DRAFT
Regulation Impact Statement
for
Underrun Protection
A draft statement inviting discussion and comments from
parties affected by the proposed heavy commercial vehicle safety initiative
January 2007
Report Documentation Page
Report No.
DOTARS VSS 01/2006
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Report Date
January 2007
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File No.
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ORR Reference No.
7317
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Title and Subtitle
Regulation Impact Statement for Underrun Protection
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Organization Performing Analysis
Standards and International
Vehicle Safety Standards Branch
Department of Transport and Regional Services
GPO Box 594
Canberra, ACT 2601
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Regulatory Agency
Department of Transport and Regional Services
Vehicle Safety Standards Branch
GPO Box 594
Canberra ACT 2601
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Abstract
The aim of this Regulation Impact Statement (RIS) is to examine whether there is a need for government intervention, to be directed towards new vehicle construction, in order to reduce the trauma from road crashes involving heavy commercial vehicle underrun. These crashes are
often severe, because of the incompatibility in both mass and geometry of heavy vehicles and
other road users such as passenger cars, motorcycles, bicycles and pedestrians.
The need for some type of Underrun Protection (UP) was identified. Costs and benefits were
estimated for eight possible non-regulatory and regulatory options to introduce UP.
Although self-regulation is very much on the agenda of the road freight transport industry, it
was concluded that the level of competition within the industry and the externality of any
benefits achieved would not make this an effective option.
It was demonstrated in line with the Council of Australian Governments (COAG) principles for making national standards that there would be a maximum net benefit in mandating an Australian Design Rule (ADR) for front UP for new rigid and articulated heavy commercial vehicles with a Gross Vehicle Mass (GVM) greater than 7.5 tonnes. The ADR would adopt the United Nations Economic Commission for Europe (UNECE) standard R 93. It was assumed that the state and territory road authorities would raise the current 6 tonne steer axle limit to at least 6.1 tonne to account for the extra mass of the UP system.
It was also concluded that the rear bumper requirements for semi-trailers in ADR 42/04 should be withdrawn, without mandating replacement rear UP. It was not recommended that side UP be mandated.
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Key Words
Underrun, trucks, crash protection, fatality reduction, UP, UPS, FUP, FUPS, FUPD, RUPS, RUPD, SUPS, SUPD
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Distribution Statement
Document is available to public through the web site: www.dotars.gov.au
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Security Classification
Unclassified
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No. of Pages
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Price
No charge
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Submitting Comments
The Department of Transport and Regional Services invites comments from interested parties and parties affected by the provisions of this Regulation Impact Statement.
Comments should be submitted using the attached format.
Comment Form A should be used by heavy commercial vehicle/trailer manufacturers, heavy commercial vehicle importers and bull bar manufacturers.
Comment Form B should be used by state and territory government agencies having responsibility for road transport safety.
Comment Form C should be used by motoring clubs and other road user agencies representing the interests of motorcycle riders, bicycle riders and pedestrians.
Comments would be preferred by email and sent to: standards@dotars.gov.au
Comments may be sent by fax to: 61 2 6274 7714
Comments may be sent by post to the following address:
The General Manager
Vehicle Safety Standards Branch
Department of Transport and Regional Services
GPO Box 594
Canberra ACT 2601
For further information please contact:
Standards and International Section
Vehicle Safety Standards
Maritime and Land Transport Division
Department of Transport and Regional Services
GPO Box 594, Canberra, ACT 2601
Telephone: 02 6274 7440
Fax: 02 6274 7714
Email: standards@dotars.gov.au
Comment Form A
To be used by heavy commercial vehicle/trailer manufacturers, heavy commercial vehicle importers and bull bar manufacturers
Please provide details of your organisation
Name of Organisation
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Address
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Postal
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Telephone
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Fax
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Email
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Contact Person
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Position
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Please indicate which option you support
Option
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Yes
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No
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Option 1 – Self-Regulation by Heavy commercial vehicle Manufacturers/Importers
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Option 2 – National Heavy Vehicle Accreditation Scheme
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Option 3 - Industry Code of Practice
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Option 4 - Australian Standard
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Option 5 – State and Local Government Fleet Purchasing Arrangements
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Option 6 – Business as usual
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Option 7 – ADR adopting FMVSS, UNECE Regulations, EEC Directives and Brazilian Regulation
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Option 8 – ADR adopting UNECE Regulations 93 for rigid and articulated trucks with a GVM greater than 7.5 tonnes
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Please respond to the following questions
1
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Can heavy commercial vehicle manufacturers and importers
confirm if any models offered to the Australian market are fitted
with front, rear or side Underrun Protection (UP)?
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Yes
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No
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2
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If NO, does your company intend to fit UP?
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1-2 years
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3-5 years
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Yes
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No
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Yes
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No
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3
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Can heavy trailer manufacturers confirm if any models offered to
the Australian market are fitted with side UP?
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Yes
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No
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4
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If NO, does your company intend to side fit UP?
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1-2 years
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3-5 years
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Yes
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No
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Yes
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No
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5
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Has voluntary provision of UP had any
impact, positive or negative on your sales volumes?
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Positive
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Negative
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Yes
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No
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Yes
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No
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6
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If fitted, can heavy commercial vehicle and trailer manufacturers confirm whether UP meet UNECE Regulations 93, 73 and 58?
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Front
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ECE R 93
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Other
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Yes
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No
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Yes
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No
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Side
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ECE R 73
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Other
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Yes
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No
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Yes
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No
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Rear
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ECE R 58
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Other
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Yes
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No
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Yes
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No
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7
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Can heavy commercial vehicle and trailer manufacturers and importers provide any costs for UP that meet requirements of UNECE R 93, 73 and 58
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Rigid front UP
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AUD
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Development cost (design + prototype + testing + production engineering + production equipment + production tooling)
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Production material and labour cost (material + labour used for production of device)
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Unit price (if obtained from supplier)
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Rigid side UP
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Development cost (design + prototype + testing + production engineering + production equipment + production tooling)
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Production material and labour cost (material + labour used for production of device)
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Unit price (if obtained from supplier)
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Rigid rear UP
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Development cost (design + prototype + testing + production engineering + production equipment + production tooling)
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Production material and labour cost (material + labour used for production of device)
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Unit price (if obtained from supplier)
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8.
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Can bull bar manufacturers identify any impact in sales, costs or other areas if bull bars for
new vehicles must be designed and tested to meet UNECE R93 requirements?
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Any other comments
Comment Form B
To be used by State and Territory transport and road safety agencies
Please provide details of your organisation
Name of Organisation
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Address
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Contact Person
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Position
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Please indicate which option you support
Option
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Yes
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No
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Option 1 – Self-Regulation by Heavy commercial vehicle Manufacturers/Importers
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Option 2 – National Heavy Vehicle Accreditation Scheme
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Option 3 - Industry Code of Practice
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Option 4 - Australian Standard
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Option 5 – State and Local Government Fleet Purchasing Arrangements
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Option 6 – Business as usual
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Option 7 – ADR adopting FMVSS, UNECE Regulations, EEC Directives and Brazilian Regulation
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Option 8 – ADR adopting UNECE Regulations 93 for rigid and articulated trucks with a GVM greater than 7.5 tonnes
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Please respond to the following questions raised in the RIS
Do you have data giving the number of underrun collisions with a breakdown into frontal, side, rear end and front/side swipe between heavy commercial vehicles with passenger cars, SUVs, motorcycles, bicycles and pedestrians, itemising each road user category between 1998-2006.
Do you have data giving the number of fatal, serious injuries (hospitalized) and minor (not hospitalized) injuries from underrun collisions for each road user category identified above and/or for different types or configurations of heavy vehicle?
Any other comments
Comment Form C
To be used by motoring clubs and other road user associations
representing motorcycle riders, bicycle riders and pedestrians
Please provide details of your organisation
Name of Organisation
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Address
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Contact Person
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Position in the organisation
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Please indicate which option you support
Option
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Yes
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No
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Option 1 – Self-Regulation by Heavy commercial vehicle Manufacturers/Importers
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Option 2 – National Heavy Vehicle Accreditation Scheme
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Option 3 - Industry Code of Practice
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Option 4 - Australian Standard
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Option 5 – State and Local Government Fleet Purchasing Arrangements
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Option 6 – Business as usual
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Option 7 – ADR adopting FMVSS, UNECE Regulations, EEC Directives and Brazilian Regulation
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Option 8 – ADR adopting UNECE Regulations 93 for rigid and articulated trucks with a GVM greater than 7.5 tonnes
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Any other comments
Important Notice
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This Regulation Impact Statement is an exposure draft
document that is released for feedback and comment. Its
contents should not be cited or published and no responsibility
is accepted for unauthorized disclosure.
The release of this paper for comment does not in any way constitute a commitment on behalf of the Australian
Government to adopt the approach outlined nor is any undertaking given as to the extent to which comments received may be adopted.
The Australian Government does not endorse products or manufacturers. Trade or manufacturers names appear only because they are considered essential to the objects of this statement.
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