VEHICLE MAKERS AND OPEF TORS REVIEW REGULATIONS
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EARLY last year the S.M.D#I.T. and the Road Transport Organization Joint Conference received a letter from the M.O.W.T. stating that the Minister had ' decided to undertake a review of the Regulations governing the construction, equipment and use of motor vehicles in relation to post-war design and production. It was not his intention to review them in detail at this stage, but to consider only those requirements which affect major questions of design, and on which it is desirable that decisions should be taken before a return to normal conditions.
He, therefore, invitedthe submission, at art early date, of any suggestions which these respective bodies might wish to put forward for the amendment of such requirements, together with the reasons for those proposals, and any supporting data, The two organizations concerned have been working on this matter for some time, and as a result have produced a review of the Regulations, together with their recommendations. To it are appended the names of Lieut.-Col. D. C. McLagan, secretary for the S.M.M.T., and Messrs. J. F. E. Pye, chairman, Vehicle Supply and Maintenance Committee, and G. NV. Quick Smith, secretary, on behalf of the R.T.O.J.C. This review was submitted to the Ministry soon after its production on December 29.
. Introduction
I. The signatories to this Memorandum welcome the invitation from the Ministry of War Transport (by above letter dated February 18, 1944) to submit suggestions in connection with the Minister's intended review of the Regulations governing the construction, equipment and use of motor vehicles in relation to post-war design and prqduction.
2. It is noted that the Minister does not intend to review the Regulations in detail at this stage but to consider only those requirements which affect major questions of design and on which it is .desirable that decisions should be taken before a return to normal conditions.
3. The signatories submit for the consideration of the Minister the views contained in this Memorandum.
Policy of the Government 4. The signatories are of the opinion that the question of the Regulations governing the construction, equipment and use of motor vehicles is closely bound up with the general policy of the Government in relation to the Road Transport Industry. It is accordingly essential that preliminary consideration should be given to the Government's policy in this connection.
5. It is submitted that the main criticisms of the existing Regulations fall under two heads:— (a) While doubtless largely dictated by considerations . of public safety, they are not entirely so. In some instances they penalize and restrict the development and use of road -transport.
(b) They have survived from a period when technical progress had not reached so advanced a stage as at present. Some of the existing Regulations are based upon the principle that vehicles must be made to St the road, whereas the road should be so constructed as to accommodate vehicles which, incorporating the most modern technical features, are eminently desirable from the point of view of public safety and from the aspect of the advancement of the Nation in general.
Acknowledgment is made to Ministers who have from time to time amended the Regulations so that they have catered for certain technical developments which have arisen. It is considered, however, that the time is opportune for a revision to be made not solely from the point of view of what is 'current, bat from what reasonably may be anticipated in the course of, say, the next five years. 6:The signatories are of opinion that as vet the poten
8. It is considered that the general structure of the Regulations should be examined carefully with a view to achieving a logical plan in keeping with technical development.
9. This can be achieved without hampering development in the design and use of motor vehicles.
Publication of Regulations
10. The present method frequently involves reference to more than one set of Regulations in order to ascertain the
position on a -particular point. For example, the Regulations concerning the Authorization of Special Type Vehicles include a number of cross-references to the Construction and Use Regulations.
Ease of reference would be greatly facilitated if all Regulations concerning all Motor Vehicles and Trailers were consolidated in one publication. Those relating to any one subject. fur example, Brakes, should be grouped as to general provisions, and should be followed by those peculiar to any one type of vehicle. An. arrangement as indicated, togetl-rar with a con.preheusive index and crossreferences would be a most deSira.ble advance on the present system, which is often bewildering to those seeking information.
Trolley Vehicles
11. It is not tecommended that the existing Memorandum relating to Trolley Vehicles he superseded. by Regulations,. but that the terms of that Memorandum he brought into line with those relating to Motor Vehicles in general, so far r.s appropriate.
Vehicle Plating •
12. It is most. desirable that a -VehiclePlating Scheme on the lines similar to
those discussed prior to the war, whereby it would be an offence for the gross load imposed by a vehicle on the road to exceed that declared by the vehicle manufacturers, with such modifications as may now be considered desirable, should be introduced concurrently with the revised Regulations.
13. The letter dated February 18, 1944, from the Ministry, specifically exciuded Regulations affecting Speed.
It is considered impossible adequately to consider the Regulations in general without reference to speed, and recommendations under that heading are, therefore, included.
Classification of Recommendations 14. (a) Certain additional and amended Definitions.
(b) Speed.
(c) Brakes.
(d) Permissible Gross Moving Weights, (e) Permissible Overall Width.
(f) Permissible overall length of a vehicle or com lination of vehicles.
Other Regulations of a consequential or minor Character which are deemed to 'require reconsideration, are listed at the close of this Memorandum. In view of the expressed intention of the Minister not to review the Regulation a in detail at this stage, they are not referred to in detail herein.
RECOMMENDATIONS Certain Additional and Amended Definitions
15, (a) Trailer means any vehicle incapable of self-propulsion and designed and constructed to be drawn by a mechanically propelled ‘ellicle, provided that for the purpose of this definition a broken-down mechanically propelled vehicle which is being drawn in consequence of a breakdown shall be regarded as a trailer. (h) Light Trailer means any trailer not exceeding 1 ton in weight unladen, or one not exceeding 2 tons gross moving weight and not constructed or adapted to carry any load, or one with a permanent or semi-permanent load, the whole not exceeding 2 tons gross moving weight.
(c) Heavy Trailer means any other trailer.
16. (a) No change is recommended in the case of vehicles . which are now within the " no limit " category.
(b) It is recommended that other motor vehicles :— (i) With or without a' trailer having two or more wheels, provided that all the wheels of the motor vehicle and any trailer drawn thereby are equipped with pneumatic tyres, be permitted a speed of 30 m.p.h.
(ii) With or without a trailer, but with all or any of the wheels of the motor vehicle or of any trailer drawn thereby equipped with tyres of soft or elastic material, be permitted a speed of 20 m.p.h.
These recommendations are not intended to apply in any area in which a lower limit is now prescribed, or to Special Type Vehicles. 17. The following recommendations are made with regar-1 to brakes:—
.(a) That the existine Regulations as to brakes be consolidated and that they be so worded as to indicate that a brake is essentially a constructional feature and not within the category, of equipment_
(b) That in the case of a Heavy Motorcar having two steering axles and one driving axle, it shall suffice for one of the means of operation to apply brakes by direct mechanical action, 3qtliout the intervention of any hydraulic, electric or pneumatic device to the driving axle only.
(c) That, provided the recommendations as to speed contained in paragraph 16 (b) above are accepted, the Regulations relating to Heavy Motorcars shall apply also to Heavy Trailers constructed after an agreed date whether drawn by a rigid goods-carrying vehicle or forming part of an Articulated Vehicle.
(d) That in the case of 'Light Trailers, the exiting Regulations as to the braking of Trailers should apply. but that the Proviso to Construction and Use Regulation 50 (1) (a) be amended to read as follows:— " Provided that this sub-paragraph shall not apply in the case of a Light Trailer if its bMkes came into operation on the-overrun of the Trailer."
(e) That the following Regulation be s,ubstituted for Conditions of Fitness Regulation 17 and that it be of general application: " The means whereby brakes and steering connections are Secured shall be effectively locked so as to prevent accidental detachment."
(1) That Construction and Use Regulation 10, which relates to a warning device to indicate a failure or impending failure in the vacuum or pressure system be deleted. (The Regulation referred to is difficult to achieve in a satisfactory manner and the warning device tends to distract the attention of the driver from the road and to induce a false sense of security. It is pointed out in this connection that alternative means of braking must be provided.)
Permissible Gross Moving Weights
18. It is recommended that Construction and Use Regulation No. 66 (S.R. and 0. 1941, No. 398), which prescribes a weight of 10 tons which may be imposed on a 2-1t. transverse strip, of road surface, be retained.
That being so, the necessity for prescribing axle weight is not apparent, and regulation of the gross moving weight of a vehicle by reference to the Vehicle Plating Scheme should suffice.
The permissible gross moving weights recommended are: For a drawing vehicle or trailer ... 30 tons For a drawing vehicle and trailer ... 40 tons Provided in each case the tot41 weight at no time exceeds the total tyre capacity of the approved tyre equipment for the vehicle in accordance with the Plating Scheme and that overall width is increased to 8 ft.
Permissible Overall Width 19, It is recommended that the permissible overall width of those vehicles which are now permitted a width of 7 ft. 6 ins. shall be 8 ft. This alteration is particularly desired to enable manufacturers to be in a position to cater for export. The American standard is 8 ft.
Permissible Overall Length of a Vehicle or Combination of Vehicles
20 (a) .For any goods-carrying rigid motor
vehicle or hailer drawn thereby ... 35 ft.
(b) For an articulated vehicle ... 40 ft.
(This is a qualification of (a) and shall not apply in the case of an Articulated Vehicle constructed and normally used for the conveyance of indivisible loads of exceptional length.) (c) For a rigid goods vehicle together with -a drawbar and any trailer drawn ... 60-ft. 21. Substitute for Construction and Use Regulation 83 (iii) (SR. and 0, 1941, No. 398) the foIloiving:— "in the case of a light trailer " (as defined in 15 (b) above).
Special Type Vehicles
22. (i) In regard to vehicles which do not comply with the Construction and • Use Regulations, but which are authorized by the Special Type Orders for the carriage of abnormal and indivisible loads, it is recommended that such vehicles (whether motors or trailers) be unrestricted in respect of:—
(I) Laden or unladen weight with or without trailers, provided loading complies with tyre capacity in accordance with the Plating Scheme; • (2) Number of trailers towed; (3) Width of vehicle; (4) Length of vehicle; pnivided:—
(a) the operator has given two days' notice of the intention to use such a vehicle over a given route:—
(1) to the Police, who shouldbe responsible for convoying the vehicle and taking such steps as are necessary to warn Other road users; (2) to the Highway authorities; (3) to the Bridge owners or authorities.
(b) the operator locates lamps at night or markings during daylight in a manner to indicate the extreme 'width and length of the vehicle and/or its load; (c) the speed (with or without load; with or without trailer) is limited to 20 m.p.h. on pneumatic tyres except where gross moving weight exceeds 50 tons or where the width exceeds 9 ft. 6 ins., in which cases and in the case of vehicles on solid tyres the speed should he limited to 12 m.p.h.
(ii) It is recommended that the operator should no longer be 'required automatically to give an indemnity in respect of, damage to roads and bridges, The operator should be
liable only if:— _ (a) the Highway or Bridge authorities give notice to the operator of the unsuitability of the road or bridge at the time the operator gives notice of his intention to use. a Vehicle over the road or bridge in question; and (b) the Highway or Bridge authorities agree the maximum, compensation in advance in accordance with the proviso to Section 54 (i) of the Road Traffic Act, 1930; and (c) the damage is caused by reason of the fact that the average weight per inch width of tyre in contact with the road surface exceeds 15 cwt.
(iii) It is further recommended that as and when progress in road construction and vehicle design so permits. maximum speeds should be increased at least on specified roads.
(iv) Whilst in present circumstances, a measure of responsibility for damage to roads is accepted in accordance with paragraph (iii), nevertheless it is recommended that adequate roads at least capable of taking the maxitnara stress permitted under the Special Types Order (S.R. and O. 1941/ 987) shall be constructed and the operator relieved of liability for damage.
Consequential and Mittor Alterations 23. It is desired to place on record that the adoption of the recommendations herein would entail certain consequential alterations to other Regulations and that, in addition, 'there are other Regulations of relatively minor importance which could he Usefully reviewed. .
Recommendations concerning, the further • RegulatiOns referred to in the foregoing paragraph are reserved for the time being, but the matters in question include:— Construction and Use
(i) Direction Indicators and Stop Lights.
(ii) Trailers. • (a) Attendants.
(b) Closets (C, and U,22).
(c) Airks (C. and U.57). • (d) Plates denoting Trailers and _permissible speed. (0-Conveyance of passengers (C. and U.92).
(iii) Visors and Sun-shields.
Equipment and Use Fire Extinguishers, Condition a of Fitness, Should it be decided to amend the "Box" dimeusions of Public SerVice, Vehicles, various' consequential Regulations will need review. Operational Date
• 24. It is hoped that the recommendations herein contained, most of which constitute construction provisions for observance by manufacturers,will become operative at the earliest possible date, and thereby contribute to the development of immediate post-war vehicles on the most desirable basis.
25. It is suggested that any permissive provisions should become operative forthwith on publication of the new Regulations but that restrictive provisions should not come into operation until 12 months thereafter,
Long-term Policy
26. As progress is achieved in road construction and vehicle design, restrictions should be further relaxed and greater overall dimensions, gross moving weights amid speeds should he permitted to the full extent possible in the light of the conditions prevailing from time to time.
27. The greatest importance is attached to the principle of planning well ahead, so that this' country does not lag behind others in developing its internal transport system.
28. Furthermore, the signatorieS recommend that the Ministry of. War Transport confer in these matters with other Government Departments concerned in planning and take steps to see that the Road Transport Industry is taken into the fullest consultation and that Architects and Road Authorities are made aware of anticipated developments in vehicle design. The vast building and rebuilding operations which will be necessary after the war provide an exceptional opportunity for premises and approaches thereto to be so designed that the larger vehicles of the future May be accommodated with space permitting,adequate manceuvre. Suitable provision should also he made for the quick despatch of vehicles and exPeditious loading and unloading, so avoiding the present deplorable waste of vehicle-hours which represents so serious a loss to the community as a whole.
Export Trade..
29. The recommendations contained in this Memorandum have a material bearing.on the country's' export trade from three angles:— • ' (a) First, the motor trade is handicapped in competing in foreign markets if there are differing standards for home and foreign markets.
(b) Secondly, international uniformity reduces costs of 'vehicle production; this, in turn, reduces transport costs and assists producers in this country when corns peting in foreign markets.
(c) Thirdly, if this country is to regain its export ti-ado its internal transport system must he at least as good as tne best in any other country; most other countries enjoy some or all of the concessions recommended in this Memorandum and if such recommendations are' not adopted this country will be handicapped when competing in foreign markets.
SO. The importance of framing Regulations so as to foster as much' as possible the export trade of this country after the war, cannot be too strortgly•.stressed. For instance, the trend in America is towards wheels with wide-base rims and particularly so far as tyre equipment is concerned there will be a lack of inter-changeability of tyres and wheels with those produced in America unless motor vehicles in this country are allowed an. increase in overall width to at least 8 ft.
Conclusion .
31. The recommendations contained in this Memorandum are designed to •improve the service which Road Transport pan give to the community. By raising the efficiency of Road Transport to the highest possible level—to a level which will compare favourably with the best elsewhere in the world —costs of prdduction will be diminished, the standard of living at home will be .raised, and the restoration of this country's foreign trade will be facilitated. The signatories urge the Ministry of War .Transport to consider the recommendations herein contained from the point of view that it is in the best-interests of the community as-a whole that no restrictionS an Road Trail Sport should be imposed, Or retained. unless such a course --for good and Sufficient reasons. is unavoidable.