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
Option 1: Self-Regulation (of front, side and rear Underrun Protection)
Download 5.27 Mb.
|
- Navigate this page:
- Option 2: National Heavy Vehicle Accreditation Scheme (NHVAS)
Option 1: Self-Regulation (of front, side and rear Underrun Protection)Industry self-regulation can be effective where the heavy commercial vehicle assemblers and wholesalers/importers voluntarily agree to supply Underrun Protection (UP) on heavy commercial vehicles. The Australian wholesale operations of some European manufacturers have recently commenced promoting commercial vehicles with front UP. This is because of a spill over effect resulting from the imposition of mandatory requirements for UP in Europe. The current volumes sold by the Australian agents of European manufacturers although not large are healthy, and while there may be a slight competitive disadvantage to European wholesalers, it has not reached a point where European wholesalers are likely to import product without front UP. DaimlerChrysler, a leading supplier of European trucks to the Australian market, supply rigid trucks (ATECO range) fitted with side UP. Currently, penetration rate for European articulated truck prime movers is around 20 per cent while that for rigid trucks is around 12 per cent. However, difficulties arise in the provision of safety equipment through self-regulation where a market is small and overcrowded market and where growth is volatile and competition intense. The effectiveness of any option, including self-regulation, depends on the extent to which it achieves the Australian governments’ objectives for reducing underrun trauma in the wider community. In such a market, this objective is can not always shared by business where the primary focus must be on improving profitability. The extent to which self-regulation is effective in simultaneously achieving the objectives of the wider community and business depends on the precise nature and extent of market failure and the general characteristics of the market. In transport markets, the external (social) costs arising from market failure are borne predominantly not by transport equipment firms nor their customers, shareholders or financiers, but by the wider community (and mainly through all the three levels of Australian governments). It is unrealistic to expect business to incur the costs associated with self-regulation, unless they can directly benefit from them. In a highly competitive market, it is difficult to ensure that the administration and operation of self-regulation is transparent. Even a proposed independent self-regulatory authority would find it difficult to administer self-regulation, let alone impose sanctions on business (its own members) that breach self-regulation requirements. The road freight transport industry currently does have self-regulation very much on the agenda. This is to be credited and a number of government studies have found that the long distance road transport industry has made a very significant contribution to the national economy, and demonstrated its capacity for competitiveness, innovation and efficiency. However some aspects of concern to the community still remain and they include: Road safety issues: including the safety of vehicles, compliance with speed limits, controls on driver fatigue, intimidating driver behaviour, and the safety and security of loads; Urban amenity issues, including noise and exhaust emissions and control of heavy commercial vehicle routes; Road damage issues: including overloading and the inappropriate use of lightly constructed roads. Leading on from these concerns, and with pressure from the government, the industry has developed some alternative compliance schemes. Examples include; mass management scheme, maintenance management scheme and national driving hours. No studies are available on the effectiveness of these self-regulated schemes and the legal enforcement initiatives continue to operate through vehicle inspections for mass limits, road worthiness, fatigue and others. Overall, the industry would not be at the stage of being able to implement self-regulation on the fitment of major safety systems such as those for UP. The self-regulation option includes the deletion of the current mandatory regulation for rear UP, ADR 42/04 requirements for rear bumper on semi-trailers. ADR 42/04 prescribes requirements for a rear bumper on semi-trailers. It does not provide any requirements for front or side UP. It is only applicable to semi-trailers and so other types of heavy commercial vehicles are not required to have any similar systems. It has been acknowledged widely in research that a bumper meeting ADR 42/04 requirements would not effectively protect road users from rear underrun trauma. This is due to both strength and geometric shortcomings. Firstly, the regulation does not specify any test to prove its strength. Many of the rigid barriers on semi-trailers bend or twist easily if they inadvertently come in to contact with loading docks. Furthermore, in attempting to accommodate loading dock clearances, the geometric requirements have proven inadequate for underrun crashes. Having a ground clearance of up to 600 mm results in a bumper that is too high off the ground to engage effectively with occupant protection systems in other vehicles. Being up to 300 mm short of the side of the vehicle the bumper would also allow a vehicle to pass under the corner of a semi-trailer with little or no resistance. There is a strong case for withdrawing the bumper requirements in ADR 42/04. To maintain a regulatory requirement for rear UP, which imposes costs on road transport operators without any reduction in rear underrun trauma, could not be justified. There is also a strong case for not developing a replacement. The benefit-cost analysis in Section 1 demonstrated that even a high effectiveness rear UP is unlikely to cover the initial costs of providing it. Option 2: National Heavy Vehicle Accreditation Scheme (NHVAS)Accreditation schemes are good substitutes for law enforcement strategies when the patronage is high, private agents supervising the scheme are frequently audited for compliance and sanctions are maintained at levels that prevent non-compliance. The National Heavy Vehicle Accreditation Scheme attempts to ensure transport operators comply with the law by ensuring that their vehicles are roadworthy and loaded within the relevant mass limits. The Scheme is offered in two modules, one for mass management and second for maintenance. A third module has also been added for fatigue management. The Scheme requires operators to develop an in-house assurance system and document procedures and produce sets of documents that prove compliance. By complying with the scheme which is voluntary, operators are not subject to frequent stops and checks at the road side. The Scheme operates in all three eastern seaboard states and covers commercial vehicles whose GVM exceeds 4.5 tonnes. In Victoria of the 50,000 rigid and articulated trucks with GVM exceeding 12 tonnes, only 120 transport operators comprising of 1000 drivers/vehicles were registered with the mass management scheme. This represents about 2 per cent of the drivers/vehicles. No information was available for the maintenance management scheme. With low patronage, accreditation schemes are unable to guarantee the high field application rate of a design rule that regulatory arrangements offer. Moreover, the lack of uniform application across the fleet can produce competitive disadvantage to those accredited to a scheme. Directory: barreirastecnicas -> pontofocal -> textos -> regulamentos pontofocal -> Ind- 2001 0382 nl- en regulamentos -> Kenya standard ks 06-77: 1978 ics 13. 340 Download 5.27 Mb. Share with your friends:
|