The requirements: how to meet them and what it will cost
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yESTE RDAY the Traders Road Transport Association held a conference at London's Hilton Hotel dealing with the new vehicle legislation 1967-1970. It was a most important conference, and proof of the interest in the subject was the attendance of 700 people—the maximum that could be accommodated—while over 100 applicants had to be turned away.
The Conference was divided into three sections. In the morning Mr. G. Turvey, assistant secretary of the TRTA, read a paper reviewing new legislation. This was followed by three operators—Mr. J. E. Farley of Tate and Lyle, Mr. L. G. Reed of United Builders Merchants Transport and Mr. F. K.
Farquharson of Shell-Mex and BP—giving their viewpoints. In the afternoon the manufacturers' viewpoint was given by Mr. L. D. Watts of Leyland Motor Corporation, Mr. G. J. Ibbitson of BMC and Mr. H. 0. Doughty of Taskers, who were supported by representatives from seven other manufacturers.
In this issue we deal with the papers available at the time of going to press and in next week's COMMERCIAL MOTOR a report will complete the picture and also cover discussions at the Conference.
The main sections of legislation due to come in from January 1 1968 affect brakes, plating and annual testing, and
Mr. Turvey's paper was designed to be a reference for those attending the Conference and also to provide a guide for the future. In his paper he said—
The braking regulations differ from other factors to be discussed as they are already embodied in legislation and their effective date is firmly established. The required standards are set out in Regulations 11, 43, 48, 60 and 78 of the Construction and Use Regulations 1966 : No. 1288 which came into operation on December 1 1966 and the relevant clauses become effective on January I 1968. New vehicles registered on or after January I 1968 must have brakes acting on all wheels which are capable of providing retardation rates of 0.5 g. (50 per cent) for the service brake and 0.25 g. (25 per cent) for a secondary brake. In addition a parking brake must be able to hold the laden vehicle on a 1 in 6.25 gradient without the assistance of stored energy.
The efficiencies must be attainable "at any time", that is throughout the vehicle's full speed range. The secondary brake can be independent of the service brake or alternatively the two can be linked through a split system. In the latter case, the braking layout must be designed and constructed so that despite the single pedal control, failure of one part must still allow for at least 0.25 g. retardation from the other. Dual braking systems which provide separate braking lines through a single pedal are also permitted, but where the secondary brake is a multi-pull handbrake the full efficiency must be obtained first time.
The secondary and parking brakes can also be combined but the minimum parking brake standard must be achieved by direct mechanical action—without the intervention of any hydraulic, electric or pneumatic device.
Manufacturers are developing their own techniques for meeting the standards. Their guide is a non-statutory Code of Practice developed jointly by themselves, the Ministry and operators. Dealing mainly with design and constructional factors, the code need be of no direct concern to most operators, but it is relevant to note that it suggests that manufacturers should construct to minimum braking standards of 0.6 g. and 0.3 g., giving operators a reasonable working tolerance between factory and in-use standards. Otherwise it will be extremely difficult to comply with the regulations during day-by-day operation.
New trailers
Trailers" manufactured after January 1 1968 must also have brakes working on all wheels which give a combination braking force of 0.5 g. and be so equipped that in any failure the driver can still apply brakes on two wheels giving a minimum efficiency of 0.25 g. It is equally important to remember that these trailers must also have a parking brake capable of holding the parked trailer on a gradient of 1 in 6.25.
Exemptions are provided for trailers of less than 2 cwt. unladen weight, land implements, agricultural trailers, broken down vehicles and certain other trailers fitted with over-run brakes.
Existing vehicles and the phasing-out period It was planned at one time to apply the 0.5 and 0.25 g. standards immediately to all vehicles although it would have resulted in thousands of vehicles being prematurely doomed to the scrapheap. Operators' associations suggested an interim period with lower standards, allowing them to phase-out their existing units on a planned-programme basis. This policy has been adopted, the standards for "existing vehicles" being:—
The efficiencies relate to maximum retardation. And existing commercial vehicles over 30 cwt. classified as heavy motor cars or motor cars, with the exception of works trucks, will have to meet these standards from January 1 1968.
As yet the termination date for the phasing-out period is not known, but it is expected that it will last at least until 1973. The TRTA is pressing for longer periods for multi-wded rigids and artics, for in some instances the conversion jobs on these vehicles look like being involved and costly and may be totally impracticable. Faced with this situation and the long average life of these units, particularly semi-trailers, a two-year extension seems entirely reasonable.
Either way it is imperative to have a decision on the duration of the phasing-out period as soon as possible. Operators cannot be expected to take sensible planning decisions unless they know the potential life of their present vehicles and the industry is now awaiting a positive lead from the Ministry.
On the termination of the phasing-out period, the higher newvehicle standards will apply to all vehicles but it is important to remember that no new constructional standards are laid down nor will be laid down for pre-1968 vehicles even after 1972-73. Attaining the minimum braking efficiencies is the sole criterion and the persistent rumours of compulsory conversion to three-line air systems and so forth are completely ill-founded.
Brakes must be tested
Over the past months the industry has been flooded with advice, quoted braking standards and recommended conversions for very nearly every vehicle. While much advice is soundly based, operators must be wary of accepting it at its face value and there is no worthwhile alternative to checking individual vehicles.
Certainly a Tapley meter or some similar decelerometer should be standard equipment for every fleet operator and even companies with only two or three vehicles will find such a meter a worthwhile investment. Failing this, operators should not delay in having their vehicles checked by some competent third party. Sensible planning decisions can only be taken once this vital information is available.
The alternatives
In considering the future, the operator has the choice of looking solely to the short-term—the January 1 1968 requirements—or to the conclusion of the phasing-out period. Some operators are bringing their vehicles up to the 1972 /73 standards immediately, but this is not essential. For five years or so all legislative requirements will be satisfied if vehicles meet the appropriate interim standard and any improvement beyond this is at the operator's discretion.
In determining standards operators must try to assess the braking capabilities of their vehicles under normal operating conditions. A vehicle which can only meet the minimum standard in the newlyserviced state will not do and any operator who plans on this basis is open to potential trouble.
Plating
Plans for introducing a plating scheme for commercial vehicles have been on the Ministry's files since the mid 1930s but only during the past few years has "plating" become a truly "live" topic. Now a plating scheme which will have a far reaching effect on goods vehicle operation, is about to commence.
There are two unrelated schemes, one involving plating by the manufacturers and the other by the Ministry, and it might be helpful to deal with the former and then concentrate on official Ministry plating which is the more important for operators.
Manufacturer's plating has been obligatory since 1964 on all goods vehicles built to the increased weights introduced in August of that year. Regulation 28 of the 1966 Construction and Use Regulations now extends this requirement to all new commercial vehicles first registered on or after January 1, 1968 and to most trailers over 1 ton unladen made after that date. Until the advent of Type Approval (anticipated for 1970), manufacturers' plates will merely act as guide-lines for operators and in themselves will not have the force of law.
However, no operator should exceed the weight specified on the manufacturer's plate without good justification, for prosecuting authorities would appear to have every reason for assessing overloading cases under the terms of Regulation 75 of the C. and U. Regulations against the manufacturer's assessed safe-loading limit as quoted on the plate. One police authority has already announced its intention of following this course.
During 1968 and 1969 all load-carrying commercial vehicles over 30 cwt. and about half the load-carrying trailers on the road will be called for their first MoT test during which they will be plated. Eventually it is intended to cover all trailers and semitrailers, and maybe other motor vehicles, but in getting the scheme off the ground the Ministry is to concentrate on normal C. and U. load-carrying vehicles. Suggested exemptions include electric vehicles, works trucks, mobile cranes and certain agricultural vehicles.
A plating certificate setting out full details of the vehicle including future permitted maximum axle and gross weights will be issued for each plated vehicle and the operator will also be given the official MoT plate to fit in a prominent position, probably inside the cab. The Ministry intends to issue plastic laminated plates and the procedure will apply irrespective of whether the vehicle carries a manufacturer's plate; the original idea of Ministry authentication of the manufacturer's plate has been dropped.
So, by the end of 1969 most vehicles should be equipped with one and maybe two plates, the official Ministry plate inside the cab, and where relevant, the manufacturer's plate on the chassis. In most cases the two will give the same details but where the quoted weights differ the MoT plate will prevail.
The approved plated gross and axle weights for most vehicles will be set out in an official standard list to be published by H.M.S.O., probably running to more than 20,000 entries covering every known vehicle and trailer made from 1951 to 1967.
So far it has been assumed that the weights quoted in the list will approximate to the manufacturers' stated weights with increases in certain instances. Probably this will still apply but the first sections led to slight differences of opinion on "safe" weight limits between the Ministry, manufacturers and operators.
Obviously the checking and consideration of 20,000 entries is a mammoth task, but if present plans prevail operators will only be allowed a cursory glance at figures which might commit them for the life-time of their existing vehicles. There appears to be ample justification for a one-year postponement of the introductory date. Failing this, the lists must be flexible and designed to permit frequent amendment after the first year's experience.
To return to the details of the Standard List: as stated, both axle and gross weights will be quoted. Vehicles will only be plated at the stated weights if they can meet the prescribed braking performance, but where the Ministry is satisfied that the standards cannot be attained without brake conversion, lower weights for non-converted vehicles will also be shown. In these cases dperators can choose between down-rating or the cost of a brake conversion, but down-rating will not be allowed to cater for illmaintained braking equipment. Similarly the full plated weights will only be allocated to vehicles fitted with tyres capable of carrying the relative axle weight. Then operators of vehicles fitted with lower capacity tyres will be able to opt for down-rating but the vehicles will be tested and have their brakes checked at the higher Standard List weight.
Probably the lists will be published towards the end of 1967
and from then on it is possible that the Ministry and police will consider the Standard List weights to be the legal maxima for the purposes of Regulation 75 of the 1966 C. and U. Regulations. If this happens vehicle payloads might have to be reduced in advance of the official Ministry plating of the individual vehicle. This is only a personal supposition, but as with new vehicles and manufacturers' plating, operators will presumably need to be sure of their ground before exceeding the listed weight. On the other hand, the courts might feel that the mere publication of a book by HMSO does not constitute adequate notice and if so operators will be able to load up to the C. and U. limit until the Ministry's plate is fixed to the vehicle.
Initially, plating will only cover load-carrying vehicles operated under the C. and U. Regulations, but this still leaves plenty of scope for peculiar and modified units which probably could not be included in a Standard List of 30,000 entries. In these cases considerable reliance will have to be placed in the judgment of the testing staff, but to aid them in attempting uniformity, a teleprinter advisory system between the 70 or so testing stations is to be established.
So in theory identical non-listed vehicles in different parts of the country should both be given the same weight. Many popular modifications such as third axle conversions will be included in the Standard List. But this still leaves the many do-it-yourself jobs. Here much will depend upon the circumstances and maybe the operator's powers of persuasion, but it looks as though much of the money spent on odd conversions will have to be written-off.
Exceeding the Ministry's plated weight will in most cases be an offence with a maximum penalty of £200. This higher penalty —increased from £50 by the Road Safety Act 1967—is already operative.
Much more thought should be given to providing better public weighing facilities and the Government's responsibilities extend far beyond the 70 weighbridges which they have promised (mainly for enforcement purposes) at commercial vehicle test centres.
In addition operators must equip themselves as well as they can and there is an urgent need not only for possible depot and site weighbridges but also for accurate instrumentation which can be built into vehicles. There has been some research in both these fields, but the latter seems to have got "bogged down" because so far the Ministry has not seen its way open to accept the small inaccuracy tolerance—about 2.5 pet cent either way—which seemingly is inevitable with existing equipment with a realistic price.
The Ministry is installing sophisticated individual-axle weighing machines in the test centres and operators could be in dire trouble if the Ministry decides to set the readings of expensive weighing equipment against the more utilitarian devices used by many operators. Most Continental countries with plating schemes allow generous administrative tolerances and it is to be hoped that their example will be followed here with the Police and Ministry examiners perhaps having their own code of practice incorporating recognized operating margins.
Plating will cover both gross and axle loadings and contravening the latter carries the same penalties as the former. Axle loadings will give rise to many operating problems. Not only will it be difficult to assess the weight on any axle at the start of a journey but it may vary during the day.
Restricted axle loadings on the scale now envisaged will give rise to vehicle purchasing problems. Operators might be obliged to buy larger vehicles than before to have a safe working margin on individual axles.
Articulated vehicles will be tested as linked units but tractors and semi-trailers will be assessed and plated separately; the former on the basis of the maximum permitted load when linked with the optimum trailer, the latter in relation to its design and constructional characteristics. Unfortunately neither of these plated weights will indicate reliably the permitted gross train weight which will be subject to wide variation with limitless tractor-trailer permutations and other factors such as axle spacings and the position of king-pins.
In spite of these complications, operators, drivers and weighbridge attendants will need to know the permitted train weight more or less at a glance. If they cannot rely on the plate or plates what can they do? The answer is some form of categorisation system whereby the permitted train weight at any time will be easily ascertainable from a schedule or similar chart which sets out the weight relative to any of the possible vehicle /trailer permutations.
Annual testing
Starting on some date in 1968 commercial vehicles over 30 cwt. unladen and load-carrying trailers will be called for their first MoT test when they will also be plated. Testing will be by Ministry examiners working in a network of test stations.
It is planned to test the oldest vehicles first and Wall goes according to plan most load carrying vehicles should have been tested by the end of 1969. Thereafter annual testing will start. Remember that the scheme will cover all vehicles irrespective of age and from 1970 onwards all new vehicles will be called forward on the first anniversary of their initial registration date.
The test centres
The network of testing stations has been designed to provide facilities within about 15 miles of any operator except in the more remote areas. The stations are being designed in five basic capacities to handle vehicles in the range from 5,000 to 40,000 per year. When the scheme is running smoothly vehicles should be processed at the rate of one every 15 to 20 minutes. The tests will be carried out on a conveyor belt system and any vehicle found wanting will have to be submitted for a re-test. Minor adjustments will, however, be permitted on the line if they can be completed quickly enough. From observations so far it appears that operators will be well-advised to send their vehicles in for test in the hands of an experienced fitter or mechanic. For some large operators it might be of benefit to . have staff permanently allocated to this task. Personal contacts and goodwill are always worthwhile.
Tester's manual
Each test station will be controlled by a qualified engineer but most of the routine testing will be carried out by semi-skilled staff working to detailed instructions set out in an official Tester's Manual. The instructions, covering over 70 aspects of vehicles are currently under consideration by a joint Ministry /operators' group but eventually copies will be available for operators to use not only when checking the Ministry's testing results, but also as a basis for companies' individual inspection schemes.
Booking the test
Little is known of the proposed booking arrangements but it is known that testing reservations will be handled through a central booking office in Swansea with records of the vehicles. Operators will have some say in the choice of test station but to ensure full capacity working the Ministry will probably take powers to direct vehicles—particularly late bookings--to specified centres.
In a way annual testing could make a bigger impact on road transport than any of the proposed measures if only because the powers of enforcement will be so much greater. Enforcing the braking standards and plating will rely in the main on spot-checks. Annual testing is all embracing and positive action will be required by all operators for, as with private cars, future excise licensing will depend upon producing a valid test certificate.
Operators' inspections and defective vehicles
A section of the 1967 Road Safety Act extends the GV9 procedure to empty as well as laden vehicles and these additional powers are likely to come into effect soon. The Act also confers extra powers relative to over-loaded vehicles and an MoT examiner, a policeman, or an authorised weights and measures inspector will soon be able to order the off-loading of excess weights when they are a danger to public safety. These two measures are of considerable interest, but a section likely to be more significant—because its impact will be allembracing—requires all operators to have vehicles regularly inspected between annual tests by a "suitably qualified person", and to retain complete maintenance inspection records for Ministry examination for up to 15 months.
Companies which do not have adequate inter-test maintenance and inspection facilities and which do not maintain the required records may lose their licences.
The TRTA Maintenance Inspection Service will be more than adequate compliance with the terms of the relevant section of the Act, and all the Association's inspectors are "suitably qualified persons" in the eyes of the 1967 Act.
Type approval
Now that the Road Safety Act is on the statute book, the Ministry, manufacturers and operators can go ahead with plans for the intended introduction of a type-approval scheme for new vehicles, which is due to commence in the early 1970s; all the details will be embodied in regulations during the next few years. Prototypes of new vehicles will be approved by the MoT and it will be an offence to sell or operate a vehicle which does not conform.
Type approval is no direct concern to operators—it is mainly a manufacturing matter. But a close watch must be kept on the Ministry's plans for the notification of operators' modifications to type approved vehicles, for the industry must not allow itself to be placed in the position where relatively minor as well as perhaps major alterations are subject to the Ministry's prior approval. In the opinion of the TRTA notifications must be kept down to the absolute minimum. Type approval should be used to ensure satisfactory constructional standards, but not as a means of fettering operators' freedom and judgment—the various use regulations are adequate to ensure safe operation when properly enforced.
Conclusion
Dealing with each item as a self-contained entity facilitates ease of presentation, but to an extent gives a misleading picture. In practice aspects of the new legislation, particularly brakes and plating, are closely related. Operators must approach their planning programmes for the next few years with an all-embracing review of the whole subject. Decisions on the choice of brake conversion kits might be influenced by possibilities in plating, and the extra cost of an immediate conversion to the final 1972-73 standards might be recouped many times if such action facilitates a plating up-rating. Similarly, any contemplated conversions must be viewed against the vehicle's chances of getting through the annual test. Money invested in improving one component will obviously fail to produce the required return if the vehicle's life is to be prematurely shortened through failure to meet the overall standards demanded in testing.
The cost of the whole exercise must also be carefully considered for there cannot be any doubt that these new proposals will be expensive. It has recently been calculated that the overall cost to the industry will be £15m. to £30m. and there is no evidence to show that this is far off the mark. With road safety in view the costs are likely to be accepted without demur but the impact will have to be paid for by the whole community in generally increased road transport pricing.