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Official Interpreter

26th September 1991
Page 36
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Page 36, 26th September 1991 — Official Interpreter
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Which of the following most accurately describes the problem?

Leyland Daf's product marketing manager John Baker has damning views on the Department of Transport's rule makers. In the first of a new series he describes the trouble truck manufacturers have in interpreting forthcoming legislation.

manufacturers ,, sari nwa na always a c t under er r pressure r we s se are

a to meet customer demands nd requirements and this is an accepted part of our job.

But must we also be the official interpreter for Department of Transport legislation?

ABS, which becomes law from a manufacturing point of view in a few weeks, is a prime example. It was only a few weeks ago that the final interpretation of the law was clarified — but not all CV manufacturers are interpreting the legislation in the same way.

ABS legislation was clear about the implementation dates — vehicles have to be equipped with ABS if they are manufactured after September this year and registered after March 1992.

But it was not clear in terms of the vehicles affected. The legislation states: 'All vehicles of 16 tonnes gross and above capable of drawing a trailer of 10 tonnes or above must have ABS fitted.'

But what does capable mean?

Our original interpretation was quite simple. If it's got a coupling then it's capable of towing some kind of trailer. But how was the 10 tonnes defined? Capable of towing 10 tonnes — is that actual capability as per spec sheet? Or is it design capability, or Type Approval documentation capability?

Leyland Daf s 1900 rigid is a good example. It is sold on the Continent with a GTW possibility of 30 tonnes. But in the UK it can only gross at 24.39 tonnes. So does it need ABS or not?

Judging by the number of phone calls our product department has received we are not the only ones confused. Other manufacturers, customers and industry associations are phoning us for advice.

AAt one stage there was even some d if a 17-tonne solo required ABS or not.

We are all in favour of legislation that improves road safety — but it must be concise from the start. Why does the legislation governing ABS not recognise the dangers of mixing ABS-equipped semi-trailers with non-ABS tractive units? Only a fully equipped ABS combination will give a worthwhile increase in safety.

The latest piece of legislation to pass through Parliament involves road speed limiters. When the introduction of these devices was first muted some months ago the manufacturers had a number of questions — all of which were put to the ministry and most of which were ignored.

Again, the use of the word capable had crept in.

What was meant by capable of exceeding 60mph. Was it based on geared speed? Should we take into account governor run-out? Or were they looking at powered speed which would give manufacturers problems in identifying usage/body types and so on.

And why 60mph? Why not 100km/h which could be considered as a more European approach.

What about retrospective fitment — did they really mean speed limiter fitment to vehicles perhaps with a lower cut-off limit of around 20 tonnes GVW.

The result is that, as we approach the Single European Market, the UK will be introducing speed limiters set at 60mph on all vehicles over 7.5 tonnes as from 1 August next year. It is proposed that two months later, from 1 October, the other community members will be introducing speed limiters set at 80km/h for vehicles over 12 tonnes GVW.

But the good news is that at least the retrospective fitment for the UK has been clarified: speed limiters will be required on vehicles first used after 1 August 1988 if it is 'an articulated combination with a tractor exceeding 16 tonnes or a drawbar combination the drawing vehicle of which has a gross weight in excess of 76 tonnes plus a gross train weight of at least a further five tonnes.'

Or does it say capable of pulling a trailer... or was that ABS?

It doesn't really matter, because the legislation is not a manufacturing requirement — the onus is on registrations from August next year, so the end user is responsible.

Of course, we will fit ex-factory. All we ask for is consistency, simplicity and a more specific definition of the legislative requirement.

If we produce a truck or tractor with a theoretical speed of 58mph, then governor run-out could well take it above 60mph but a large body or semi-trailer could drag its powered speed down to 55mph.

But does it need a road speed limiter? According to the legislation, no. But how do we know the powered speed when producing the original chassis cab? The fitment of speed limiters on the production line is both in the interests of ourselves and our customers.

The subject of weights and dimensions is also very topical at the moment. There has been a great deal of discussion about the UK being obliged to accept certain vehicles on international transport from 1993 at different weights to those currently permitted for our own domestic operators.

Policing vehicles according to their destination wouldn't be easy, but it is also difficult from a manufacturing point of view to design and develop a 'road friendly suspension' or an 'air or equivalent suspension' when no measurement criteria has been established. Remember we are talking about 1993 — just 15 months away. On 6x4 units there was a great deal of talk about a suspension requirement that met 2HZ. Then it moved to 2,5 and our understanding now is that it's likely to be 2.3. But what about single-drive axles? What is the consistent measurement requirement for these? In engineering developing and testing terms January 1993 is tomorrow. We need to define the specific requirements today.

On the dimensional front it is proposed that from January 1992 drawbar units will be allowed to operate at 18.35m overall length if they are engaged on international journeys — but only 18m if they operate on domestic work. Coupled to the 18.35m length limit is a maximum allowable body length of 15.65m within an overall envelope of 16m, But if the UK sticks to the current 18m legislation then we can still accommodate longer body lengths than with the new longer 18.35m overall lengths. Where is the logic?

Let's not forget the green issue where legislation is coming thick and fast.

It is genereally accepted that these new levels of emissions will only be achieved with low content sulphur fuel expected to be available by the time the standards apply.

However, these environmental measures should not be looked at in isolation and the improvements in engine specific fuel consumption achieved over the past decade or so will be stopped in their tracks. These imminent environmental controls could bring about a 4% deterioration in fuel consumption

— so you get less acid rain but more global warming. The diesel engine is a bit like a water bed — you can push down hard in one area but it pops up elsewhere.

Leyland Daf could meet the requirement with expensive research into a better combustion process. But if we did so would the Dip say well done lads"?

Of course not. They'll say 'well if that's what you have achieved without a particulate trap just think the improvement that can be made by fitting one. So off you go, fit one.'

So did we need to develop that expensive four valves per cylinder unit with overhead cams in a genuine attempt to avoid the need of a very expensive particulate trap?

There is no doubt that truck technology through the 1990s will be driven by legislation and from our point of view we have no problem with the motives of better safety or a better environment, OF both.

But perhaps this is better achieved through a much closer dialogue and understanding between those people that have to design the products and the legislators.

Tags

Organisations: Department of Transport
People: John Baker

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