Directive action 06 October 2011
Changes to the Testing Directive will come into force at the beginning of 2012, affecting the testing of brakes, steering, suspension and a range of other vehicle and trailer components. John Challen gets the lowdown from VOSA's Andy Cattell
An amendment to Annex II to Directive 2009/40/EC has led to the introduction of Commission Directive 2010/48/EU, commonly referred to as the Testing Directive, set to be implemented from 1 January 2012. To facilitate the required changes, VOSA (the Vehicle and Operator Services Agency) has been liaising with the Department for Transport and the European Commission, establishing the extent of changes necessary, and how to implement them with minimal impact, in terms of testing times, test fees and new equipment necessary.
"The EU has built on the previous [vehicle testing] concept, and also the fact that modern vehicles have lots of electronic functions that are not included, which they think should be," says Andy Cattell, VOSA's vehicle standards manager. "Hence the introduction of 2010/48."
Designed to harmonise testing by including these electric control systems, the path to introducing the directive has not been completely straightforward. "At the beginning, we thought that everything in the directive applied to every class of vehicle. However, that is not correct, because, for example, air brakes don't apply to cars, and fluid braking systems don't really apply to trucks," explains Cattell. "This meant we had to look carefully at the directive and see what applies to trucks and to cars, and then make sure that each scheme has one of those test items covered."
VOSA has now identified the areas of vehicle testing subject to the biggest changes, and introduced guidance on the agency's website. The following is a summary of what operators and technicians should be looking out for, from the New Year.
First, a check has been added to the service brake, as well as additional guidance where electronic braking systems have been fitted to a vehicle. However, Cattell maintains that operators will not be required to carry out enhanced checks beyond those normally performed in relation to ABS. The check will be to make sure that the EBS malfunction indicator lamp (MIL) operates correctly where possible and that an ISO 7638 unit is fitted when required. Operators will now also find an additional reference in the directive concerning correct brake pivot movement in relation to mechanical operation of the lever.
Another significant change being introduced to brake testing concerns in the area of systems and components. Test items relating to brake cable guides and brake fluid levels have been added, the latter only being relevant where they are visible without removing the reservoir cap. Brake fluid level warning lights, where fitted inside the cab, also need to be checked, in line with the new test conditions.
Additionally, operators will also have to meet requirements relating to correct fitment of load sensing valve data plates. But this check will be not be carried out on vehicles and trailers until 2013 and 2014 respectively, the only exception being on PSVs. Vehicles in that category, registered after 29 October 2011, and therefore subject to Whole Vehicle Type Approval, will be affected.
"We plan to make one fundamental change to the way we test brakes, which will be later than the implementation date, if we see issues in relation to equipment requirements," warns Cattell. "We currently test performance values in relation to the design gross vehicle weight, but we plan to test brakes to the EU Classification known as maximum authorised mass [MAM]." The VOSA man assures us that operators will be kept informed of developments in this area.
Steering and suspension
There are two main changes for suspension inspections – the first relating to the inspection and identification of dust cover failures. Those fitted to suspension components, to prevent the ingress of dirt, will be inspected as part of the new test procedure.
The second change only relates to air/fluid suspension systems. Essentially, a method of inspection and reason for rejection has been added, to prevent the modification of suspensions where it affects the system function.
Meanwhile, electronic power steering is at the core of proposed changes to the directive's attention to steering. However, Cattell maintains that this alteration is more about future-proofing the industry against design changes, rather than requiring action now. "Air and fluid powered steering systems have been used in large vehicle schemes for many years and we do not expect many test sites will see electronic power steering systems, except perhaps those fitted to light commercial vehicles," he explains.
That said, an additional check has been included in relation to the hydraulic fluid content level. But this inspection only applies to reservoirs that can be checked without removing the reservoir cap. And finally, power steering cables, hoses and the electronic power steering malfunction indicator light all become testable items under the new rules.
Cattell says that the introduction of conspicuity marking and rear and side marking is one of the most complex changes reflected in the Testing Directive. The first stage of the legislation is in place now, as goods vehicles with a gvw exceeding 7,500kg and trailers exceeding 3,500kg gvw were required to be fitted with conspicuity markings from 10 July 2011.
In general, full contour marking on the vehicle's rear is required and partial contour marking on the sides, but in testing, consideration will be given to where the vehicle shape, structure, design or operational requirements make it impossible to fully comply.
A slight reprieve
Although the New Year is just a few short months away, Cattell says operators do have a little more time to comply. "The directive mandates that tests be in place by 1 January 2012, and we'll have our manuals available online and be testing by then," he confirms. "But we won't be failing vehicles right away, because we have managed to secure a three-month familiarisation period. What we don't want is brakes suddenly generating a failure rate of 16%, compared with the current 2%, for example," he explains.
For more information on the changes please visit www.dft.gov.uk/vosa/publications/manualsandguides/vehicletestingmanualsandguides.htm and look for the technical pen picture documents.
Check your number
Aside from the main areas featured in the article, Directive 2009/40/EC has been amended with the addition of tests to a number of other items found specifically on commercial vehicles.
Registration plates: check that front and rear plates are present, secure, legible and match with the vehicle record documents.
Seat belts and restraint systems: added to reflect the growing number of airbags on vehicles, as well as seat-belt pre-tensioners and load limiters.
Seats: Front passenger seat becomes a testable item.
Mirrors and indirect vision devices: added to accommodate devices that, in some cases, replace traditional vehicle mirrors.
Speedometer/tachograph: a check will be required to make sure the tyre sizes comply with the calibration plaque.
Electrical wiring and equipment: addition of security and condition of trailer electrical sockets. Checks will need to be visual, rather than functional, as powered vehicles may not be presented with a trailer.
Fuel tanks and system: a leak detection spray will be used to confirm a leak is present on LPG-powered vehicles.
Transmission: the directive mandates a test item in connection with transmission joints. This item should be considered in the context of the ability to retain a lubricating medium and prevent the ingress of dirt into the lubricant.
Driver & Vehicle Standards Agency (DVSA)
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