HVIA has called for amendments to the National Heavy Vehicle Regulator’s proposed changes to the requirements for the Performance Based Standards (PBS) Directional Stability Under Braking (DSUB) standard.
The consultation period on the revised requirements is now closed. HVIA was very encouraged by the strong interest and engagement from members on the topic, and collated the diverse set of views on technical and administrative matters into a concise submission that was sent to the NHVR on Friday last week.
The submission is available for download here.
Chief Technical Officer Adam Ritzinger says overall, HVIA supports the NHVR’s proposal as outlined in the consultation paper, with relatively few exceptions on technical matters.
One example is that HVIA recommends that the limitations of the current ISO 11992 standard be acknowledged by the NHVR, and alternative compliance pathways be offered for very long vehicle combinations, should a compliant braking system be unavailable, or unfeasible to fit.
Another is trailer status indicators – HVIA calls on the NHVR to retain the requirement for status indicators, but remove the ADR compliance condition, in recognition of the current, ongoing work between industry stakeholders and the Federal Department that oversees the ADR package that seeks to formalise the regulatory pathway for those status indicators.
HVIA also warns of a potential ‘rush’ of PBS approvals or requests towards the end of the transition period and encourages the NHVR to publicise the changes widely and often.
“HVIA also anticipates some difficulties and confusion within industry operators during the implementation, due to the complexity of the arrangements for managing existing PBS combinations. Those difficulties may be exacerbated by the need to identify the level of braking systems fitted to trucks and trailers, and which version of the relevant ADRs they comply with,” he adds.
“To that end, HVIA strongly encourages the NHVR to provide as much notice and information as possible to impacted industry stakeholders and operators, to facilitate a smooth transition.”
Ritzinger notes that heavy vehicle advanced brake technology is very complex to start with, “but once you overlay the PBS scheme’s intricacies, and interactions with other regulatory instruments like the Australian Design Rules, it’s about as difficult as it gets”.
“Working with HVIA’s members on complex regulatory and technical matters such as those covered in the DSUB review is one of the best parts of my role.
“HVIA is very lucky to have input from an experienced and dedicated group of brake and regulatory professionals that provided specific insights to guide this submission, and I’m thankful for that.
“I’d also like to call out the NHVR’s review team, who were proactive during the consultation, accommodated requests for extensions, and took the time to facilitate genuine two-way discussions with industry.”