The National Heavy Vehicle Regulator has created a new Vehicle Standards Guide, VSG38, in a bid to address an inconsistency between the recently updated Heavy Vehicle National Law and existing Australian Design Rules.
Throughout the second half of this year, HVIA has kept members informed on confusing interactions and inconsistencies between the recently updated HVNL and existing ADRs.
One of those interactions stems from the hard limit on the trailer S-dimension of 9.5 metres in ADR 43/04 (Vehicle Configuration and Dimensions). HVIA members reasonably asked how trailers can comply with that ADR requirement but also take advantage of the new HVNL allowance for trailer S-dimension to exceed 9.5 metres for 20-metre semi-trailers.
HVIA’s technical and advocacy team engaged with the NHVR and the owners of the ADR regulatory package, the Federal Department of Infrastructure. The Department was unwilling to change the ADR and explained a workaround utilising the ‘substantially comply’ ADR approval pathway.
At the most-recent Vehicle Standards Consultation Forum (VSCF) in Canberra, HVIA formally called on the Department to resolve the issue but was advised that the confusing interaction would remain.
At the same time, HVIA was advised that the NHVR had created a new Vehicle Standards Guide, VSG38, which directly addresses the issue. The guide is available online here.
The guide acknowledges that certain dimension limits in ADR 43/04 no longer align with the same limits under the HVNL’s Mass and Dimension Regulation. Those limits are rear overhang, S-dimension and distance from point of articulation to rear of trailer.
The guide outlines two compliance pathways, one for newly manufactured trailers, and one for modifications done to an in-service trailer.
HVIA members impacted by the changes are encouraged to read the guide in its entirety as the conditions and processes differ. All questions can be directed to HVIA’s Chief Technical Officer, Adam Ritzinger.
Ritzinger supports the NHVR’s release of the guide, but laments the fact that it was needed at all. “Regulations should not be in conflict. That is a fundamental requirement of a functional legislative framework,” he says.
“The guide is undoubtedly helpful but cannot guarantee that all future confusion and subsequent productivity loss will be avoided. However, amending the ADR would,” he adds.
“HVIA will continue to call for future HVNL changes to yield a simpler law that is easier for industry to comply with, devoid of pitfalls and traps.”