Submission110– MVSA Review 2014
Following is my Submission regarding the 2014 Review of the Motor Vehicle Standards Act 1989, as outlined n the Options Discussion Paper, Issued September 2014.
My background:
I am a Chartered Professional Engineer, and Director and Engineering Manager of Rolling Diesel Pty Ltd, an engineering and mechanical drafting services company based in Victoria. I am also a registered VASS / AVE engineering signatory, a registered Agentwith the federalRVCS (RoadVehicle Certification System), and a consulting engineer specialising in heavy vehicle connection and heavy vehicle dynamics. I routinely design, test, analyse and validate towbars, couplings, safety chain attachments, and heavy vehicle chassis. I also provide advice to companies regarding heavy vehicle fleet safety.
My qualifications and affiliations:
Wayne Baker
CPEng MIEAust, MSIA, MSAE-A,FESA
MEngSc(Res), BE(Mech)(Hons), BA, GCertOHM
Chartered Professional Engineer (Mechanical)
Master of Engineering Science (Research)
Graduate Certificate in Occupational Hazard Management
Member of Engineers Australia, Mechanical College
Member of the Safety Institute of Australia
Member of the Society for Automotive Engineers, Australasia
Member of the Forensic Engineers Society of Australia
Delegate member of the Australian Road Transport Suppliers Association
Nationally Registered Professional Engineer, NPER #2085386
Engineering Signatory for Heavy Vehicle Modification AVE/VASS #1056
Lecturer in safe systems and safe design and the University of Melbourne
Submission:
It would be a major step backwards for Australian road safety should ADR62 be aligned to the United Nations Economic Commission for Europe (UNECE) Regulations.
The referenced Productivity Commission Recommendation 5.5 refers to international harmonisation of ADR's. However, ADR62 is a special case and should remain in place. ADR62 deals primarily with heavy vehicle (truck) towing components. The existing ADR62 sets the world's leading standard for the strength, marking, and existence of critical components that ensure safe vehicle connection.
ADR62 is unique to Australia and contains a number of sound safety measures that do not exist in the equivalent UNECE standards (or any other international towing standards). ADR62 prescribes benchmark strength and performance criteria for towbars, safety chain and safety chain attachments. These design criteria translate to a "safe life" design philosophy - that is, components must be designed to survive their service life without the need for inspection, repair, replacement or maintenance. ADR62 ensures that towing component designs are professionally engineered and validated to a level that ensures a reliable vehicle connection for the Australian operating environment.
Heavy vehicle towing components are critical for community safety. Failure of a towing component can lead to a 'runaway' trailer, which can weigh up to 45 tonne, exposing the community to very high levels of risk. Innocent road users have been killed by runaway heavy vehicle trailers. The high relative mass and high load beds of heavy vehicle trailers means that collision outcomes with light passenger vehicles are catastrophic. Passive safety systems such as crumple zones and air bags in light vehicles are ineffectual due to a poor collision interface.
Importantly, ADR62 mandates a system of marking for towing components. This ensures that useful information is available to operators, as well as traceability, with law enforcement officers able to hold component manufacturers and NHVR approved vehicle examiners to account.
--
Wayne Baker
CPEng MIEAust, MSIA, MSAE-A,FESA
MEngSc(Res), BE(Mech)(Hons), BA, GCertOHM
Engineering Manager
ROLLING DIESEL(R) Pty Ltd
• Design consultation including validation, integrity reporting, expert services.
• Innovative vehicle components, design solutions, industrial design.
• Engineering signatory services - VASS No. C056
Chartered Professional Engineer (Mechanical)
Master of Engineering Science (Research)
Member of Engineers Australia, Mechanical College
Member of the Safety Institute of Australia
Member of the Society for Automotive Engineers, Australasia
Member of the Forensic Engineers Society of Australia
Nationally Registered Professional Engineer, NPER #2085386
Engineering Signatory for Heavy Vehicle Modification AVE/VASS #1056
Ph: 03 53413563
Fax: 03 5341 3573
Email:
ABN: 301 545 957
ACN: 154 595 712
P.O.Box 667 Buninyong Vic 3357