New DOE thread

Aidan_M_M

Folks , seeing as the RSA have now a set of proposed rules/guidelines for the Camper Test , is it time for a new thread? Have any of you lot seen the email they've sent out?


Modedit:
Good idea! Question mark removed from thread title ...this now is the new DOE thread ....carry on

*Kol*

I have seen the comment letter which doesn't cover a lot of subjects. The glazing seems to be the main issue. I don't feel like reglazing the MH any time soon. Apart from the fact it would be very expensive I found it very difficult to get the sizes I was looking for the last time replaced a window and I am not sure if I could even source certified windows in the sizes I need.

Buford T Justice

Yeah, I got an email from them,

Check out their PDF here

peasant

Another thing to have a look at is the actual DOE test manual for heavy vehicles to which most of our campers will be tested

http://www.boards.ie/vbulletin/showpost.php?p=65259928&postcount=16

There may be the odd pitfall in there where usual camper equipment/fitments may collide with the regulations.

Aidan_M_M

LHD vehicles too , with single Fog and Reverse lights , in theory would need them switched side to side... and will they accept beam benders on LHD headlights?

Also , how are they going to test AL-KO chassis?

peasant

Aidan_M_M wrote: »

Also , how are they going to test AL-KO chassis?

Yepp ...that could be another stickler

spaceHopper

Didn’t somebody here research it and find that campers / motor homes are class M and are exempt under Irish / Eu regs.

I’ve small side windows on an 19 year old Jap camper I won’t be able to get certs – might ask a friend how has plastics factory for a letter though or get a MH supplier to write me one – the nearest to me is in blessingtown.

They should at the very least check the gas and pressure test the system – a friend of mine has a leaky cooker and was getting sick from it till they found it. At the very least I could be driving a mobile bomb.

I’ve a side rack for surf boards, it’s well made and secure but surely they should be checking that ladders, racks, roof boxes, tanks are all secure.

I take their point about testing 10 year old van every year.

Am I right in thinking that when I doe the camper I have to pay to get the report changed into a cert – sorry not on, it should be the same as the NCT, you get a cert when you pass –end of

Every thing else should be fine and I’d have no problem passing but I won’t be getting it tested as a commercial it must be a proper camper test. They could lift the elements from the insurance test report.

I’d also like to see them own up to getting it wrong for how it’s been done and that campers weren’t required to be tested.

loobylou

spaceHopper wrote: »

Am I right in thinking that when I doe the camper I have to pay to get the report changed into a cert

Yep, at least it is when you DOE a commercial van at present.
They take the test certificate and hand write the details from it onto an almost identical certificate. That will be €6 sir.:mad::mad:

peasant

My very personal opinion (and not that of a forum moderator) on this mess is this:

Regardless of legal nitpicking and fiddling with the categories ...the idea that someone can drive around in a 3 ton lethal weapon that may never have been tested is a bit scary ..so I'm in favour of a test in principle (and by the way ...where is the test for motorbikes and trailers?)

That thing about the glazing is just ridiculous and shows how litte an idea of motorhomes the RSA actually has.

Gas testing ...well your ordinary vehicle tester probably knows less about gas installations than you or me and a separate gas test would cost even more money. Get your gas tested privately by a fitter every now and then, don't be giving the RSA ideas. Next they'll want to have the electric installations tested as well.

A test once a year for older motorhomes ...considering the little mileage that I do I find that totally unnecessary. But that's coming in the NCT as well, so there probably is no opt-out clause.

The fact that the DOE costs nearly twice as much as the NCT and just as much as the tax ...well, I'm not impressed ...especially not on an annual basis.
I don't make money from my camper (unlike a company from their commercial vehicle) why should I be paying commercial rates?

hellbent

The RSA state the following in their document re proposed testing of motor Caravans:

Motor Caravans, to be tested on the fourth anniversary of their first registration, and thereafter every two years.

Is it correct to assume that the date of first registration applies to when first registered as a Motor Caravan (rather than the date the vehicle was first registered)? After all, the document relates solely to testing as a Motor Caravan, so surely the reference applies only from the point of registration as a Motor Caravan, onwards??

i.e. if I owned a, say, year 2000 Transit, which I now convert and re-register as a Motor Caravan - Do I get 4 years grace before my next/first DOE test as a Motor Caravan, or, because the Transit itself (as an LGV) is 10 years old, am I required to test it in 1 years' time?

As it's usually a big mistake to make assumptions:(, I'd be grateful for further opinions on this question, please.

Edit: On reflection, it has to be that the date of first registration of the vehicle itself is the applicable date, and not whenever its re-registered as a Motor Caravan. Also, it seems reasonable that it should undergo testing at least as frequently as a car does. Also the tests are more numerous and possibly stricter than car testing, so I guess its also fair that a higher fee should apply. Maybe not as high as for an LGV though, due to the lower mileage typical of a Motor Caravan.

The RSA should take that into account, plus the fact that all Motor Caravan owners have another vehicle as their main source of transport, and are therefore not using it commuting daily, etc.

*Kol*

I intend respoding to the RSA on the comment document. I would suggest that as many people as possible do the same in order for this to be clarified/amended before it becomes law.

Irishgoatman

Yes a test is important but it should be, in my opinion, as our vehicles are not commercial, just as the NCT but with allowances made for the weight.
Having said that, there are lot of cars on the road that are heavier than my camper but go through the NCT with no problem.

I agree with Peasant that we need to see the DOE manual if that is what the RSA intend using as a basis for the tests, otherwise how can we fully comment?. As an example, for the NCT, wheel trims need to be removed or they will not test. Will this be the same under the DOE?.

I cannot see that the glazing will be a problem because as I mentioned in a posting on the other thread, if you go to someone like EEEC Ltd. in the U.K. for new windows, they are specialists in caravan and camper windows, they will still be made of Perspex.

Any charge for the test must include a cert. and a windscreen disk as with the NCT.

I will be contacting the RSA after the weekend and asking for a copy of the DOE test manual. If they say no to that I will ask for authorisation to view a DOE test on a commercial vehicle of approx the same weight as my camper and see where that gets me.

peasant

The DOE manual is also online (see post #4)

Irishgoatman

Thank you Peasant.
Missed that one.

Irishgoatman

peasant wrote: »

The DOE manual is also online (see post #4)

Hi Peasant,
I'm afraid that the link you gave appears not to work.
I've tried googling for the manual but without any luck.
Any other ideas?.

peasant

The RSA seem to have re-vamped their site.

found it again though on this page
http://www.rsa.ie/RSA/Professional-Drivers/Vehicle-testing/Testing/The-Commercial-Vehicle-Test/

Light goods vehicles <= 3.5 tons
http://www.rsa.ie/Documents/Vehicle%20Testing/LGV%20manual.pdf

Heavy goods vehicles > 3.5 tons
http://www.rsa.ie/Documents/Vehicle%20Testing/HGVManualV6sm.pdf

Irishgoatman

Thanks Peasant, I'll try that one.

BTW with regard to vehicles older than 10 years being tested every year from 2011, which I have no problem with, I wonder if the RSA realise that Directive 2009/40/EC of the European Parliament of 6th May 2009, page L 141/16 Annex 1, Item 6 , states that frequency of testing is every two years for vehicles for the carriage of passengers and with not more than 8 seats!. Surely they will have to get the change passed through the EU unless that is already in motion.

Malta1

Hi All

I fully agree that it is hugely important that we get our say on this document. My question is regarding the "mechanism" of reply. There seems to be 2 distinct options:
1. Should a small group from here offer to meet the RSA and go through the test doc conveying the issues and concerns?

or

2. Should we all respond as concerned owners outling perosnal issues and concerns?

Any opinions?

Slidey

Just said I would post the email the RSA have sent to the test centres

31 March 2010

Roadworthiness Testing of Motor Caravans


Dear Stakeholder,



The Road Safety Authority (RSA) has today, 31st March 2010 launched a public consultation undertaking a review of motor caravan roadworthiness testing. As part of this review the RSA is consulting with owners of motor caravans, individuals and organisations who sell and hire motor caravans, the general public and other stakeholder groups who have an interest in the safe operation of such vehicles on Irish roads. The consultation document can also be downloaded from the RSA website www.rsa.ie under the “Publications” tab.



RSA policy, to save lives and prevent injuries by reducing the number and severity of collisions on the road, is to require as many vehicle categories as possible to undergo periodic roadworthiness testing. Every owner and driver is obliged to ensure that their vehicle is roadworthy and in compliance with the law. 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 testing of motor vehicles and trailers and only exempts from testing vehicles owned by the armed forces, police and fire services. In light of this the RSA wish to revise our national roadworthiness testing regulations to ensure that an appropriate test is mandated for Motor Caravans.



You can submit your comments on or before 12th May 2010 by email to motorcaravanconsultation@rsa.ie or in writing to Vehicle Standards, Road Safety Authority, Moy Valley Business Park, Primrose Hill, Ballina, Co Mayo. Please mark the envelope “Motor Caravan Consultation”.





Yours sincerely





Tom McHale,

Principal Engineer - Head of Vehicle Standards

niloc1951

Just back from a weekend away and a few quick observations about contents in the Consultation document.
Appendix 1
Italy and Romania, speed limiters on category M2 & M3, vehicles of this category are not defined as 'motor caravans' in Directive 2001/116/EC, so this would appear to be something of a 'red herring'.
Appendix 2
The number of axles has been mentioned to me as a matter which could cause additional cost when testing, but this wouldn't appear to be an issue unless the DVGW is greater than 7,500 Kg.

Interestingly,the RSA 'survey' of other European countries (Appendix 1) does not include Germany, France, Sweden, three countries with highly developed road and vehicle safety standards, plus others like Spain, Belgium, Switzerland and Denmark, who between them account for over 68% of the camper fleet of the EU (Census 2006)
They quote, for example, Austria 2.3%, Cyprus, Romania and Malta , Finland 2.3%, The Netherlands 3.9%, UK 10.3%
Perhaps if they checked with the 'major players' a satisfactory resolution to the glazing issue could be found.

niloc1951

Websters Dictionary
Glazing:
To furnish (a window, a house, a sash, a case, etc.) with glass.

Thats GLASS not plastic or anything else ;)

deadl0ck

Hi All

I fully agree that it is hugely important that we get our say on this document. My question is regarding the "mechanism" of reply. There seems to be 2 distinct options:
1. Should a small group from here offer to meet the RSA and go through the test doc conveying the issues and concerns?

or

2. Should we all respond as concerned owners outling perosnal issues and concerns?

Any opinions?

For option 1, I'd be doubtful if they would meet a group, but it's worth a try..

For Option 2 - Would it maybe be better if we all drafted a letter as a group and then send the same letter individually, along with our name, address and MH reg. number (to prove we're not just the same person sending loads of letters)

Would it be worth having a site / wiki dedicated to this? Basically, where we start to add any information, documents etc. along the way, including any correspondence from RSA et. al. in reply to any questions asked. It could be a valuable resource...

peasant

deadl0ck wrote: »

For Option 2 - Would it maybe be better if we all drafted a letter as a group and then send the same letter individually, along with our name, address and MH reg. number (to prove we're not just the same person sending loads of letters)

Would it be worth having a site / wiki dedicated to this? Basically, where we start to add any information, documents etc. along the way, including any correspondence from RSA et. al. in reply to any questions asked. It could be a valuable resource...

We could do that here, collect all the elements of the letter in a dedicated thread and I would assemble the letter in an ordlery fashion in a closed post (for all to see but so that it doesn't get chatted to bits) until it's ready to send.

Malta1

Im happy with that idea

deadl0ck

Me too - sounds like a plan !

peasant

Ok ...appropriate threads created ...now, INPUT please

(please keep in mind that I also have a day job and will only be able to work on this every now and then and not always immediately)

Irishgoatman

This look like a good plan Peasant.

I agree with deadlOck on option2, one letter sent collectively and the same letter sent from each of us as individuals. One letter with lots of names gets read only once, lots of letters with one name all have to be read even if they say the same thing and have to be acknowledged.

peasant

Please check the draft of the letter frequently.

I'm trying to keep it as up to date as possible by adding all new/decided points as and when they happen.

Text that will end up in the final letter is currently in italics.

The letter and the discussion thread have both been stickied and marked with this

no excuses

Aidan_M_M

peasant wrote: »

Please check the draft of the letter frequently.

I'm trying to keep it as up to date as possible by adding all new/decided points as and when they happen.

Text that will end up in the final letter is currently in italics.

The letter and the discussion thread have both been stickied and marked with this

no excuses

Excellent work sir . Do you want to lock this thread now so?

peasant

Aidan_M_M wrote: »

Excellent work sir . Do you want to lock this thread now so?

Yea ..probably should lock this ...thanks