Mr. R. E. G. Brown Lets Off Steam
Page 68
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ONSIDER exemption 2K of the Road and Rail Traffic Act (Exemption) Regulations 1957. The effect of this is that a C licence is not required for a dual-purpose vehicle used by a commercial traveller for the purpose of soliciting orders, but not for the purpose of advertisement or the sale or delivery of goods.
"What a classical piece of confusion. Who is a commercial traveller ' ? What does 'advertisement' mean—that he shall not have a pamphlet describing the goods he sells? Or that the firm's name or the brand of its goods shall not be shown on the vehicle? Or merely that he must not distribute leaflets? Has he delivered ` goods ' if he leaves a sample?
"Does anyone know the answers? I don't."
In this energetic manner Mr. R. E. G. Brown, secretary of the London and Home Counties Division of the Traders' Road Transport Association, addressed the annual conference of the National Co-operative Traffic Managers' Association, in Blackpool on Monday, on "legal complications which plague and often irritate the• operator." The views he expressed were his own.
Service Mechanic's Vehicle
He went on: "Consider the complications of deciding to provide a service mechanic with a mechanically propelled vehicle instead of a pedal bike, to move him from job to job carrying his tools and spare parts with him. Buy him a Morris Minor and there is no question of C licence or records, even if he sometimes delivers the odd parcel or spare part.
"Buy him a Minibus and the same applies. Buy him a Traveller and you must register it as a goods vehicle, but it still remains exempt from the need of a C licence so long as he does not deliver the odd parcel. If he does, then he needs i. C licence. Buy him a 5-cwt. van and he needs a C licence in any event, even if he carries nothing but his own tools of trade.
"But these complications are nothing to those which set in if you happen to prefer him to use his own vehicle, and pay him a mileage allowance for doing so. He is then the user of the vehicle, so he is the person who needs the C licence, not his employer.
• Will Need B Licence
"Worse than this—if he delivers any small parcels or spare parts for his employer in his own van, he will be deemed to be carrying goods for hire or reward and will need a B licence or enter into some arrangement for the hire of the vehicle to the employer."
Mr. Brown said that he often told a harassed transport manager to "stick to 'a car if he tan," and asked whether any great harm would be caused by releasing all vehicles under 30 cwt. from the licensing system unless they were used to carry for hire or reward.
B22 The Morris Traveller type had folding seats and full rear access. As such it was regarded as a vehicle "constructed or adapted to carry goods." If, in fact, it were used to carry business goods, it must be registered as a goods vehicle and would probably require a C licence.
"On the other hand, a near relative of the Traveller has a folding back seat, but only half a rear entrance. Because of this profound difference in construction, it may be registered as a private vehicle, even if it used to carry business goods. It is not considered to be constructed or adapted for the carriage of goods," Mr. Brown continued, The Austin Omnicoach was also not regarded as being constructed or adapted to carry goods. This was because the seats were fixed and not collapsible, and it could be taxed as "private," requiring no C licence, even when business goods were carried.
"In practice, I suppose it could carry as many goods in the gangway and on the seats as the Traveller, but the slight variation of folding or non-folding seats makes all the difference in the rules of operation. It comes to something when the answer to a question about the registration or licensing of a small vehicle depends on whether it has a full door or half a door, or whether the seats fold or do not fold," Mr. Brown remarked.
It was time that basic principles were re-examined for the sake of simplification, and Mr. Brown wondered whether construction could not be ignored and the guiding factor be use.
Nearly Always Disregarded
There was no sense in having a 30-m.p.h. speed limit for a light van while the car model it resembled was unrestricted. Moreover, bad law was nearly always disregarded and became a mockery.
Apart from mentioning the proposal of the British Road Federation for the relaxation of the law concerning keeping records for those drivers working within 25 miles of base, Mr. Brown did not delve deeply into this aspect of legislation. However, be mentioned the anomaly whereby the driver of a coach used to carry workers to a site was not bound by the hours and records regulations because his vehicle, being for private use, was not considered to be a public service vehicle.
..„Fle then switched his contumely to the Construction and Use Regulations. One of the foremost problems concerned parking brakes. Was a parking brake expected to act sufficiently well to bring a vehicle to a standstill as an alternative to the foot brake? This might have been reasonable in days of lower speeds and mechanical foot brakes, but not so now.
Mr. Brown said that he had never thought that mirrors on lorries were big enough, and some windscreen wipers on big vehicles seemed to be a long way short of efficient standards. Winkinglight direction indicators ought to be made compulsory, and it was interesting to note that the manufacturers were in advance of official thinking in separating such indicators from rear lamps.
Unnecessary Brilliance
Despite the almost universal use of brake lights, these were not yet compulsory. With higher traffic speeds today, vehicles withont stop lights had become a greater hazard. Many drivers complained of the unnecessary brilliance of some direction indicators and brake lights. "I would like to see manufacturers again show the way to the law by laying down reasonable standards," said Mr. Brown.
There might be a need for new signals to differentiate between a moving and a stationary vehicle, he suggested, and there seemed to be scope for manufacturers to experiment with the possibilities of introducing luminous or reflecting materials into bodywork paint and tarpaulins.
Although there were rules to govern the lengths and widths of vehicles and gross vehicle weights, there were none about lengths, widths or weights of loads. It was not helpful to tell a transport manager that there was no laid-down overhang for a load, and that he must exercise his judgment as to what was safe and reasonable.
"Height of Futility"
There was even more doubt about carrying capacity. It seemed the height of futility to tell an inquirer that the maximum gross weight for his two-axled 30-cwt. van was 14 tons. The marking of gross weights on chassis by manufacturers would enable operators to assess carrying capacity relative to body weight.
Having unburdened himself of so much, Mr. Brown ended: "There are minor matters which I feel irritate and confuse unnecessarily. For example, why confuse the main regulations with odd references to steam engines, solid fuels and other relics of the past which now apply to so few vehicles? I think these could, with advantage, be transferred to the regulations for special types—they are special all right."
Mr. Brown spoke extempore on the subject of traffic restrictions. There was need, he said, for co-operation between manufacturers and operators for the imprOvement of vehicles in respect of speedy loading and unloading.