees, but I'm not entirely unconvinced.

I think having crockery or glass in a vehicle, especially if it's not protected somehow, is inviting disaster. Plastic and metal tableware would be what I consider traditional for this reason. The onus on protecting contents from the road I would have considered was on the proprietor to pack and although relevant, driving style should not be used exclusively to accommodate a loose pack.

I have never received my vehicle back from a DOE any worse for wear. I have however received a car back from the NCT with torn bushings and suspension noise where there wasn't before.

I'll keep plumbing this one for a few days before I respond to RSA.

Irishgoatman

Sir Liamalot wrote: »

Niloc's post does concern me. There's plenty of vehicles out their that can be up/down rated without modification. For example the twin axle Iveco Daily luton body can be changed from 3.5ton to 7.5ton without modification according to Iveco.

The only benefit I see of classifying a camper as a private vehicle for test purposes is perhaps an unlikely reduction of testing fees, but I'm not entirely unconvinced.

I think having crockery or glass in a vehicle, especially if it's not protected somehow, is inviting disaster. Plastic and metal tableware would be what I consider traditional for this reason. The onus on protecting contents from the road I would have considered was on the proprietor to pack and although relevant, driving style should not be used exclusively to accommodate a loose pack.

I have never received my vehicle back from a DOE any worse for wear. I have however received a car back from the NCT with torn bushings and suspension noise where they weren't before.

I'll keep plumbing this one for a few days before I respond to RSA.

I would assume, perhaps wrongly, that niloc became a stakeholder when the initial test discussions were going on and is quite capable of putting his own views forward. If others, under their own name, put forward the same concerns then so much the better. One hundred letters that have to be read is far better than one letter with one hundred names. As with the original letter that went to the RSA regarding testing as representing the view of boards members, we were all encouraged to send individual letters at the same time.

imo having a camper classified as a private vehicle for testing purposes is not a benefit, it is a must because that is what it is.

My mention of things being damaged to to rough treatment during the test was just repeating what was mention during the original discussions. I know from a recent rally that I attended that I am one of the few who carries a wine glass in my camper because I refuse to drink wine from plastic!.
If you look back at the original test thread you will see that quite a few were concerned about rough handling damaging property inside the camper.

I will be sending my reply to the RSA after checking to make sure that it is quite clearly my own views.
What others do is up to them of course.

Fair enough, I'm honestly not looking for an argument here, I, like you would like this carried out as best it can. You are of course correct that simply jumping on a band-wagon is not putting the best foot forward.

Not to belliger a point, I see no reason not to carry select items of glass/ceramic but it's only common sense to protect them in a case or otherwise suitable guard. My thoughts on the matter are that if they can potentially be harmed then it is due to inadequate packing.

Irishgoatman

I totally agree with your last point.

Now I've never seen how HGV's are tested but rough handling/shaking was a point that was raised by many people in the past, which is why I mentioned it.

Ah ha, now I see your logic (having blitzed the entire thread...gasp, sorry for jumping in late like that turns out the relevant section was only a page or two before where I skipped in). Food for thought too.

Irishgoatman

Sir Liamalot wrote: »

Ah ha, now I see your logic (having blitzed the entire thread...gasp, sorry for jumping in late like that turns out the relevant section was only a page or two before where I skipped in). Food for thought too.

So I guess we're still friends then:).

Were we ever not? I was seeking to understand the notion, not an argument. Sorry if it came across otherwise.

Irishgoatman

Sir Liamalot wrote: »

Were we ever not? I was seeking to understand the notion, not an argument. Sorry if it came across otherwise.

It's ok. Just my sense of humour.;)

kadman

Quick question on DOE test.

I have just bought an 87 camper that has been off the road since 2011, and never been doe'd.

Its first manufacture date is August 1987, and I have owned it since May 28th 2013.

Its now DOE ready, and provisionally booked for one on June 27th 2013.

What date will the new DOE run from, as its a first DOE done on this camper, given registration date, new ownership ect. Will it be a full 12 month cert I will be getting if I pass on the day.

Thanks.

Mods feel free to move this, if I have posted in the wrong thread.

kadman

Irishgoatman

Hi Kadman, as things stand at the moment you will get a full 12 mths. cert running from the test date.

The RSA were talking about arranging things so that tests were due on the date of first registration but, so far, to the best of my knowledge that idea appears to have been put on the long finger.

Best of luck, hope it passes.

I have a 1986 Bedford RomaHome, what's yours?.

kadman

Its a vw T25 Karisma 1987.

I,m very confident it will pass, I,m sure I,ve covered all the bases, and spent the money in the process :-)

I,ll keep you posted on it.

kadman
thanks

kadman

Happy days.

Camper passed with flying colours, even down to the black and white tele, that was
part of the original fittings, 26 years ago:-)

Seaswimmer

Hi all.

A quick query. My camper 2002 LHD import has a rear fog light and also a switch on the dash for it. However it has never been wired as I believe it was not required on the continent at the time. Would this fail a DOE whicjh is due soon. Its its first DOE test..

Sinderella

Hi, does anyone have a link to an actual checklist of what my camper needs to pass the Road worthiness DOE please? I assumed it was like an NCT and they checked tyres, brakes etc.. apparently not.

I'm very confused and not a happy camper

Aidan_M_M

Sinderella wrote: »

Hi, does anyone have a link to an actual checklist of what my camper needs to pass the Road worthiness DOE please? I assumed it was like an NCT and they checked tyres, brakes etc.. apparently not.

I'm very confused and not a happy camper

What did you fail on? Windows?

Irishgoatman

Seaswimmer wrote: »

Hi all.

A quick query. My camper 2002 LHD import has a rear fog light and also a switch on the dash for it. However it has never been wired as I believe it was not required on the continent at the time. Would this fail a DOE whicjh is due soon. Its its first DOE test..

The test is the same as for cars in this respect.

If it's fitted it must work.

Is it as "add-on" or original fitting? if it's original then very strange that it's not wired in . If it's an add on, just remove it.

Seaswimmer

Irishgoatman wrote: »

The test is the same as for cars in this respect.

If it's fitted it must work.

Is it as "add-on" or original fitting? if it's original then very strange that it's not wired in . If it's an add on, just remove it.

Well as I understand it when a coach built is built then the original light fittings are removed from the Fiat chassis and the camper builder puts their own lights onto the camper but the switch is left in the cab as that is not modified. I can only assume that the fog light not being a requirement back then meant that it was never wired in at the time. Its due on Thursday so I will see how it gets on..

Irishgoatman

Seaswimmer wrote: »

Well as I understand it when a coach built is built then the original light fittings are removed from the Fiat chassis and the camper builder puts their own lights onto the camper but the switch is left in the cab as that is not modified. I can only assume that the fog light not being a requirement back then meant that it was never wired in at the time. Its due on Thursday so I will see how it gets on..

Interesting. Let us know the result.

Another thought that has found it's way into my head is, as the vehicle is left hand drive then the fog light, if it's a single one, will be on the wrong side for driving here won't it? It's supposed to show the outside, in our case the right hand side, of the vehicle.

Seaswimmer

Irishgoatman wrote: »

Interesting. Let us know the result.

Another thought that has found it's way into my head is, as the vehicle is left hand drive then the fog light, if it's a single one, will be on the wrong side for driving here won't it? It's supposed to show the outside, in our case the right hand side, of the vehicle.

Excellent thought. So it would be dangerous to fix it....:rolleyes:

Irishgoatman

Seaswimmer wrote: »

Excellent thought. So it would be dangerous to fix it....:rolleyes:

There is your answer if they try to fail it on the light .

Seaswimmer

Irishgoatman wrote: »

Interesting. Let us know the result.

Another thought that has found it's way into my head is, as the vehicle is left hand drive then the fog light, if it's a single one, will be on the wrong side for driving here won't it? It's supposed to show the outside, in our case the right hand side, of the vehicle.

Well it failed the DOE on the fog light (+ an axle bumper stop missing) so I will have to get it wired up. Wont be charged for a retest, just an inspection and then hopefully that will be it. I did point out that it would be on the wrong side but that didnt seem to worry them So easiest to just get it going..