A major flaw in the draft amendments to the Road Vehicle Standards Act has been revealed which will need to be corrected before the legislation is presented to Parliament.
HVIA’s Policy and Government Relations Manager Greg Forbes said that the industry consultation process has caught the key issue which, if it went through, would create gaps between ADR’s and the VSB6 for body builders.
“The amendments changed the definition of the time of supply to market, and the legislation requires all changes to a vehicle prior to supply to market to be done through the second stage manufacturing (SSM) process or through model reports,” Mr Forbes said.
“This would essentially force body builders and other companies using VSB6 to modify vehicles into the SSM process, or have to submit a model report for every body/truck combination.
“The changes are clearly unworkable and we will ask for this to be changed as part of HVIA’s response to the draft legislation.”
Mr Forbes explained that the technical requirements of VSB6 relating to typical modifications carried out prior to first registration, such as body fitment, chassis extension/shortening and addition of a lazy axle do not exist in the ADR’s.
“The SSM process only requires demonstration of compliance to ADR’s and a quality assured manufacturing process.
“A simple body and chassis fit, for example, would not require an assessment by a third party of how the body is fitted nor the chassis alteration once SSM has been approved.
“Further, the SSM procedure is primarily intended where a significant number of vehicles are constructed in the same way. That is, the same modification is done on the same truck make and model.
“It is not intended for example, where the same body is fitted to several different truck makes and models. ”
“The SSM process would impose a significant administration burden on an average bodybuilder, or suspension and chassis modification business, and all with a lower safety outcome than the current arrangement.
“There is nothing in the ADR’s covering VSB6 modifications and legally, under an SSM process would not require the modifications to comply with VSB6 requirements.”
“Comments from industry attendees at the DIRDC public information session in Brisbane this week, indicated that there are already issues in relation to body fits and chassis alterations done overseas under the SSM scheme that do not comply with VSB6.”
HVIA has previously highlighted the incongruence of the second stage manufacturing process with VSB6, over two years ago where trucks had been imported and certified through the RAWS scheme did not meet key VSB6 requirements for body fit and lifting systems.
While the NHVR manages VSB6, it has no jurisdiction over modifications done under second stage manufacturing.
“Legally, the enforcement of VSB6 requirements when the vehicle has an SSM plate after first registration is very difficult,” Mr Forbes said.
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