DOE for campers

peasant · 04-08-2009 10:35am

Is it just me or is this whole affair just another example of a typical Irish farcical mess?

Let's make it up as we go along and tell no-one about it ....

I'm all for testing of campers, after all it's in our own interest, but not like this.

As far as I'm concerned, I'm going to wait until someone official (i.e. the motor tax people) tells me in writing that I have to get my camper tested.

*Kol* · 04-08-2009 10:57am

+1

I have absolutely no intention of getting that test done. It's like a chinese whisper at the moment.

Malta1 · 04-08-2009 11:42am

Like the majority on here, from a safety stand point I have no problem getting the van tested. I do have a problem with the test criteria and how the story seems to be evolving.

I wont be getting my van tested until I am told to

Macspower · 04-08-2009 1:19pm

I have just written a mail to bill at the RSA outlining my views on the test..

My understanding of the situation is as follows

No one seems to have a problem with a test.
Just the test needs to be fair and designed to make sure the vehicle is safe for the purpose it was intended for... ie Leisure Vehicle with low mileage

How do we suggest getting such a test designed/agreed with the RSA?

It does seem they are willing to listen a little (re markings for example) so where to from here...

A legal challenge against a test is not a viable option however an action group with a properly constructed committee might be an option... A spokesperson to meet with the RSA and discuss the matter

We are very much a minority group but should still make our opinions known to the RSA or whoever is dealing with it...

Any opinions?

spaceHopper · 04-08-2009 2:03pm

This will be fun going in to tax my camper for the first time, won’t get a vehicle licensing cert till I tax it and bet I can’t DOE it till I have the cert. But I bet it will be fine as I don’t need a DOE to tax it ;-)

Karg · 04-08-2009 7:16pm

Macspower wrote: »

I have just written a mail to bill at the RSA outlining my views on the test..

My understanding of the situation is as follows

No one seems to have a problem with a test.
Just the test needs to be fair and designed to make sure the vehicle is safe for the purpose it was intended for... ie Leisure Vehicle with low mileage

How do we suggest getting such a test designed/agreed with the RSA?

It does seem they are willing to listen a little (re markings for example) so where to from here...

A legal challenge against a test is not a viable option however an action group with a properly constructed committee might be an option... A spokesperson to meet with the RSA and discuss the matter

We are very much a minority group but should still make our opinions known to the RSA or whoever is dealing with it...

Any opinions?

Definitely think something should be done - anyone got any further word from the camper club(s)? Wexford VTN centre now advertising on South East Radio that they are testing campers!

roryq · 05-08-2009 11:08am

My father's Iveco F10 has failed the DOE test in Kilkenny.. They failed him on the windows.. As there were plastic and he did not have windows cert. The problem is I've spent the last 3 days looking to try and find the window makers but the have gone out of business See Thru plastics is the company and they are a contora window.. Is there anyway around this does anyone know. Can you get them inspected by someone and certified.

Macspower · 05-08-2009 5:30pm

Well speedy response from the RSA... It seems all is not written in stone as yet

Even though it was a private mail in response to my letter I think it is in the public interest.. ( if deemded inappropriate mods please delete)

My letter

Sent: 04 August 2009 12:05

Subject: Testing of Motorhomes and campers

Hi

Regarding the new proposed regulations about the testing of Motorhomes
and Campers.

Just to fill you in on the matter. I am a camper van owner now for
nearly 10 years and also recentyl purchased a motorhome and
I am well aware of the need for testing of all vehicles on the road but can I please bring a few matters to your attention..

Firstly as stated I am all on for testing as I personally know of some
campers and in particular conversions that should not be on the road.
But and it is a big BUT the test needs to be suitable for the purpose it
is intended... To make for safer motoring.

A DOE test for a camper with all the regulations of a Commercial Vehicle
is not a fair test for a motorhome.. It is not a commercial vehicle and
therefore should not and cannot be tested as one. These are leisure
vehicles and while some may have many similarities to commercial
vehicles they are a seperate category in their own right.... Leisure
Vehicles

In my opinion the following should be taken on board while designing a
test for these vehicles

1) The test can be carried out through the VTN as proposed

2) Due to the mileage ( I do on average 2000/3000 miles per year) an
annual test should not be required but instead one proportional to the
use... Every 2 years like the NCT or 3 years would be more appropriate.

Once every vehicle is tested once and it is deemed as roadworthy very
little is going to change in a year

3) For vehicles over 3.5 tonne (many are just over this) do you propose
that need to be treated like a commercial with a tacho and side marking
and weight plate, speed limiter etc?? Due to the purpose of the vehicle
I believe this is not necessary and completely complicates the situation
and the purpose of the test which is to have safe vehilces on our roads

4) On speaking to my local DOE centre they inform me thay a certificate
of some sort is required for the window glass.. In my vehicle the
windows are stamped by the manufacturer and are made from some sort of
double glazed perspex. While I understand the need to make sure that the
windows are safe a cert is not the answer in my opinion.. I have seen
some conversions with ordinary "house" window glass and this should be
outlawed... Why not leave it to the test centre to determine if the
windows are safe or not?

5) Is there a proposal for some sort of inspection of the gas and
wiring? This is every bit as important for safety as the rest of the
test and to overlook it would be contrary to the purpose of the test...
ie SAFETY

In Summary... The test needs to be designed for the purpose which it is
intended... To keep unsafe vehicles off our raods.. Campers/Motorhomes
are not commercial vehicles and should not be tested as one but instead
have a custom test designed for the purpose and frequency to fair to the
use.. every 2/3 years.... If every 2 years is good enough for a car
doing 50k per year every 2 years should be good enough for a leisure
vehicle..

While we are a minority group and whatever you decide we will have to
live with all I ask for is a FAIR test for my vehicle designed for the
purpose and use it was intended for.

Kind regards,

response from RSA

Thank you for your submission and views. The RSA will be conducting a review of the testing regime for motor caravans and we shall include in the discussion the issues you have mentioned.

Briefly, the RSA is considering these vehicles as goods vehicles for testing purposes only. A goods vehicle does not mean a commercial vehicle.

The legislation for tachograph use provides for exemptions including one for "vehicles or combinations of vehicles with a maximum permissible mass not exceeding 7.5 tonnes used for the non-commercial carriage of goods." I believe most owners who might otherwise be liable for a tachograph can legitimately claim this exemption. Each VTN centre has copies of the form to be signed prior to the test.

The RSA has already issued a circular to the test centres providing a temporary exemption (pending the review) from the requirement for conspicuity markings.

Non-glass glazing must be to an automotive standard; therefore, if the material is marked as such (e.g. E-marked 43R signifying type approval to UNECE Regulation 43 for automotive glazing) it will not require further documentation. The burden of proof is on the owner to show that that the glazing meets automotive standards for the reason you mentioned. It is not the responsibility of the test centre to investigate the source and quality of the glazing.

Again, thank you for your views. They will be considered and discussed during the upcoming review of testing motor caravans.

Regards,

XXX

Engineer

Standards & Enforcement

RSA_Official

Clonfert House, Loughrea , Co Galway

Aidan_M_M · 05-08-2009 5:55pm

there are between 9500 and 10,000 motorhomes registered in Ireland... So we deserve to be heard! In fairness to the RSA , they are good to reply , we've spoken to them a few times already .

zagmund · 05-08-2009 7:40pm

Umm, there's a loophole (a huge one in my view) in the 'glass' certificate thingie.

What's to stop me getting a certificate for a window and submitting it to the test centre saying it represents the one in my vehicle, when in fact it represents the one in someone elses vehicle, or a scrapped vehicle, or one in the UK or something ?

Also, I know it says the original must be stored by the test centre but that just ain't going to work. What happens if I get my vehicle tested in Smiths Garage and the next day they go on fire and my cert is lost forever ? Or they spill a pot of tea over it, whatever . . .

Will I not be able to get my vehicle DOE'd next year because I can't stump up the cert ? What if Smiths Garage closes down and someone dumps the pile of old certs they found mouldering in the corner ?

z

salamander27 · 05-08-2009 9:20pm

peasant wrote: »

Is it just me or is this whole affair just another example of a typical Irish farcical mess?

Let's make it up as we go along and tell no-one about it ....

I'm all for testing of campers, after all it's in our own interest, but not like this.

As far as I'm concerned, I'm going to wait until someone official (i.e. the motor tax people) tells me in writing that I have to get my camper tested.

Totally agree. They have my address. I'm waiting for the letter.

OuterBombie · 06-08-2009 11:28am

Hi lads,

I'm taking the same view as Peasant on this one, wait and see what happens. However while being in the process of buying a van at the moment (more on that next week), i'm wondering about the glazing issue:

Macspower wrote: »

Non-glass glazing must be to an automotive standard; therefore, if the material is marked as such (e.g. E-marked 43R signifying type approval to UNECE Regulation 43 for automotive glazing) it will not require further documentation. The burden of proof is on the owner to show that that the glazing meets automotive standards for the reason you mentioned. It is not the responsibility of the test centre to investigate the source and quality of the glazing.

Anyone have details on seitz windows, a lot of vans are fitted with them. I searched for a seitz website with no joy. I'm hoping they are to an automotive standard, would anyone know otherwise? or be able to point me to a website with more information.

Thanks,

Ray.

peasant · 06-08-2009 11:45am

Seitz windows have an "R" stamp ...at least mine have

Factory built motorhomes must pass EU homologation, they wouldn't if the windows didn't comply

OuterBombie · 06-08-2009 11:53am

peasant wrote: »

Seitz windows have an "R" stamp ...at least mine have

Factory built motorhomes must pass EU homologation, they wouldn't if the windows didn't comply

Thanks Boss, I suspected as much, couldn't see Germans putting non complying anything onto German factory build vans.

zagmund · 06-08-2009 12:26pm

I've been holding off checking, just in case . . .

I had a look now and my factory fitted ('93 Hymer) Seitz windows don't have an R - waaaaaaaaaaaaaaaaah. There is a D512 though - any ideas if that will keep them happy ? If not, then Hymer and others are going to be getting lots of mails from "Concerned of Longford/Blackrock/Kilfenora" looking for certificates. Alternatively, does anyone want to buy a '93 Hymer Camp which meets all currently enforced regulations (for the moment anyway) ?

My replacement windows bought last year (according to Mrs Zag the original one "just fell out") has a 43R. On the plus side I'll be able to keep at least one of my windows. Yaaaay. I might add that then the original one 'just fell out' it didn't shatter. Does that help my case ?

z

bugsntinas · 06-08-2009 1:16pm

i've been reading this for awhile and it seems like a typical irish government balls up.what's with the reflective strips(i know exempt at the moment)i have a mk2 transit swb and if it has these strips on it will ruin the look as it's a classic.is the doe going to be for campers aswell as motorhomes as there is quite a difference between the 2 especially old ones as in 27 year old?

sunchaser · 06-08-2009 9:34pm

Has anybody asked the question of any camper with a tag axel, whether it be under or over 3.5t with an alko chassis. You will be in for a little surprise, as far as DOE are conserned it is a modification to existing chassis and the fun begins. I am told a little worse than the window problem.

Slidey · 06-08-2009 9:42pm

Well if it has a manufacturers plate states that there is 3 axles then you are sound.

If not then you will need to get an independent assessment from an engineer.

peasant · 06-08-2009 9:50pm

With the exception of home conversions or aftermarket additions, the campers that drive around on Irish roads weren't just conjured up out of nowhere. They were buildt in dedicated motorhome manufacturers to the EU standards / national guidelines that applied at the time.
These motorhomes had to be homologated and pass the relevant safety inspections before they could be sold to the public. In case of s/h imports they also quite likely have been tested several times by the TUV, MOT or whatever else applied.

Who does the RSA / DOE think they are that they can all of a sudden come along and doubt the safety expertise of other EU countries and make up their own rules? (particularly after not giving a hoot for decades :rolleyes:)

If the windows on my van were good enough to pass the German TUV about ten times, they should bloody well be good enough to pass here without me having to bring along any paperwork whatsoever.

The same goes for any ALKO chassis, Westfalia highroof or whatever else came standard with your camper.

peasant · 06-08-2009 9:53pm

Slidey wrote: »

Well if it has a manufacturers plate states that there is 3 axles then you are sound.

If not then you will need to get an independent assessment from an engineer.

You do realise that a double axle where the hubs are less than 1 meter apart technically counts as a single axle and can be plated as such?

Don't ask me for the relevant EU regulation, I don't know it ...it's true nonetheless

Slidey · 06-08-2009 10:29pm

I didn't know that. I will do a bit of digging tomorrow and see what I can find out.

peasant · 06-08-2009 10:52pm

An Alko double axle chassis should however be plated with three axles ...but there may be exceptions as mentioned above

http://www.al-ko.co.uk/Downloads/amc_handbook/al-koamchandbook_17-18.pdf

Slidey · 06-08-2009 10:55pm

I will open it 2mrw in work, if I install Adobe on this yoke for whatever reason it plays merry hell.

Just thinking though, I metre wheel base with wheels and tyres must be very tight.

Des32 · 06-08-2009 10:56pm

Hi all,
I own a transport business so I rang the DOE garage that I use today to see if they had any information, They have tested a few motorhomes and they said to get a form from my insurance company which specifies what has to be tested, Sounds like the 15 year engineers report to me but they said it for a DOE. Then I rang Dolmen and it was the first they heard of a DOE for motorhomes. They told me to ring the Dept of transport, don't think I will bother.

*Kol* · 06-08-2009 10:59pm

Its all a geting a bit complicated now. For the 5 times a year I use my MH it's not worth the hassle to get it done unless you cant tax or insure it.

peasant · 06-08-2009 11:11pm

Maybe if we stop talking about it (giving the RSA ideas in the process) it will just go away?

:D:D

2 stroke · 07-08-2009 12:49am

I've emailed the rsa a few times but only half of my questions are being answered by them.

blue42 · 07-08-2009 7:58am

only a matter of time before this government finds a way to screw money out of campervan and motorhome owners, nearly time to go back to camping i think!:(

bugsntinas · 08-08-2009 12:32am

i ain't gonna bother although my van needs work so won't be on the road this year:(
surely they have to treat motorhomes and campers differently as they are different from each other i mean our mk2 camper is like a minibus in appearance and is totally different from a mk2 motorhome.
i'd love to see the test critirea for them all.

salamander27 · 11-08-2009 11:11pm

I've been trawling the statute books looking for any reference to campers being tested and have come up with zilch. Could anyone point me where it states legally campers must be tested?

DOE for campers

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