Caravan MoTs

[otherclive]

Dont forget that in early September the European Parliament will be discussing the proposals to introduce road worthiness testing of trailers which will include caravans above MAM of 750kg, but trailers above 2000kg. When the EC proposals were first debate earlier this year it was confidently predicted that caravans below 2000kg would be exempt...how wrong the 'experts were.
Writing now to your MEP via the Write to Them website may help to influence the outcome. I have also sent my local MP a copy in case he feels that he can influence views via the party links. Below is a copy of my input which can be cut and pasted if required. For the sake of a few minutes it might be sufficient to make a difference. And dont forget there are European Parliament and UK national elections in the not too distant future and I am sure that potential redundancy would not be a lifestyle choice for our elected representatives!!

Dear William (The Earl of) Dartmouth, Ashley Fox and Trevor Colman,

Caravan/Trailer MoT

I am sure that you are aware that the European Parliament has put
forward an amendment to the EC proposals for trailer and caravan road
worthiness tests that would introduce MoT-style tests for caravans. If
the proposed changes to current legislation become law they will affect
all caravans with a mass over 750kg, which is virtually 100% of UK
caravans.

A UK DoT study showed that only one percent of all accidents ( and less
than 1% fatalities) involved a towed unit (of any kind) and the
majority of those weighed more than 3500kg. Costs for UK registration
alone have been estimated to be more than £230m and this did not
include operative training or the required infrastructure.

The main causes of accidents involving trailers/caravans are
overloading, poor weight distribution, poor car-caravan weight match,
tyre age/condition and driver error and inappropriate sped for the
conditions. None of these factors would be addressed by the proposed
trailer/caravan road worthiness testing.

Caravans have been unfairly singled out with a weight limit above
750kg, whereas other trailer tests would start at above 2000kg. There
was no supporting evidence for this decision which I understand was
contrary to the EC proposals.

I would seek you support in the forthcoming discussions to oppose this
measure when the evidence does not support its introduction. The money
could be better spent on driver education and training. With the UK
rules on B&E group licences and the associated training and testing
that drivers have to undertake it is quite clear that the standards for
towing demanded of drivers have been raised and it is expected that the
UK's present excellent safety record for trailers/caravans will
progressively lead to even fewer accidents in the future.

Yours sincerely,

 

[Surfer]

This has been done to death on numerous occasions and the government is resisting it so not much point in writing.

 

[otherclive]

What do you mean by the government is resisting it? Do you mean they are against the EP proposal or that they are resisting the efforts to take caravans under 2000 kg out of the proposals? If its the former then I don't hold out much hope based on the UK track record on resisting EU legislation being introduced into UK law. If its the latter then knowing that there is considerable opposition may strengthen their resolve.
I am aware that there has been much previous correspondence on this issue but I raised it now following a call by the C&CC Director General that it was worth once again reminding your MEPs that this is a proposal that has minimal cost benefit. It would not pass the ALARP test!

 

[Dustydog]

Forget The British Parliament. What The EU says goes and that's that whether we like it or not.

Clive's proposed draft letter to our MEP is needed, if you do it a few months ago when this subject first reared its head.
The cost of "caravan mot stations won't be cheap and you guess who will pay for it. Grrrrrrrr.

 

[RogerL]

The UK Government can opt out of EC legislation, if it has a mind to - for the moment HM Government is on the side of common sense.

 

[Surfer]

What do you mean by the government is resisting it? Do you mean they are against the EP proposal or that they are resisting the efforts to take caravans under 2000 kg out of the proposals? If its the former then I don't hold out much hope based on the UK track record on resisting EU legislation being introduced into UK law. If its the latter then knowing that there is considerable opposition may strengthen their resolve.
I am aware that there has been much previous correspondence on this issue but I raised it now following a call by the C&CC Director General that it was worth once again reminding your MEPs that this is a proposal that has minimal cost benefit. It would not pass the ALARP test!

As per Roger's post. The UK government has resisted it from the start. I have posted previously a detailed study by the government why it is not worth them implementing a MOT for caravans. Here it is again in case you are interested. http://www.publications.parliament.uk/pa/cm201213/cmselect/cmeuleg/86-xv/86xv.pdf For once the government is on our side!

 

[otherclive]

Thanks Surfer,
I had read your link when the issue was raised earlier in the year. Despite what some may say the UK Government cannot opt out of all EU laws, it all depends on what area of EU legislation it comes under. However, shudder the thought, the UK government does have the means to decide how to implement a Directive, whereas for a Regulation it is the same as an Act of Parliament and is mandatory on all member states. In many cases the UK bureaucracy is wont to 'gold plate' Directives without any real thought given to the cost-benefits, whereas other nations often take a more pragmatic, and cost-effective approach. Unfortunately in such cases the EU gets blamed for something that was basically under UK Goverment control. However as I understand it the Roadworthiness Testing is planned as a Regulation. Only if it contains specific links to criminal law would UK have 3 months to decide whether to opt in. Reading the proposed Regulation and its many amendments I see no reference to criminal penalties so that opt in would not be relevant.
Let's hope that in the forthcoming discussions caravans get moved to the over 2000kg limit.

 

[Surfer]

Thanks Surfer,
I had read your link when the issue was raised earlier in the year. Despite what some may say the UK Government cannot opt out of all EU laws, it all depends on what area of EU legislation it comes under. However, shudder the thought, the UK government does have the means to decide how to implement a Directive, whereas for a Regulation it is the same as an Act of Parliament and is mandatory on all member states. In many cases the UK bureaucracy is wont to 'gold plate' Directives without any real thought given to the cost-benefits, whereas other nations often take a more pragmatic, and cost-effective approach. Unfortunately in such cases the EU gets blamed for something that was basically under UK Goverment control. However as I understand it the Roadworthiness Testing is planned as a Regulation. Only if it contains specific links to criminal law would UK have 3 months to decide whether to opt in. Reading the proposed Regulation and its many amendments I see no reference to criminal penalties so that opt in would not be relevant.
Let's hope that in the forthcoming discussions caravans get moved to the over 2000kg limit.

What is grossly unfair is that horse boxes and other trailers are not included in the legislation. I think I have seen more horseboxes involved in accidents than caravans. Unfortunately when a horsebox is involved, more than likely the horse is injured. On more than one occasion the animal has escaped and run across the motorway causing even more havoc.
In all cases I would think that a horsebox that is being towed exceeds the maximum kerbweight including drivers etc of the towing vehicle by a good margin making it an unstable combination. However you wil fin that many MEPs have horses so that legislation will never happen!

 

[ChrisUK]

I'm synical about horeboxes and landowning MP too.
An MOT would surely have to also mean caravan registration? This might dramatically reduce the number of vans stolen. At a registration cost and annual cost ++++

 

[Parksy]

Cars are registered but they continue to be stolen.
The danger is that caravan MOT's will be the thin end of the wedge and registration would be used for government revenue raising purposes, another stealth tax.

 

[Surfer]

Cars are registered but they continue to be stolen.
The danger is that caravan MOT's will be the thin end of the wedge and registration would be used for government revenue raising purposes, another stealth tax.

Not sure why you think that as it would mean the government would have to tax mobility scooters, electric cars and scooters, horseboxes and all trailers which would make the government very unpopular.
Implementing a MOT system would cost millions and to recoup just the initial outlay would probably take several generations which is why the government is fighting the proposal.

 

[ProfJohnL]

The Government may have stated it is against the proposed testing of trailers, but unfortunately we have seen on a number of previous occasions that despite the will of the people or the stated intention of the Govt' the EU has sometimes steam rollered through.
I know my personal views will not find favour with every one, but I do think that some form of formal testing of the roadworthiness of trailers should be checked, otherwise we a reliant on the technician who carries out the maintenance on the caravan, and as far as I know no caravan service centre has a dynamic brake testing set like an MOT centre.

 

[Surfer]

The Government may have stated it is against the proposed testing of trailers, but unfortunately we have seen on a number of previous occasions that despite the will of the people or the stated intention of the Govt' the EU has sometimes steam rollered through.
I know my personal views will not find favour with every one, but I do think that some form of formal testing of the roadworthiness of trailers should be checked, otherwise we a reliant on the technician who carries out the maintenance on the caravan, and as far as I know no caravan service centre has a dynamic brake testing set like an MOT centre.

If a MOT for a caravan only is introduced and other trailers are exempt, that in essence means a segment of society are being discrimnated against. Also if it is introduced it should be either 2 or 3 year between MOTs due to low mileage of caravans.

 

[Dustydog]

A Dynamic Brake Testing Set for a Twin Axle is mind blowing

.
The cost, space and complexity

.
This is just another ill conceived , ill founded EU generated idea.
At the risk of upsetting the DIYers I'd certainly support a simple scheme where a qualified caravan engineer, mobile of dealer, has to carry out a full service on ALL aspects of the caravan including gas electric etc.
Surely that is more than enough and a vast number do that now anyway.

 

[RogerL]

A Dynamic Brake Testing Set for a Twin Axle is mind blowing

.

They'll just test one axle at a time - like cars !

 

[ProfJohnL]

If a MOT for a caravan only is introduced and other trailers are exempt, that in essence means a segment of society are being discrimnated against. Also if it is introduced it should be either 2 or 3 year between MOTs due to low mileage of caravans.

I do not envisage the testing being limited to caravans, it would be for trailers of which caravans are a small subset. As to the which ones: over 750MAM or with brakes has been mentioned, and possibly over a certain physical size, could be the criteria.
As for test interval, I agree 12months is perhaps over zealous, but who can tell. this is after all the EU beaureaucrats we are talking about. To make it workable there would need to be some form of trailer registration so the authorities can track compliance.

 

[RogerL]

Recently, the EC bureaucrats wanted car MoTs set to every two years - after a long campaign the UK government agreed to retain the one year MoT although the items tested changed in line with other EC countries.
So the precedent is there for HM government to opt out of trailer MoTs, or indeed just part of it - while EC bureaucrats aren't known for being predictable there's every likelihood that they'll press for a two year trailer MoT - there can't be many reasons why trailers need testing more often than cars!
Forget MEPs, the EU legislation is a lost cause - focus on MPs and UK ministers to ensure that the UK opts out of trailer MoTs.

 

[Dustydog]

A Dynamic Brake Testing Set for a Twin Axle is mind blowing

.

They'll just test one axle at a time - like cars !

But there 's hardly any distance between the axles unlike a car.

 

[Raywood]

On looking at articles on the subject quite a few forms of trailer are missing. As someone who has been heavily involved in handling claims for accidents both in the office and out on thye road I cannot remember any accident involving a caravan that would have been prevented by an MOT type inspection and as a caravanner I do look at accidents involving caravans. The only type of trailer that was regularly involved due to poor maintanance was farm tractors.

 

[RayS]

Well said Raywood. At the start of this episode I contacted our MP who happens to be in charge of DEFRA and pointed out that many farmers in his rurual constituency whould be affected. I have also drawn the matter tothe attention of farmers in several parts of the country and through them to the NFU.
While the caravanning fraternity should continue to lobbly, there are many more farmers and they probably form a more influential group, so spread the word through any agricultural contacts you may have.

 

[Surfer]

Well said Raywood. At the start of this episode I contacted our MP who happens to be in charge of DEFRA and pointed out that many farmers in his rurual constituency whould be affected. I have also drawn the matter tothe attention of farmers in several parts of the country and through them to the NFU.
While the caravanning fraternity should continue to lobbly, there are many more farmers and they probably form a more influential group, so spread the word through any agricultural contacts you may have.

Trailers are NOT included in the MOT proposal, only caravans which is what makes it so one sided!

 

[hortimech]

What is more, agricultural trailers are explicitly exempt, so they can be falling to bits, have no lights etc and they still will not have to be tested!

 

[RayS]

I have just received from my MP David Heath a copy of a letter to him from Stephen Hammond Under Secretary of State at the Deptartment for Transport. This is a reply to a letter sent by Mr Heath following my earlier letter to him on this matter.

I quote parts of the letter from Mr Hammond.

"The text proposed by the European Parliament is that trailers over 2000kg would require testing as would caravan trailers over 750kg. There are further exemptions for agricultural trailers"

"I am in full agreement with your constituent in that the Commission have not provided evidence that the testing of caravans will actually make a significant contribution to road safety. For that reason i opposed the inclusion of testing of all trailers less than 3500kg at the transport council last December. As the position of the MEPs is some way off the position agreed by the Council of Ministers the Presedency will be seeking a compromise position. My officials will continue to oppose the testing of caravan trailers in those negotiations"

A little later "the only further suggestion I can offer is that he ( i.e.me) should write to Werner Kuhne as the Rapporteur of the Committ on Periodic Technical Inspection. His email address is werner.kuhn@europarl.europa.eu"

So it seems that the UK government has put up some opposition and that the matter is not yet fully decided. I shall certainly write to Mr Kuhne (probably twice, as I see there is a difference in spelling his name between the text and his email address).

It seems ironic that exemptions are proposed for agricultural trailers when simple observation will showm many of these to be far less roadworthy than the vast majority of trailer caravans. Obscured number plates, no or malfunctioning lights, tyres with poor tread or inflation, overloaded, shedding loads are just a few of the faults seen by standing at my front gate for an hour today. The exemptions also remove most of the farming comuninity from our cause.

 

[Raywood]

Any improvement to road safety would be so small as to be immeasurable. I doubt that even farm tractors being required to be tested would make a noticable difference, this is one of the the most useless wastes of public money ever and that takes some doing. They have simply invented a problem that never existed.

 

[otherclive]

Recently, the EC bureaucrats wanted car MoTs set to every two years - after a long campaign the UK government agreed to retain the one year MoT although the items tested changed in line with other EC countries.
So the precedent is there for HM government to opt out of trailer MoTs, or indeed just part of it - while EC bureaucrats aren't known for being predictable there's every likelihood that they'll press for a two year trailer MoT - there can't be many reasons why trailers need testing more often than cars!
Forget MEPs, the EU legislation is a lost cause - focus on MPs and UK ministers to ensure that the UK opts out of trailer MoTs.

As I said in an earlier post this is being introduced as a Regulation which is mandatory within the EU and unlike Directives Regulations are common across all member states. In theory you could have the test carried out anywhere in the EU. The UK can opt in/ out of Regulations if they impact on our criminal justice system. But reading this one I cannot find any link to that system. The best hope is that the Council of Ministers puts it back to what was originally mooted which was not testing of trailers under 2000kg.

as I said in my earlier post