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



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Option 6: Business-as-usual

The current situation would remain unchanged and so there would not be any new regulations introduced nor any existing regulations removed. The only regulated Underrun Protection (UP) would be a rear bumper for semi-trailers as currently required by Australian Design Rule (ADR) 42/04 General Safety Requirements.


Option 7: Australian Design Rule adopting front Underrun Protection regulations from Europe, Japan and United States

Only the European Union and the UNECE have front Underrun Protection (UP). Japan and the United States do not have any specific requirements for front UP. As Japan is a signatory to the 1958 Agreement, it is most likely to apply UNECE R 93 in the near future. Japan, United States and Canada mandate the provision of side and rear UP. As the provision of side and rear UP was demonstrated earlier to not provide any net benefits to the community, this option will not be assessed any further.


Option 8: Australian Design Rule adopting international standard UNECE R 93 for front Underrun Protection for rigid and articulated heavy commercial vehicles with a GVM greater than 7.5 tonnes

UNECE R 93 Front Underrun Protection (UP), is the relevant regulation for application to front underrun crashes involving heavy commercial vehicles. The regulation is annexed as a part of the 1958 Agreement and its requirements are available for application as an Australian Design Rule. This option meets the Australian government’s objective of adopting international standards for the construction of motor vehicles and trailers. A copy of the regulation is attached at Appendix 9.


The VC- COMPAT program, a European Union safety initiative under the EU Frame Works Research Program, is currently reviewing Regulation No. 93 and technical requirements from the research program are expected to be available in 2006.

  1. Impact Analysis

Background to the Heavy Commercial Vehicle Industry

The heavy commercial vehicle industry in Australia is made up of heavy commercial vehicle assemblers, importers, and sub-assembly suppliers. Industry revenue for 2003-04 was nearly $15 billion, while for trailers it is estimated at $2 billion.


Locally built heavy commercial vehicles account for around 16 per cent of the total number retailed in 2003 with the remainder mainly from Japan and Europe. The European Union is a key supplier of prime movers along with Australian made heavy commercial vehicles such as Kenworth, Mack and International. The industry displays a high level of globalization. However, trailers from Japan, Europe and the USA are rarely supplied to the Australian market.
In Australia, there are five main operating classes of heavy commercial vehicles. These are:


  • Rigid commercial vehicles

  • Rigid commercial vehicles with trailers

  • Semi-trailers

  • B-Doubles

  • Road trains

More detailed information regarding the industry and types of vehicles can be found at Appendix 2.


The Affected Parties


Parties directly affected by the proposed standard are:

  1. Rigid and articulated heavy commercial vehicle manufacturers and importers; trailer manufacturers;




  1. Sub-contractors designing and supplying components used in the manufacture of rigid heavy commercial vehicles, prime movers and trailers;




  1. Consultants providing vehicle certification and compliance services to heavy commercial vehicle manufacturers, trailer manufacturers and road freight operators;




  1. State and territory transport agencies performing a regulatory, review or oversight function; and




  1. Road freight operators;

A detailed table listing all affected parties is provided in Appendix 7. Several interest groups represent the affected parties and these include:



  • Heavy commercial vehicle assemblers and importers are represented by the Truck Industry Council The sector comprises heavy vehicle assemblers, heavy vehicle importers and component manufacturers/importers;



  • Suppliers of trailer components are represented by the Australian Road Transport Suppliers Association;



  • Suppliers of vehicle certification, design and testing services are represented by the Commercial Vehicle Industry Association of Australia;



  • Heavy commercial vehicle distributors are represented by the Motor Traders Association of Australia ;



  • Motorist clubs (membership drawn from passenger car owners) are represented by the Australian Automobile Association;





  • Motorcycle owners are represented by the Australian Motorcycle Council;



  • Bicycle owners are represented by the Bicycle Federation of Australia;



  • Pedestrians are represented by the Pedestrian Council of Australia;





  • Other interest groups operating largely in the after market, are represented by the Australian Automobile After-market Association.



Impact on Existing Regulations

The only current requirement in the Australian Design Rules for heavy commercial vehicles is for a rear Underrun Protection (UP) for semi-trailers in Australian Design Rule 42/04 Rear Bumpers for Semi-trailers. The retention of this standard has been discussed later in this RIS.


The introduction of any effective UP requirements would increase the effectiveness of current crashworthiness regulations for other vehicles.

Impact of the options



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