Information Note. Roadworthiness testing requirements for Mobile Machines
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1 October 2010 Information Note Roadworthiness testing requirements for Mobile Machines Dear Mobile Machine registered owner, Following the introduction of penalty point offences on 1st May 2009 for using a vehicle in a public place without a Certificate of Roadworthiness, a number of Mobile Machine owners sought clarification from the RSA regarding the roadworthiness testing requirements for Mobile Machines. We are writing to you now to clarify the roadworthiness testing requirements. Every owner and driver is obliged to ensure that their vehicle is roadworthy and in compliance with Road Traffic Law. All vehicles degrade in service over time and it is key to road safety that vehicle defects are identified and remedied to ensure that the roadworthiness of a vehicle is not compromised. Roadworthiness testing is a preventative measure which helps ensure that vehicles using our roads are in sound working order. It is a mandatory requirement throughout the EU and is governed by EC Directive 2009/40/EC which sets out the requirements for the roadworthiness testing of motor vehicles and their trailers and which exempts from such testing only those vehicles that are owned by the armed forces, police and fire services. Regrettably, many vehicle owners do not adequately maintain their vehicles so significant numbers of defective vehicles are in use which is a matter of concern to the Road Safety Authority as poor vehicle condition has an adverse effect on safety and the environment. The term Mobile Machine is derived from the taxation class of the vehicles. The Vehicle Testing Regulations 1 require any vehicle which is constructed or adapted primarily for the conveyance of goods or burden of any description to undergo a roadworthiness test annually. This clearly already applies to vehicles such as Mobile Shops, Concrete Mixers and Curtain Siders. The RSA is aware that differing practices have been adopted in various local authorities for some of the other vehicles classified as Mobile Machines which are constructed on a goods vehicle chassis, but, which do not necessarily carry a burden. Following assessment of the existing Regulations, the RSA intends to recommend to the Minister for Transport that the Vehicle Testing Regulations 1 be amended to explicitly include the types of vehicle that are listed in Table 1 below as being categories of vehicles that are required to undergo annual roadworthiness testing, thereby clarifying the legal position for the owners of such vehicles. 1 The European Communities (Vehicle Testing) Regulations 2004; (S.I. No. 771 of 2004) 1
2 Vehicle Type Compressor Concrete Pump Drain Cleaner Hoist/Crane Road Gritter/Chip Spreader Road Maintenance Vehicle Road Tar Sprayer Travelling Machine/Workshop Watering/Sweeping Machine Well Driller/Drilling Machine Table 1 The majority of the vehicles listed in Table 1 are built on a goods vehicle chassis, the test requirements of which are the same as those that apply to goods vehicles already tested at the Vehicle Testing Network. The majority of vehicles listed in Table 1 also have a Design Gross Vehicle Weight (DGVW 2 ) exceeding 3,500kg and will be tested in accordance with the requirements of the Heavy Goods Vehicle (HGV) Test Manual (the HGV Manual ). A summary of the individual items that must undergo testing on a HGV is outlined in Appendix 1. The RSA is aware that some oversize vehicles may have difficulties with certain aspects of the roadworthiness test because of their size. Details of potentially oversize vehicles are included in Appendix 2. In a limited number of cases it may not be possible to perform all tests mandated in the HGV Manual, such as testing the suspension, steering play and alignment, wheel bearings, brake performance using the roller brake tester, and carrying out the chassis under-body inspection. The RSA will be putting in place specific arrangements to cater for such vehicles. If your vehicle is oversize you should book it in for the test in the normal way; however you will need to notify the test centre that it is oversize if you think that it will have difficulty undergoing all aspects of the test. The test centre will then confirm to you whether they can test your vehicle and if necessary will consult with the Local Authority Authorised Officer for Vehicle Testing and the RSA. In some instances, depending on the vehicle type, a vehicle may be inspected by an RSA or Local Authority Authorised Officer prior to a test being carried out in order to ascertain the optimum testing arrangement. 2 DGVW (Design Gross Vehicle Weight) means the gross weight of a vehicle laden with the heaviest load which it can reasonably carry having regard to the engine, brakes, tyres and general construction of such vehicle and shall, until the contrary is shown, be taken to be its design gross weight as specified by its manufacturer or, where the design gross weight as specified by the manufacturer is not ascertainable, the design gross weight as specified by an automotive engineer. 2
3 There will be no changes to fees and the existing test fee structure (as set out in Appendix 3) will apply to all such Mobile Machines. The RSA website contains further information on the HGV test, tachograph requirements and issues generally relevant to commercial vehicle and driving standards which may be helpful. We would welcome any comments you may have and in particular if you believe that your vehicle may have difficulty completing certain aspects of the test or if you have any comments or queries on the proposed changes to the Vehicle Testing Regulations to explicitly apply to the vehicles listed in Table 1 above. Please contact us on from 9.00 a.m. to 5.30 p.m. Monday to Friday or by at vehiclestandards@rsa.ie before 26th November Yours sincerely, Vehicle Standards, Road Safety Authority, Moy Valley Business Park, Primrose Hill, Ballina, Co. Mayo 3
4 Appendix 1 Test Items As outlined in the Vehicle Testing Regulations, these items will be checked on all Mobile Machines with a DGVW exceeding 3,500kg in so far as is practicable. 1. Braking systems Note that the brake performance will be tested using a decelerometer in the case of an oversize vehicle 1.1 Service brake Mechanical condition Efficiency Balance Vacuum pump and compressor systems. 1.2 Secondary brake Mechanical condition Efficiency Balance. 1.3 Parking brake Mechanical condition Efficiency Balance. 1.4 Additional components for trailers/semi-trailer Brake away brake. 2. Steering and Steering Wheel. 2.1 Mechanical condition. 2.2 Steering wheel. 2.3 Steering play. 3. Visibility. 3.1 Field of vision. 3.2 Condition of glass. 3.3 Specification of glass. 3.4 Rear view mirrors. 3.5 Windscreen washers/wipers. 4. Lamps, Reflectors and Electrical Equipment. 4.1 Main and dipped-beam headlamps Condition and operation Alignment Switches Visual efficiency. 4.2 Side lamps and marker lamps Condition and operation Colour and visual efficiency. 4
5 4.3 Stop lamps Condition and operation Colour and visual efficiency. 4.4 Direction-indicator lamps Condition and operation Colour and visual efficiency Switch Flashing frequency. 4.5 Rear/registration plate lamps. 4.6 Reflex reflectors and rear and side markings condition and colour. 4.7 Electrical connections between tractor vehicle and trailer or semi-trailer. 4.8 Electrical wiring. 4.9 Tell tales. 5. Axles, Wheels, Tyres, Suspension. 5.1 Axles. 5.2 Wheels and tyres. 5.3 Suspension. 6. Chassis and Chassis Attachments. 6.1 Chassis or frame and attachments General condition Exhaust pipes and silencers Fuel tank and pipes Spare wheel carrier Transmission condition Coupling mechanism on tractor vehicles, trailers and semi-trailers. 6.2 Cab and bodywork General condition Mounting Doors and locks Floor Driver's seat Running boards. 7. Other equipment. 7.1 Safety belt. 7.2 Locks and anti-theft devices. 7.3 Warning triangle. 7.4 Wheel chock(s) (trailers). 7.5 Audible warning device. 7.6 Speedometer. 7.7 Speed limiter device (For vehicles capable of exceeding 90 km/hr) 7.8 Tachograph 7.9 Sideguards. 5
6 7.10 Rear underrun protective device. 8. Nuisance 8.1 Noise. 8.2 Exhaust. 8.3 Suppression of radio interference. 9. Exhaust emissions. 10. Vehicle identification Registration number plate Chassis number Vehicle weights and dimensions plate. 6
7 Appendix 2 - Characteristics of Oversize Vehicles For vehicle testing purposes, oversize vehicles, including trailers forming part of a vehicle combination may have the following characteristics. 1. They have a Design Gross Vehicle Weight (DGVW) exceeding 44 tonnes. 2. They exceed 4.8 metres in height with all equipment stowed in the transport position. 3. They exceed 2.6 metres in width. 4. One or more of the individual axles fitted to the vehicle has a DGVW exceeding 15 tonnes. 5. They are fitted with wheels with a diameter exceeding 1600 mm. Vehicles with some or all of these characteristics will have difficulty undergoing aspects of the roadworthiness test and hence additional arrangements will be put in place to accommodate them. Difficulties may be encountered when testing some of the items listed in Table 2 below. This list is not exhaustive and may include additional items depending on the design of the vehicle undergoing the test. Test Item Mirrors Wheels Steering Service / Secondary / Parking Brake Brake wheel units / mechanical brake components / brake lines / hoses Chassis/Under-body Exhaust System Front & Rear Springs / Suspension Shock Absorber Condition Transmission / Engine / Final Drive Headlight Aim Table 2 Difficulty Encountered Difficulty checking field of vision Difficulty checking wheel bearings Difficulty checking steering alignment & linkage Difficulty checking brake performance & imbalance Difficulty checking the operation & condition of these components Difficulty checking for corrosion or damage Difficulty checking for corrosion or damage Difficulty checking the condition of these components Difficulty checking the condition of these components Difficulty checking for leaks, wear or damage Difficulty checking the headlamp aim where the vehicle cannot be positioned in front of the headlight tester. 7
8 Appendix 3 Test Fees Test fees for Mobile Machines based on DGVW (Design Gross Vehicle Weight) and number of axles. Fees are in alignment with the European Communities (Vehicle Testing) (Amendment) Regulations Vehicle DGVW 3.5 tonnes or less 3.5 to 7.5 tonnes 7.5 tonnes or greater with 2 axles 7.5 tonnes or greater with 3 axles 7.5 tonnes or greater with 4 or more axles Test Fee (exclusive of vat) Retest Fee (exclusive of vat) Certificate of Roadworthiness Fee 4 Replacement Certificate of Roadworthiness Fee Table 3 3 The European Communities (Vehicle Testing) (Amendment) Regulations; S.I. No. 709 of A Certificate of Roadworthiness (CRW) can only be obtained from Local Authority Motor Tax offices on presentation of a Pass Statement from an authorised Commercial Vehicle Test Centre. 8
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