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Paul Dodd

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About Paul Dodd

  • Rank
    Lance Corporal

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  • Location
    Lincolnshire UK
  • Occupation
    Consultant Engineer
  1. Just in case someone fancies Beef instead of Turkey for Christmas.
  2. Setting aside whether there are allowances made for historic or Ex military vehicles, the current regulations regarding Lateral and Rear Underun protection are there for a purpose. That is to afford some protection to "unprotected Road Users" such as Cyclists and Pedestrians. With regard to Lateral protection, this is especially useful if you do not have the modern standards of Indirect Vision devices as it affords protection against anyone inadvertently falling beneath the rear wheels. I am sure you would agree that having to defend your self in this situation would be somewhat more difficult if the decision not to fit guards was made only on the basis of keeping the vehicle aesthetics original. For the IVA process certain vehicles are exempted these are the terms given: Vehicles with a distance of more than 3 metres between consecutive axles must be fitted with Lateral protection Exempt vehicles are: Artic Tractors, Car Transporters , Gulley Emptiers, Vehicles expressly designed and constructed for a purpose that would be hindered by the fitment of Lateral protection. Road Sweepers You can of course avoid fitting the sort of guards shown in the photographs if the body or any lockers etc fitted to the vehicle fulfil the same criteria. There are then certain conditions those parts must meet so as to conform. The type of devices shown in th pictures can be bought as removable devices, from companies such as VBG or Service metals. This is so they can be used practically to gain access say to the hoses on Fuel tankers etc, or in some cases where the vehicle is an N2G or N3G (IE Off road) they can be removed or stowed to prevent damage. So maybe you can consider this so they can be removed for showing and replaced for road use. For the Rear Underun protection, again for IVA purposes the default position is that all vehicles must have this, however again it is possible to obtain exemptions for certain types of vehicle. Generally this exemption covers vehicles where the equipment mounted to the rear would not be useable if a Rear Underrun device was fitted (EG A Fire Engine, or a Grit Spreader) In this case however Off Road vehicles (N2G or N3G) are exempt, so if your vehicle meets the criteria for becoming an Off Road vehicle ( and that isn't just that it has 4WD) , it would certainly make sense to register it as such to gain this exemption. If it doesn't have an exemption it may be possible that the bodywork could perform the same function both mechanically and dimensionally as the device in which case having had it tested and witnessed you could claim compliance in this way, but that would be unusual. So in a nutshell N2 or N3 (On Highway) it legally needs both N2G or N3G (Off highway) it needs Lateral but Not rear Underun Sorry for the rambling post but nothing in this line of work can be explained properly in a few words.
  3. The Regulation is the Road Vehicles Construction and Use regulation 1986 otherwise known as SI1078/1986 http://www.legislation.gov.uk/uksi/1986/1078/made You should however be aware that there are many amendments to what is the base legislation and these each have separate issue dates for each of the years in which they were issued. There are hundreds, and very little attempt to consolidate them into one document. So the legislation becomes very easy to cherry pick and read what you want to see. You also have to consider that because of the age of the vehicle you may be able to comply with C and U and not fit lights. However you also have to remember that there are many other acts which govern different aspects of the way we use vehicles and the roads we travel on. Foe example in this case consideration should be given to the Road Traffic act, The Road Vehicle Lighting Regulation Act and a number of others. Ultimately the way it works in UK law is that you can be charged under any number of offences pertaining to infringements under these acts but unless you admit to them they have to be tested in court. So, to take some extreme examples, if you are driving along in the middle of a nice clear sunny day, giving hand signals because you have no indicators, the police are not going to be bothered with you. If however, the weather changes or it gets dark , you make a turn, and are invisible to an overtaking motorcycle who didn't see the vehicle clearly or your hand signals, then trying to use a Defence of being compliant with Construction and Use Regs is not going to be adequate when faced with a charge of Causing Death by Dangerous driving. This is especially relevant when the solution is reasonable, and straight forward. IE Fit a trailer board etc to improve the visibility. Like it or not we live in a litigious society, and its all about minimising risk.
  4. Type approval as it is drafted under 2007/46/EC should only be applied to the manufacturers of new vehicles. A manufacturer can be the primary builder or anyone who adds to or modifies that originally approved vehicle. EG Volvo may build an 8 wheel flat bed, and they would gain approval for it as an incomplete vehicle, but a secondary manufacturer adding a HIAB would need to gain their own approval before a Certificate of Conformity can be issued to allow that completed vehicle to be registered. Clause 14 shows that: The main objective of the legislation on the approval of vehicles is to ensure that new vehicles, components and separate technical units put on the market provide a high level of safety and environmental protection. This aim should not be impaired by the fitting of certain parts or equipment after vehicles have been placed on the market or have entered service. Thus, appropriate measures should be taken in order to make sure that parts or equipment which can be fitted to vehicles and which are capable of significantly impairing the functioning of systems that are essential in terms of safety or environmental protection, are subject to a prior control by an approval authority before they are offered for sale. These measures should consist of technical provisions concerning the requirements that those parts or equipment have to comply with. The difficulty arises where an assumption is made that First registration of a vehicle, is deemed to be its first entry into service. Any attempt to impose the same strictures on a heritage vehicle would be foolish and should be challenged. However, the authorities (DfT/DVSA) have a duty of care to ensure that vehicles on the road today regardless of their age do not pose an undue risk to other road users, as such older vehicles have recently been required to have safety devices retrospectively fitted such as lateral protection frames and vision equipment and to this end it may be necessary to put the vehicle through an IVA process. The IVA uses standards which are not dissimilar to those within the Whole vehicle Type approval process, but there are certain dispensations which are allowable, and sometimes negotiable. With regard to exemptions for Military vehicles, the directive says, Vehicles designed and constructed for use by the armed services, civil defence, fire services and forces responsible for maintaining public order. The spirit of this part of the directive is designed to cover vehicles whose prime role sees them largely in work away from the general public, for example Specialist Fighting vehicles, etc where normal rules do not apply. That said, these vehicles when working on the road must still comply with legislation such as the Road vehicle lighting regs etc . Vehicles which serve a dual role such as Trucks, and Trailers are largely type approved from new anyway. So to summarise:, With older vehicles that are sold out of service and come up for first registration Whole vehicle Type approval cannot apply as the Owner will not be the Manufacturer. But it may be necessary to add some of the more modern safety features so that it can pass an IVA.
  5. I don't know if this has been discussed elsewhere but it may be something you guys need to discuss and/or get involved with. All to often in my line of work I hear the cry "we didn't know about this" or "nobody involved us" , and as they say forewarned is forearmed. https://movingon.blog.gov.uk/do-you-think-classic-vehicles-should-be-exempt-from-annual-test/
  6. C and U regs have been around in one form or another for alot longer. However then as now Military vehicles and those used primarily for use on airports or for specific tasks have always been granted derogations and exemptions.
  7. Tony thanks for your reply it helps me alot, if only to expose a grey area between the licensing requirements for a new type of vehicle and the interpretations of the traffic commissoners. Thanks again.
  8. Only when in service. Now thats an interesting point Tony B. Totally off topic now but it is relevant to some research I have been doing for s client. Do you know the piece of legislation that defined this as it would be useful to me or is it just sn off the cuff remark. Bus lanes are defined and controlled by s couple of pieces of legislation. The local transport act and the traffic management act neither of which define when they can or cannot be used. They do say however they can be used by buses taxis cycles and motorcycles. The road traffic and vehicle excise acts define what a bus is but they dont cease to be a bus when they are unladen. See my problem here. If you know the legislation I would appreciate taking a look. Thanks in advance.
  9. If you design build or import a new type of caravan for use in the EU it needs to be approved now. If its an existing design then it has to be approved by Oct 29th 2014. As it only affects new build it isnt retrospective. There is a difference between the statutory plates required to be fitted by a manufacturer and the ministry plates. There has been a requirement to fit an identification plate containing details of the manufacturer and the mass of a trailer etc since 1982. The ministry plates are only attached to vehicles that are for hire and reward, this is where the 1020 kg limit comes in. It gets very complicated when you define hire and reward as reward does not necessarily mean a payment. Of course this may all change when the MOT s for trailers comes in.
  10. Alot of US vehicles are capable of being equipped with continuous brakes but a majority utilise Electric or Electro hydraulic brakes. There isn't any reason for these not to be used in Europe other than the fact that they are triggered by an electrical signal either from the brake lights or from a decelerometer. The problem arises then with the overall reaction time. It is possible to tow more than one trailer in the EU providing the maximum train length isnt exceeded. Towing a vehicle on a dolly is not allowed except for recovery and there is some dispute with regard to towing on A Frames. When towing on an A frame the car is now counted as a trailer and as such the brakes have to work. There are some systems that allow the cars brakes and lights to be applied but again these have to give the correct reaction times. Some European countries dont allow them at all.
  11. Providing we are only talking about vehicles that are driven on B licenses and have less than 8 seats then there shouldn't be a problem. You should however always refer to the manufacturers data for the tow vehicle as some have surprisingly low towing weights and/or allowable imposed loads on the axles. The total towable width is 2.55m and the loading length of the trailer is 7m (the drawbar length is not counted) As for mirrors the minimum requirement is for using the tow vehicles mirrors however if the width of the trailer or more likely any load on it reduces the rear / side visibility (there are figures which I cant remember at the moment) then extension or supplementary mirrors must be used. These mirrors must be type approved.
  12. If I can help I will, my areas of expertise are Type approval, IVA and Licensing requirements, If you know of any specific "grey areas" let me know.
  13. Could you put it through an IVA? This would effectively give it a document that serves the same purpose as a CofC
  14. Just to pick up on an earlier point made, Fifth wheel trailers do need to have Type approval, however it isn't law for a fifth wheel caravan until next October (2014). There are currently problems with getting type approval for braking systems on these, as you are not allowed to have Over-run brakes, and I haven't yet seen an electric or electro hydraulic system from the US or anywhere else that actually has approval, although I am working on one at the moment. Some of these Fifth wheel caravans especially the larger US ones have an unladen weight approaching 3500 kg, when you add in the laden weight of additional furniture , crockery, your bikes and the barbecue the weight often climbs above 3500kg making them CAT 03 trailers which then mean they are subject to the same testing and plating required by HGVs.
  15. Ok, now this always gets contentious, so it is important to understand what all the various terms mean. (And to put the record straight I have heard of cases going both ways, so don't take as gospel what I say here will keep you out of court) Trailer and vehicle legislation refer to a number of terms some of which mean the same thing. For the Towing vehicle MRO or Mass in running order (sometimes called Kerbweight or Kerbside weight) refers to the weight of a vehicle usually defined by the vehicle manufacturer, it is calculated and their are various formula used but generally means A vehicle normally, with 90% full tank of fuel; an adequate supply of other liquids incidental to the vehicle’s propulsion; the driver but without any passengers; without any load, except tools and equipment with which the car is normally provided; but without the towing bracket. The MAM or Maximum Authorised mass (sometimes called the Gross vehicle Weight GVW or Max Permissable weight MPW) is the weight of the Tow vehicle complete with passengers, luggage, the dog and the imposed noseweight of any trailed load. Within this the manufacturer will specify Two other weights that these days are found the VIN plate: The Gross Train Weight (GTW) and the Maximum Permissable Towing Mass MPTM) For the Trailer you will generally see the following MiRO (Mass in running order) this is the ex works unladen weight of the trailer, and the Maximum Technically Permitted Laden mass (MTPLM), which is the maximum weight the trailer can physically weigh when loaded, IE the difference between the MTPLM and the MiRO is the Payload. Now the confusion arises with the difference between a Payload Trailer and A non payload trailer. So a non payload trailer such as a caravan is likely to plated with its MTPLM it may say 2000 kg and that is what it will weigh. But a Payload trailer has to be able to say on the plate what it can carry so for example a trailer could say on the plate 2000kg but this is only the max allowed. People have been summonsed for this because the plated weight is greater than the allowance for the tow vehicle even though the actual weight is less. There is a VOSA document however that states quite unambiguously that it is the actual weight that counts not the potential. So to give an example , I have a Vauxhall Zafira, the manufacturers figures for this are that the MRO is 1628kg the MAM as 2175 kg the Maximum Permissable Towing Mass as 1500kg and the Gross Train weight as 3550kg.My trailer has a MiRO 700kg and a MTPLM of 2200kg, so theoretically I have a payload of 1500kg. So assuming I don't carry any passengers or luggage I could theoretically only load a payload of 800kg (IE 700 + 800 = 1500 (the towing limit for the car) onto the trailer and still stay within the limits. This still gives me a total GTW of 3128 kg (1500 + 1628 well within the limits) so again I could load the car up with a payload of 422kg (3550 GTW- 1628 MRO ) providing the payload does not either take the car over its MAM (which it doesn't in this case) or overload the individual axle loads of the car. Hope this helps , bit long winded I know but there isn't an easier explanation. :cheesy:
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