Tuesday, Jan 29, 2019 at 19:01
9900 Eagle: As far as I am concerned, no apology is necessary. The discussion on this thread forced me to look into the subject and learn things that I did not know last week.
nickb: The answer to your last question might be found in some stuff from the Lovells Facebook page which is pasted below.
Frank P: Yes – there was too much Queensland stuff (because that is where I live). Maybe others can contribute from other States/Territories where they live. And yes, it is ridiculous to have so much State-by-State variation – separate rules for vehicle modifications is just a start, add to that separate State-by-State registration of all vehicles, speed limits, road rules, driver licencing, Police Forces, etc, etc, etc. These things derive from our Constitution, so they are not likely to change any time soon, even if many of us think that we have much more “Government” and costs than we need. Happily, all these Governments manage to reach agreement on some standards – the Australian Design Rules (ADR’s), National Code of Practice (VSB14), National Circulars like 0-4-6 (June 2018) and the Clarification of 0-4-6 (03AUG18) which together deal with the Second Stage Manufacture stuff, etc, etc, etc. These are all absorbed into the State regulations – BUT always with some local twists. There was a huge furore in Queensland (there I go again) in mid-2018 and a lot of out-of-date stuff from that time still turns up when us ordinary people do a search – so the confusion lives on. It is noteworthy that the reputable manufacturers have facilities all over Australia and they understand both the National and the State-by-State "rules" (actually, "laws").
cruiser 3: Thanks for starting this thread!!
Here’s a few of Lovell’s recent statements from their Facebook page as a Second Stage Manufacturer with operations and installers all over Australia – so it is not just Qld stuff. Similar
views also can be found coming from other reputable suppliers and installers. This does not make it correct – does mean that all of these outfits are not likely to be openly flouting the law:
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Lovells Springs
August 21, 2018 (Facebook)
GETTING TECHNICAL
Towing Capacity Upgrades and GCM Revision
Contrary to social media and competitors’ spin, Lovells wish to confirm the following which was uploaded to the RVCS website (Federal Dept of Transport and
Infrastructure) on 3rd August 2018.
Of note in this, which is listed at the following (https://
infrastructure.gov.au/…/rvcu-2018-August-issue-3.as…) is to do with Australian Government Administrator’s Circular 0-4-6. (To see the clarification, scroll down to a heading “Release of New Circulars - Administrator's Circular 0-4-6 (Issue 4 June 2018)”
Administrator's Circular 0-4-6 (Certification of vehicles which have undergone a second stage of manufacture) was amended in June 2018 following industry consultation. The circular was amended to include arrangements for Second Stage Manufacture (SSM) Light Vehicles that have been subject to a Gross Vehicle Mass (GVM) upgrade under Clause 10—and formalise current business practice for GVM upgrades to light vehicles.
Of note:
• The guidance provided by the Circular 0-4-6 applies to NA (GVM up to 3.5 tonnes) and NB1 (GVM over 3.5 tonnes and up to 4.5 tonnes) category vehicles.
• The revised circular only applies to new applications and new amendments to existing Identification Plate Approvals (IPAs).
• The Circular will not affect the existing IPAs held by the second stage manufacturers. Existing IPA holders can continue to supply (to the market) vehicles covered by the approved Road Vehicle Descriptors (RVDs). This includes vehicles where the approved RVD has variants that exceed the first stage manufacturer's Gross Combination Mass (GCM) rating or Rated Towing Capacity or Maximum Braked Towing Mass rating. The second stage manufacturers need to ensure that the current approved RVDs refer to the current approved RVDs for the first stage manufacturer.
• The option of GCM or towing capacity upgrade may be available to consumers in some state and territory jurisdictions, after the vehicle is supplied to the market.
In conclusion, we confirm that there is no change to existing SSM Approvals. Any vehicles (as stated in current SSM Approvals and as noted on current RVDs) can still be plated with GVM Upgrades and Towing Capacity Upgrades (BTC upgrades) under the approved RVD. Thus Lovells SSM Approved kits can continue to be supplied.
The implementation of Administrator’s Circular 0-4-6 is effective for all future IPA Approvals. That is, any SSM Approvals applied for beyond the current valid and active SSM Approvals.
Lovells GVM/GCM/Towing Capacity or variants of these modifications remain 100% legal in all States and Territories for all vehicles in service/previously modified.
Lovells GVM/GCM/Towing Capacity or variants of these modifications remain 100% legal in all States and Territories for all vehicles when modified prior to first registration (Federal Compliance).
Lovells GVM/GCM/Towing Capacity or variants of these modifications remain 100% legal in all States and Territories, other than Queensland and NT, for all vehicles when modified after first registration/in service vehicles (State Compliance). State based GCM modifications are governed by the State Authority and their individual Type Approvals or Modification Codes.
Lovells GVM/GCM/Towing modifications have always been legal and we have always strived to ensure compliance with the Federal, State and Territory Regulators.
The whole point of GVM/GCM/towing upgrades is to ensure the ongoing compliance and safety of vehicles and occupants when carrying/towing heavy loads and thus ensuring the safety of other road users.
Despite false reports in some forums and competitor press releases, safety is not an issue. SSM Approval holders can attest to and advise categorically that there is no evidence of any safety issues, accidents or fatalities due to or related to any GVM/GCM/Towing Upgrade.
Unfortunately, all of the SSM Approval Holders who nominate a revised GCM and/or Towing Capacity increase will be affected by these changes in the future, as will any road user who wishes to tow a caravan, boat, horse float etc.
In Summary
• PRE REGO there is no change in plating vehicles with GVM & Towing Upgrades. GCM as defined by the SSM manufacturer
• POST REGO vehicles can be plated with GVM upgrade. The Towing and GCM upgrade would be supported and approved via State Authorities and state based signatories.
• The implementation of 0-4-6 is for all future SSM approvals.
+++++++++++++++++++++++++++
Lovells Springs
September 18, 2018 (Facebook)
MEDIA RELEASE
17th September 2018
Lovells response to Australian Automotive Aftermarket Association (AAAA) statement on Gross Combined Mass re-rating of vehicles:
As the Australian leader in research into Towing Capacity Upgrades and GCM revision, Lovells supports the AAAA in calling an industry-wide
forum on the potential to develop an improved testing protocol for GCM revision.
Lovells will bring to the
forum its experience of the extensive testing regime that it has undertaken to prove the safety of upgrades – on the basis of advice received from the Federal Department of
Infrastructure, Regional Development and Cities (DIRD) and undertaken in DIRD-approved testing facilities.
It is misleading to claim, as AAAA does, that a SSM, “can simply nominate an increased Gross Combination Mass (in addition to the increased GVM), without the requirement for any testing or evidence to ensure the vehicle can operate safely at the new nominated capacity”.
The fact is that Lovells nominates a GCM based on an investment of hundreds of thousands of dollars, and many years, in research and testing in accordance with relevant ADRs; with not one report of a safety issue or catastrophic failure.The rigour of our testing speaks for itself.
Some of this testing is required by Federal and State laws and some testing has been conducted under the guidance of engineering experts, as no official Australian Standards exist. Many of the independent engineering companies we utilise (five different companies and points of
views) have vast experience in towing and GCM testing. Two of our consultants have worked with Mitsubishi Aust and GMH and are experts in their field.
Lovells’ testing has been undertaken on guidance from DIRD on how to approach a towing upgrade, and has included the extrapolation of Heavy Vehicle Standards to light vehicles.
This has included purchasing complete chassis systems which have been load tested and analysed over many years at DIRD Approved
Test Facilities.
These tests were carried out in accordance with the relevant ADR’s and engineering data and evidence was intricately compiled.
Lovells has independently tested our 5T off-road hitch, which forms an integral part of our towing upgrades. This included static load testing and durability testing using the applicable ADRs by a recognised DIRD and NATA Approved
test facility.
Lovells has applied for and been granted a CRN (Component Registration Number) and SSM Approval for towing upgrades with DIRD and the relevant Road Vehicle Descriptors (RVD) are still active on the Dept of Transport’s RVCS site, which is publically searchable.
Lovells determines its GCM figures on the basis of extensive engineering data including FEA (Finite Element Analysis) for chassis, towing points, axles and driveline components including dynamic brake and thermal testing, beyond the ADR requirements (as there is no recognised procedure in Australia), which backs up our revised GCM figures.
Original Equipment Manufacturers are not required to disclose their data or evidence for GCM or towing capacities to DIRD or any other State or Federal Department. This is critical and sensitive IP, so there is no reason, why Lovells should, as a SSM, have to disclose their data or evidence for GCM capacities.
Original Equipment Manufacturers are liable for their engineering decisions, capacities and the vehicle being fit for purpose.
As a Second Stage Manufacturer, Lovells is also liable for our engineering decisions, capacities and the vehicle being fit for purpose.
Lovells has solid engineering and
test evidence regarding Towing Upgrades and GCM Revision including 17 years’ experience in the field with zero evidence of safety issues, accidents, thermal failures or catastrophic failure of any OE critical component. This includes in excess of 10,000 upgraded vehicles in the field both in Australia and overseas.
In anyone’s terms, this equates to solid evidence.
One more point: Lovells disagrees entirely with the AAAA’s view that “the key issue is not whether a GCM upgrade on a particular vehicle is safe or unsafe, but the fact that there is no agreed method of validating this”.
Safety will always be Lovells’ first priority. The key issue will always be safety.
That is why we are the Australian leader in research into Towing Capacity Upgrades and GCM Revision.
++++++++++++++
The above items separated by the +++++++ lines are Lovell's words, not
mine.
Cheers!
Indrocruiser
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