HVIA is seeking feedback from members on the ADR ‘alternative standards’ omnibus instrument prepared by the Federal Department of Infrastructure.
In late September the Department advised HVIA via the Vehicle Standards Consultative Forum (VSCF) that it had prepared a draft omnibus instrument to recognise a series of United Nations (UN) regulations as alternative standards for seven ADRs.
An omnibus instrument is a legislative tool that addresses multiple matters by combining them into one cohesive document, as a series of amendments, repeals, or new provisions. Omnibus instruments are occasionally used by the Department to group together a series of minor, and sometimes unrelated, regulatory changes.
In this instance, the omnibus instrument updates the acceptable alternative standards for the following ADRs:
> ADR 3/04 Seats and Seat Anchorages
> ADR 4/06 Seatbelts
> ADR 5/06 Anchorages for Seatbelts
> ADR 14/03 Devices for Indirect Vision (pay attention)
> ADR 18/03 Instrumentation
> ADR 92/00 External Projections
> ADR 93/00 Forward Field of View
Each of these ADRs are applicable to category N heavy vehicles in some way, however the primary focus of these ADRs is on rigid trucks and prime movers.
HVIA understands that the changes will not increase the stringency of the amended ADRs and there will be negligible change in the regulatory burden, although the Department is yet to conduct an impacts analysis. The Department has explained that:
> The amendments will provide equivalent or better safety outcomes to the series of amendments already accepted in each ADR;
> Most of the changes between series of amendments are minor; and
> The existing series of amendments to the UN Regulations accepted as alternative standards to the ADRs will be maintained as acceptable alternative standards, to avoid any regulatory impact for vehicles already certified to these ADRs.
Members wishing to understand the detail on any of the proposed changes to any of the listed ADRs are invited to contact HVIA Chief Technical Officer Adam Ritzinger at a.ritzinger@hvia.asn.au, who will provide the Department’s draft explanatory statement for confidential review.