DOE for campers

niloc1951

[Modedit: name removed] AKA Billy Bunting was quite active on this thread during the summer but has gone quiet since the end of July.
AFAIK Bill is/was President of The Motorcaravan Club. Perhaps he might give us an update of how his club is getting on regarding the issue.

Perhaps Bill and any officers of the other clubs might get their members involved in a campaign of requesting the EU Vehicle Category on their Reg. Certs corrected from N1 to M. for reasons stated in previous posts.



[and another modedit: I'm sure Billy Bunting would like to inform us himself (or not as may be the case) what his real name is and what he is or isn't president of]

peasant

Right, I've also requested to be sent that document and to be included into the consultation process.
Not just as a private person, but also as a mod of this forum.

If the RSA is willing to talk to me (and us), I will open another thread for the particular discussion of this document so that we owners/users can speak with one voice and perhaps prevent some silly measures that other groups might have in mind from making it into the test procedure.

niloc1951

Good Idea peasant and don't forget to let them know the number of posts and views on the subject, it will give them an idea of the level of activity, on this forum alone, the issue has created.

Irishgoatman

Nice one peasant.
The RSA have shown that they are prepared to talk, and hopefully listen, to us individually so lets hope that they will listen to us collectively.
I'm sure that everyone on this thread will be with you on this.

Malta1

Just been in contact with the RSA and they have indicated that they will include me as a stakeholder for circulation of the Public Consultation Document for campervan vehicle testing.
Suggest more contact them and get on the list

Also been on to the VRU in Shannon......looks like they are not going to replace all vehicle reg certs automatically. I have been asked to return mine with a covering letter to organise the amendment

gbl666

Hi all have been reading with interest all that has been said. I have contacted Shannon first via email then phone. It appeared that by phone I was going to be passed to my local tax office the helpful lady I spoke to did not have a clue about the categories. I insisted that they were the people to help and after much asking I was told I would be contacted by a supervisor. I await. I then got an email requesting I sent my registration doc to them for amendment possibly by the same lady who dealt with the others. The reg doc will be sent this afternoon.
I always ensure that any vehicle I drive is road worthy and safe so having a vehicle test on my camper is no upset. However I do not want it compared to a comercial vehicle and treated as such due to negligence of the authorities.

niloc1951

Just got an email from Tom McHale of the RSA this morning. The email included the following "The consultation document on roadworthiness testing of motor caravans is nearing completion and I expect that it will be published in the next few weeks." so hopefully it will be sorted satisfactorily and in line with best practice elsewhere sometime soon.

gbl666

Received my tax renewal so had a go at renewing online. Appears I can do it with no mention of a DOE or nct test???

niloc1951

gbl666 wrote: »

Received my tax renewal so had a go at renewing online. Appears I can do it with no mention of a DOE or nct test???

This is another example of the confused state regarding 'motor caravans'
The Motor Tax office say a valid NCT cert is not required to be produced - as per 'cars'.
However for a 'commercial vehicle' a 'DoE Pass Statement' is required.
Therefore according to the Motor Tax office 'motor caravans' are not a category of vehicle that are required to undergo and pass a DoE test. :rolleyes:

peasant

niloc1951 wrote: »

Therefore according to the Motor Tax office 'motor caravans' are not a category of vehicle that are required to undergo and pass a DoE test. :rolleyes:

Yes!

And for heavens sake, whatever you do ...don't anyone start writing to them about that as well

Last thing we all need now is not being able to tax our vans until this mess is sorted ...leave well enough alone.

niloc1951

Recently I have had a conversation with a member of An Garda Síochána Traffic Division who is familiar with the issue being discussed here, he also indicated the matter will be mentioned at an upcoming meeting with the RSA.
He is of the opinion that in the current confused circumstances a prosecution under either of the S.I's., covering vehicle roadworthiness testing would be unlikely to succeed in court and would not be expected to be taken by a member of the force in the first instance.
Obviously the opinion expressed was purely a personal one and not in any way official.
The member did indicate however that there is plenty of existing legislation available to deal with vehicles found on the road in an unroadworthy condition which could also include dangerous driving charges against the driver.

vinniem

Got my cert back from Shannon last week, now says M1 and not M...is this OK?

niloc1951

vinniem wrote: »

Got my cert back from Shannon last week, now says M1 and not M...is this OK?

Category M1: Vehicles designed and constructed for the carriage of passengers and comprising no more than eight seats in addition to the driver's seat.
"Special purpose vehicle" means a vehicle of category M, N or O for conveying passengers or goods and for performing a special function for which special body arrangements and/or equipment are necessary.
"Motor caravan" means a special purpose M category vehicle constructed to include living accommodation which contains at least the following equipment:- seats and table,- sleeping accommodation which may be converted from the seats,- cooking facilities, and- storage facilities.This equipment shall be rigidly fixed to the living compartment; however, the table may be designed to be easily removable.
See http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001L0116:EN:NOT for full document.

My certificate says 'M'.
M1 would be a car, mpv, suv, etc., basically a vehicle 'designed and constructed' for carrying no more than eight passengers passengers, a 'motor caravan' is not a category M1 vehicle.

Is your certificate OK, well it probably doesn't matter on this ould isle, not a lot does it seems, but it could be the source of problems if police or other authorities in a foreign land have reason to be interested in your documentation.

vinniem

Thanks Niloc :) When I sent my cert I specifically wrote telling them to change from N1 to M as per this thread...what's this department like?
They cant even follow simple instructions!! Although the cert does now have Motor-caravan on it and make model which the last cert did not. Suppose will have to send off to them again in the new year. Thanks again.

niloc1951

vinniem wrote: »

Thanks Niloc :) When I sent my cert I specifically wrote telling them to change from N1 to M as per this thread...what's this department like?
They cant even follow simple instructions!! Although the cert does now have Motor-caravan on it and make model which the last cert did not. Suppose will have to send off to them again in the new year. Thanks again.

Interestingly, category M1 is the official EU description of the type of vehicle described in the enabling legislation here for the NCT. Therefore if 'officialdom' is categorising your 'motor caravan' as M1 it should be accepted by the NCT service for testing (as it should be in the first instance if the relevant authorities had their act together)

vinniem

Once again thanks Niloc for your reply. What would you recommend then, get the cert changed to M or leave as M1?

niloc1951

Recent feedback from the RSA indicates that the consultation document mentioned in previous posts should be circulated to stakeholders by the end of February 2010.

niloc1951

As of Monday 01/03/2010 the RSA is implementing a New Testers Manual for HGV's for use at all test centres.
In its pre-amble the document specifically lists Vehicle Types M2, M3, Special Purpose M (Ambulance), N2, N3, O3, and O4 as the types of vehicle which are to be tested under its auspices.
Special Purpose M (Motor Caravan) is not included, therefore as of 01/03/2010 motor caravans are, without question, not subject to testing under the auspices of the RSA HGV test manual.
It is interesting that the RSA have chosen to include 'Ambulances' under the HGV manual and not test them as Category 4 (the same category as Taxis) as set out in DIRECTIVE 2009/40/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 6 May 2009 .
Lets hope that when they conclude their deliberations on how 'Motor Caravans' are to be tested they follow what is set out in the Directive and require them to be tested to specifications applicable to Category 6, as is the requirement elsewhere.

For the record, I have ask for and been refused a roadworthiness test for my motor caravan by both the NCT central reservations office and a number Light Goods Vehicle test centres, all were quite adamant they were not authorised to test such a vehicle.

PS. We had been promised the 'discussion document' by end of February but no sign yet :rolleyes:

Irishgoatman

niloc1951 wrote: »

As of Monday 01/03/2010 the RSA is implementing a New Testers Manual for HGV's for use at all test centres.
In its pre-amble the document specifically lists Vehicle Types M2, M3, Special Purpose M (Ambulance), N2, N3, O3, and O4 as the types of vehicle which are to be tested under its auspices.
Special Purpose M (Motor Caravan) is not included, therefore as of 01/03/2010 motor caravans are, without question, not subject to testing under the auspices of the RSA HGV test manual.
It is interesting that the RSA have chosen to include 'Ambulances' under the HGV manual and not test them as Category 4 (the same category as Taxis) as set out in DIRECTIVE 2009/40/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 6 May 2009 .
Lets hope that when they conclude their deliberations on how 'Motor Caravans' are to be tested they follow what is set out in the Directive and require them to be tested to specifications applicable to Category 6, as is the requirement elsewhere.

For the record, I have ask for and been refused a roadworthiness test for my motor caravan by both the NCT central reservations office and a number Light Goods Vehicle test centres, all were quite adamant they were not authorised to test such a vehicle.

PS. We had been promised the 'discussion document' by end of February but no sign yet :rolleyes:

Another interesting thing is that after reading the above from Niloc I went on to the NCT bookings site as I did back in November (See my posting of 20/11/09) and whereas at that time they offered me a booking date, which I did not accept, this time my vehicle registration does not even appear on their system!. This, to me, implies that the transport authorities have removed, possibly all, campervan registration details from the NCT computer. So as far as the NCT people are concerned we do not exist! Don't you just love the Irish system? I do.

Irishgoatman

Received today, At last.

All campers still to be tested at CVT centres which I think we expected.
Charges (at least for my small van) still the same as commercial, which I think is cheeky.

The only problem that I, and maybe most of us will have, is side and rear windows.

In this document, Item 4.3.4 Glazing Materials, (page 9) third paragraph, states that anything other than safety glass must have a certificate stating that the material will not, if fractured, produce fragments capable of causing severe cuts. These windows on my van are made of Perspect.

I rang the main manufacturer in the U.K. EECO Ltd. and they told me that this is what they make for all campervans and caravans and they have never heard of any regulation against this.
The only marks on my windows are those of the original manufacturer who has now gone out of business, but EECO told me that what they make today are the same.

Would anyone of you like to check your side and rear windows and report back please.

Other than this, nothing too drastic that I can see.

Thanks.

Irishgoatman

Must use Spell checker now and then!

In previous post please read Perspex instead of perspect !! DUH

vinniem

Just checked my windows and they comply. Should have circle with E1 and also 43R stamped somewhere on each window. If u have this according to previous posts you don't need a safety cert from mfg

Des32

Hi
Take a look at the RSA home page for today lots of information re motorhome DOE consultation and what they will be looking for in the test.

peasant

Yes, this safety glass thingy is an issue

4.3.4 GLAZING MATERIALS
Motor vehicles registered on or after 1st January 1986 must be fitted withwindscreens made from laminated safety glass and marked to UNECE
Regulation 43, E-marked 43R.
Alternatively they may be marked to one of the following British Standards;
B.S. 857-2 or B.S. 5282 or B.S. AU 178 or an equivalent standard as shown inTable 2 overleaf and detailed in the Vehicle Testing Manuals.
The Vehicle Testing Manuals also state that where windscreens, side or rearwindows, are fitted with glazing material other than safety glass, the vehicle
owner shall provide a certificate from the manufacturer or installer stating that the glazing material is not likely, if fractured, to produce fragments capable of causing severe cuts.
Issues have arisen in the past, where the markings affixed to the glazing werenot evident on examination by the vehicle tester, and it has proven difficult for owners to provide certification to the standards above, particularly in the case of vehicle manufacturers/converters that are no longer in business. In such instances it may be necessary for the vehicle to be re-glazed with material meeting the standards specified above.

My motorhome (first registered in 89) has safety glazing in the cab. A laminated windscreen and toughened glass side windows, all of which are marked with E 43 R marks.

The rest of the windows however are plexiglass windows (Seitz/Buchholz and ParaPress) all of which have manufacturers markings, a wave symbol and a D-number, but no E 43 R mark. The wave symbol followed by a D and a number is the type approval or Bauartgenehmigung for vehicle glazing. This was in use prior to E 43R markings *

To my knowledge the test and certifying criteria for E 43 R has only recently been extended to non-glass glazing products and only since then can plastic windows actually be marked with the E mark. Not many of them actually are.

It is further my understanding that only windows that are situated where there are seats (that is seats with belts that may actually be used to transport people while driving) actually need to conform to these regulations.



But we absolutely need to get clarification on this.
Which windows need to be type approved?
Which type approvals (other than E 43R) will be accepted?

In my case, If I had to re-glaze my camper I might as well just throw it away ...much to expensive


* It might be worth mentioning that my camper for example has been passing German Tuev inspections between 1989 and 2005 with exactly those windows without any problems.

Des32

My motorhome is a 2003 rollerteam it does not have the E 43 mark either apart from the cab windows. My windows are made by a Dutch company called polyplastic so I have emailed them today to see if I can get some sort of certificate for the windows.

peasant

Des32 wrote: »

My motorhome is a 2003 rollerteam it does not have the E 43 mark either apart from the cab windows. My windows are made by a Dutch company called polyplastic so I have emailed them today to see if I can get some sort of certificate for the windows.

You shouldn't have to really. Unless these windows were put in afterwards by some cowboy, they should have type approval.
No motorhome manufactured (or sold from new) in the EU gets to see the road without type approval. Type approval isn't granted without windows that don't conform.

Your windows probably also have another marking than just the manufacturers name (something like ~~ D 1234 for example) ...just check again.

It's these markings that we need to identify and get included in the test requirements as valid.

Once again, E 43R is a marking for glass derived from a standard for vehicle glass. Only lately have some manufactuerers gone through the trouble to get E markings for their plastic windows.
But plastic vehicle windows with other forms of type approval are perfectly acceptable as well ...at least in other countries.

*Kol*

I have three windows made for me by EECO (mentioned above in another post). I am sure they have no markings at all (but I must check). The rest are made by polyplastic and they do have markings as far as I recall. I have installed the windows myself, does that mean I can provide a cert to say that they are not not likely, if fractured, to produce fragments capable of causing severe cuts??? ("owner shall provide a certificate from the manufacturer or installer ").

I think it is a minefield due to the amount of windows out there manufactured with no markings. It is going to be very difficult for any DOE test centre to interpret or enforce this part of the test properly as it will be impossible to verify any certification provided for a window that has no markings.

Irishgoatman

peasant wrote: »

Yes, this safety glass thingy is an issue



My motorhome (first registered in 89) has safety glazing in the cab. A laminated windscreen and toughened glass side windows, all of which are marked with E 43 R marks.

The rest of the windows however are plexiglass windows (Seitz/Buchholz and ParaPress) all of which have manufacturers markings, a wave symbol and a D-number, but no E 43 R mark. The wave symbol followed by a D and a number is the type approval or Bauartgenehmigung for vehicle glazing. This was in use prior to E 43R markings *

To my knowledge the test and certifying criteria for E 43 R has only recently been extended to non-glass glazing products and only since then can plastic windows actually be marked with the E mark. Not many of them actually are.

It is further my understanding that only windows that are situated where there are seats (that is seats with belts that may actually be used to transport people while driving) actually need to conform to these regulations.



But we absolutely need to get clarification on this.
Which windows need to be type approved?
Which type approvals (other than E 43R) will be accepted?

In my case, If I had to re-glaze my camper I might as well just throw it away ...much to expensive


* It might be worth mentioning that my camper for example has been passing German Tuev inspections between 1989 and 2005 with exactly those windows without any problems.

Hi Peasant, My side windows are marked the same as yours, Para Press (Manufacturer who has now closed down) followed by a D number.

My van has passed the U.K. M.O.T. ever since it required it and I have all the pass certs. as the previous owner kept every one up to, and including the test document for August last year. New windows for my van would cost about %00 to 600 pounds sterling and I would have to take out and send the existing windows to the U.K to ensure that identical ones were made. They would then be made by EECO Ltd out of PERSPEX !!!

*Kol*

Irishgoatman wrote: »

New windows for my van would cost about %00 to 600 pounds sterling and I would have to take out and send the existing windows to the U.K to ensure that identical ones were made. They would then be made by EECO Ltd out of PERSPEX !!!

You would be lucky to get away with £600 stg for a ful set of windows (unless you have either tiny windows or very few windows). I would say you would be lucky to get away with €1500-€2000 including shipping to and from the UK.

All MH windows are made from perspex/acrylic/plexiglass it's the same thing. It's the very same material that aircraft windows are made from (they are just thicker to withstand the pressure of the cabin).

zoltar_boi

I have a German import 2000 Dethleffs, which don't have this "E" marking. They are made from a product called Roxite. I tracked down the manufacturer, and they set me details of after-manufacture certification from the German government for Roxite windows.

I will see how they take them in the VTN centre before I even consider changing windows. Maybe I could just salp boards up over the window openings and say "windows - what windows?":D