Play by the rules07 January 2011

Changes to testing and regulations could leave some operators at a loss to know what is required and why. John Kendall outlines what's new, and which vehicles will be affected

New O-licence holders in possession of a shiny new CPC, must feel that they have a pretty good grasp of all they must do and not do to run a fleet of trucks or buses. However, there is still uncertainty in some quarters, with many requiring clarification.

Fortunately, vehicle inspection and testing requirements are fairly straightforward, and aided by VOSA, which produces several helpful guides to assist all operators to comply with the law. One of them, 'Commercial Vehicle Tests: the basics', gives a broad view of what needs to be tested, and when.

Fundamental to the programme of vehicle testing is the annual test. Where buses, minibuses and coaches are concerned, the guide lists three main criteria. First, all buses with more than eight passenger seats used for hire and reward need a class VI MOT. Then, buses not used for hire and reward that have up to 12 passenger seats require a class IV test. Finally, vehicles with more than 12 passenger seats must have a class V test.

Class VI testing needs to be carried out at a VOSA test site, ATF (Authorised Testing Facility) or DP (Designated Premises). Five key vehicle types fall under this umbrella: vehicles with a gross weight of more than 3,500kg; all units forming part of an articulated vehicle; semi-trailers; converter dollies (a fifth wheel mounted on single or double axle for coupling a semi-trailer); and trailers with an unladen weight of more than 1,020kg.

Beyond the basics

But all this is just the tip of the testing framework. In addition, a number of other tests may be required, depending on the vehicle. Most of these are specialist, including the Certificate of Initial Fitness (COIF) that all buses and coaches must undergo before they can be used on the road, and TIR (Transports Internationaux Routiers) that permits vehicles to carry goods outside the EU without customs inspections, vehicle weight re-plating, seat belt checks and disability access tests (for buses and coaches).

Other tests include those for environmental vehicle taxes, such as the RPC (reduced pollution certificate), where an aftermarket device, such as a particulate trap, may qualify a vehicle and hence reduce its vehicle tax rate. VOSA can also conduct testing on vehicles submitted voluntarily, to check, for example, brake performance, headlamp alignment and smoke emissions.

Against this background, it falls to VOSA to implement any new legislation that has an impact on testing. Some of this is phased in over a period of time, and most relevant for today's transport operators are those planned for 2011 and 2012.

The big deal here is Whole Vehicle Type Approval, which started in 2009 and is being phased in until 2014, depending on vehicle type. The system is designed to improve consistency of build quality for vehicles and bodywork across the EU. Until October 2010, the system was voluntary, but 29 October marked the introduction of the first mandatory stage. From that date, all new minibuses, buses and coaches built in a single stage, or the first stage of a multi-stage building process, have had to be type approved.

Three approval methods exist, selected according to the vehicles' intended use – and these may have particular relevance for buyers of second-hand vehicles, because two are national schemes aimed at smaller production vehicles. The point is that, if a vehicle is exported to another EU country, with only national type approval, it may need approval again before it can be used there. This could, for example, affect trailers – particularly specialist units built in small quantities.

WVTA 2011

The next stage is due to be implemented this year, from 29 October. This will apply the whole vehicle type approval system to multiple build stages for new minibuses, buses and coaches, effectively completing the process begun last year. From that date, WVTA will also be applied to the single stage build process for light vans and trucks. This will have relatively little impact on volume-produced vehicles but, for the reasons given above, may affect small production run vans and trucks, or chassis cabs with specialist bodywork.

Meanwhile, from February this year it will be mandatory for new cars and small vans to be fitted with daytime running lamps (DRLs). The proposal will then be implemented for all other vehicle categories, including trucks and buses, from August 2012. The lamps must light up when the ignition switch is in a position where it can start the engine, but the legislation will not be retrospective. Similarly, there will not be a requirement for vehicles without DRLs to drive with headlamps lit, except when the law already requires it.

Where testing is concerned, a vehicle that requires DRLs must be fitted with them and they must be working for the vehicle to pass MOT or VOSA testing. It's also worth noting that the legislation only requires DRLs to be fitted at the front, so tail lamps are not lit when they are in use.

Be safe, be seen

What about conspicuity markings? That legal requirement comes into force from July this year, the result of an EU regulation affecting all member states. The legislation will apply to all newly registered goods vehicles exceeding 7,500kg gvw and trailers of more than 3,500kg operating in the UK. Highly reflective material between 50mm and 60mm wide must be applied to the sides and rear of these vehicles. The intention is that they become visible from up to 1,000m in the dark – around eight seconds earlier than presently for drivers of approaching vehicles.

If the rear of the vehicle is wider than 2,100mm, which will be the case for most heavy trucks, it must be marked with a contour line, presenting a box-shaped outline. Red is the DfT's (Department of Transport) preferred colour, although yellow is also permissible. The ruling is that the markings should be as close to the edge of the vehicle as possible. Then, for the sides, the DfT preferred colour is yellow, although white is also allowed. The reflective material must be applied to both cab and body sides. For the body, there are two options: either a partial or a complete contour line.

A partial line is the minimum, involving a strip of reflective material between 250mm and 1,500mm from the ground, along the lower edge of the bodywork. A maximum height of 2,100mm may be permissible if it is not possible to fit the material any lower. For a partial contour, the upper corners of the body must be marked, viewed side on, with material not less than 250mm in length. This must be fitted within 400mm of the top.

Regulations dictate that the markings should cover at least 80% of the length of the vehicle, excluding the cab, or, for trailers, the length of the vehicle excluding the drawbar. If the type approval authorities can be satisfied that covering 80% of the length is impossible, the cumulative length required may be reduced to 60%.

Two final points: first, for those concerned about roadside checks, further regulations – again the result of European legislation – have been expected for some time. However, VOSA assures us these will not be implemented until January next year at the earliest. Second, reform of Operator licensing in Northern Ireland – due to bring that country's O licensing into line with the rest of the UK – is also ongoing. As we go to press, it remains unclear when this might be implemented.

Author
John Kendall

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