Option 1: Self-Regulation (of front, side and rear Underrun Protection)

State/Territory/Local

By encouraging the fitment of UP devices through self-regulation, the costs of medical treatment and hospitalizations are likely to reduce following a decrease in underrun trauma. The estimated savings are approximately $7.9m per year, based on an assumed 15 per cent voluntary take up of UP.

Industry

By encouraging the fitment of UP through self-regulation, European manufacturers may find that they have a competitive advantage over manufacturers from other countries. This is because they would have had experience in designing and manufacturing UP. However, because Australia relies on overseas heavy commercial vehicle manufacturers for over 90 per cent of its transport equipment requirements, self-regulation may also introduce varying requirements across the fleet with some standards (including in-house) being less effective or untried. If this were to happen, all heavy commercial vehicle makers may find it difficult to sell product in to a confused or sceptical market. This benefit has not been estimated.

Consumers

Installation of front UP would on average reduce downtime and liabilities for heavy commercial vehicle operators (through less trauma from road crashes). There would also be reductions in road trauma which may lead to reductions in insurance premiums for all road users. This benefit has not been directed estimated but would form part of the benefit attributed to State/Territory and Local government.

Likely Costs

Government

Australian/State/Territory/Local Governments

In removing the requirements in ADR 42/04 for fitting a rear bumper for semi-trailers, there would be no cost (in terms of a loss of a benefit) to road trauma reduction. This follows on from the argument earlier that these rear bumper requirements are ineffectual.

The Australian government may need to work with industry to identify appropriate voluntary specifications for underrun systems. This would assist in achieving the government’s objective of reducing the cost of heavy vehicle underrun trauma. The government may also have to put systems in place to monitor the take-up of these voluntary specifications. The cost to do this has not been estimated.
Costs may accrue to states and territories as part of the effort towards monitoring the take-up of UP for heavy commercial vehicles as well as underrun trauma costs. These costs have not been estimated.

Business/Consumers

In encouraging the fitment of UP through self-regulation, manufacturers who are not European may find that they have a competitive disadvantage against manufacturers from Europe. These costs have not been estimated.

There would be additional costs to heavy commercial vehicle suppliers and trailer manufacturers for designing, manufacturing and installing UP. These costs may be passed on to the consumer. The estimated costs are approximately $3.4m per year, based on an assumed 15 per cent voluntary take up of UP. These may be passed on to road transport operators.
Distributional Effects
The benefits from Option 1 would be gained by the community in the reduction of road trauma and road transport operators in the reduction of downtime and liabilities. Industry and government may gain slightly on reduced certification costs and some parts of industry may gain some competitive advantage in being able to supply UP more efficiently that their competitors.
The costs from Option 1 would be incurred by business in the increase costs of supplying UP. These costs may be passed on the consumer. Industry and government may also incur some costs on facilitating and monitoring any voluntary arrangements.
Discussion and Conclusion for Option 1
Option 1 estimated that if industry is encouraged to fit front, side and rear UP through self-regulation, the benefit/cost ratio would be positive with a net return of about $4.5m per year.
However, this option would be unlikely to achieve fully the government’s primary objective of reducing costs from road trauma, and particularly those of the National Road Safety and the National Heavy Vehicle Safety Strategies. Although the benefits and costs were calculated on an assumed take up rate of 15 percent, the option would be voluntary and so in fact there would be no guarantee that UP would be fitted to any heavy commercial vehicles.
This is partly due to an environment where profits are shrinking (profit margins are around 4 per cent), competition is increasing, growth of road freight is slowing and more commercial vehicles are running empty. Operators would be looking for savings to sustain their businesses and in the main would only install equipment which is essential for meeting regulatory requirements. In addition, provision of front UP may add some extra mass to the vehicle and this may impact on operator revenue. This impact may be limited but in a highly competitive industry it may have some negative effect. These are key factors which would determine the field effectiveness of self-regulation as a measure for providing UP.
The response of heavy commercial vehicle makers who are facing shrinking profits may be to discontinue the provision of UP. The supply of heavy commercial vehicles complying with a (say) code of practice would be a cost to road freight transport operators if their trade association or consignors insist on operating heavy commercial vehicles with UP. Although it is expected that on average there would be a reduction of downtime and liabilities for heavy commercial vehicle operators (through less trauma from road crashes) to offset this cost, this benefit would not be obvious to freight transport operators in the short term.
Table 12 provides a summary of the benefits and costs of Option 1.

Table 12: Costs and Benefits : Option 1- Self –Regulation (of front, side and rear Underrun Protection (UP))

	BENEFITS		COSTS
	Description	Estimate	Description	Estimate
Business	Increased competitive advantage for some (15%) heavy commercial vehicle manufacturers meeting market demand for UP Reduced design, manufacturing and certification costs for trailer manufacturers not required to fit ADR compliant rear bumpers for semi-trailers (deletion of requirement in ADR 42/04)	unable to estimate unable to estimate	Decreased competitive advantage for some (85%) heavy commercial vehicle manufacturers not meeting market demand for UP Increased design, material and manufacturing costs for some Australian, Japanese manufacturers for choosing to meet market demand for UP 2. These may be passed on to road transport operators	unable to estimate $3.4m
Consumers	Reduced road trauma for all road users 3 Reduced insurance premiums for all road users Reduced downtime and liabilities for heavy commercial vehicle operators	$7.9m unable to estimate
Government	Reduced need for public resources such as emergency services etc Reduced certification costs for not administering the approval and maintenance of ADR compliant rear bumpers for semi-trailers 4		Increased costs to assist industry with voluntary specifications for UP and monitoring application rates.	unable to estimate

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: