My original intent was to have my say and leave it at that, but
as all the responses are well considered and sensible I thought I would reply
to as many points as I can. However, let
me say that I would not for one second suggest anybody else do what I have done
without making sure that they have checked to their own satisfation that this
is correct.
Prof John L: You are the
third contributor to openly make this claim about MTPLM. Neither of the others
have been able to point to the legislation that discounts the caravan
manufactures specification as defined by thier data plate.
PS: No and nor can I,
because it doesn’t exist. The point is
that there there is no legislation that requires the MTPLM to be regarded as a
legal requirement. In fact, there is no
reference to the term MTPLM in any VOSA sources that I can find.
Prof John L: Please bear in mind that MTPLM has the same
meaning as MAM,MAW, and GVW, so are you infering that these are also to
be ignored also?
PS: On that I
disagree. The MTPLM is stipulated by
whoever fits the body on the caravan and subsequently markets it. The chassis manufacturer, on the other hand,
sets the legal weight limits (MAM, MAW, GVW) which are set out on the plate on
the chassis. As the chassis
manufacturers only produce a limited number of chassis configurations (length,
width, weight capacity etc.) the caravan manufacturers will chose the one
closest to their required configuration and then, quite understandably, set an
MTPLM that offers the widest possible market for their product. And this
is why, manufacturers can provide plates upgrading the MTPLM with no more in
the way of documentation than a cheque for £30.
Prof John L: This is a
very perplexing issue as despite extensive searches I have never found any
official document that should give rise to this suggestion that manufactures
data plates are to be ignored.Can you please identify the documents that give
rise to your conclusions.
PS: I have to agree with
you there. But again, no there is no
legislation saying that manufacturers data plates have to be followed
either. There is legislation regarding
VIN plates on cars and on the chassis manufacturers plate, but that is a
different matter altogether.
Prof John L: I currently beleive your contention is wrong,
simply because the manufactures should be the best people to know what their
products are designed to do, but I am not averse to changing my view given
verifiable evidence.
PS: An eminently sensible
stance. In fact it was that paragraph
that persuaded me to respond. I knew
this might be a bit contentious and, as a newbie, if I had been simply told I
was talking nonsense I would have let the topic drop. Equally, if someone proves to me that I am
wrong – which is far from unknown – then I will recant.
Colin-yorkshire: (edited) the total upshot of it
was, that the trailer chasis weight is the legal requirement not
the whole trailed weight. (with previso) as the boat sat on it was just the
load, the previso was that the trailed tow load was under the GTW of the towing
car and the trailer chasis weight was not exeeded,
but
even though I do understand the principal I would NOT risk it as I believe that
the authoties view caravans differently from other trailers simply because the
load is fixed to the chasiss and issued with a weight plate separate from the
chasiss weight plate that it is built on, the MTPLM or MAM is fixed
by the van manufacturer and deemed to be that maximum weight, as far as I am
aware the weight plate is a legal requirement, on caravans and the reason
manufacurers will issue another FOC if it is damaged or faded. it can be
increased or decreased on application for a fee but that does not negate the
need to have one. weight isses are
complex enough without adding other dimentions to it.
PS: As your friend found out, these things need
to be argued in court, which may well happen.
But I would disagree with you that the authorities view caravans
differently. The law dosen’t work like
that. A trailer is a trailer and
although there are some differences in the legislation for trailers that do not
carry loads – generators and the like – the authorities cannot cherry pick
which bits they want to apply just as it suits them.
Much of my
research was done on the phone because getting anyone in a government
department to commit to anything in writing is close to impossible.
Gafferbill: ........a trailer or
a caravan has the MTPLM or (MAM,MAW,GVW) fixed by the manufacturer and they must by law fix a plate to the trailer or caravan
stating what this is.
PS: The question
has been raised as to where it says in law that a caravan manufacturers plate
isn’t a legal requirement? As I’ve said,
it doesn’t. So, where does it say, in
law, that you do have to have one? And
yet again, why is the MTPLM being taken as exactly the same thing as the
MAM,MAW or GVW?
Gafferbill:
Nobody is entitled to change this except the
manufacturer who sometimes will increase the amount for a caravan when
requested to do so. They will issue a new plate showing the new MTPLM to comply
with the law.
PS: Who says so?
Gafferbill: They can do this because they buy in the chassis
upon which they build the caravan and this chassis can almost always carry a
greater load, provided suitable tyres are fitted.
Only
the manufacturer knows if the structure of the caravan built on that chassis is
capable of taking the extra load.
Tom,
Dick or Harry cannot come along and decide that because their twin axle caravan
has a chassis that can carry 2100kgs, then it is OK to carry a 450kgs payload
over and above manufacturer stated MTPLM of 1650kgs.
A
manufacturer of a specialist trailer such as a boat trailer or a general
purpose trailer, will construct and design it to carry the load up to the
trailers plated MTPLM.
PS: Again, this is the
generally held opinion, but that doesn’t necessarily make it so. Chassis manufactures will, of course, allow a
hefty safety margin and so do the manufacturers of the bodywork. Elddis would provide me with a new plate – we
didn’t get as far as how much they would up-grade – for £30, if the van were
newer. I believe (from another source) that they would have provided me with
900kgs on the caravan if it had been a year newer. That happens to be my self-imposed limt. I find it difficult to believe that the
safety margin built into a caravan isn’t sufficient to allow a ten per cent
invrease over that 1900kgs without becoming unsafe.
Wee Jock: Without
having the time to research this to the nth degree as some of you I will throw
in a few points.
My
experience is mainly with goods trailers and as a cpc holder of more than 20
years whom has had a few appearances due to drivers running incorrect axle
weights etc this would lead me to agree with most of what has been said before.
Plated axle weights cannot be exceeded neither can plated gross weights. Call
the terms by whatever you wish but to me that plate by the door equals the same
plate attached to my work trailers and trucks by VOSA. Yes these weights can be
changed and replated but what is there at the time is what is in force.
For
those of you who think these are not binding please check various other threads
on here re license requirements. You will see there that the max allowed
trailer weight is used when working out the maximum train weight for drivers
license re whether they need a B+E etc. This is also why manufacturers may
choose to use lower limits than the trailer is capable of. To suddenley think
you can switch between them as suits is daft, either that or I need to be
thinking about using you for legal services.
PS: I agree with what you
say in that the trailer plate is legally binding, as is the one on the chassis
of my cravan. The fact that it is not
the same as the one by the door is where my argument lies. The one by the door serves as a quick
reference, and VOSA may even prosecute on the strength of it. They’ll probably win too unless
challenged. However, if it is not there,
or even replaced by another plate with the chassis and axle limits (on a TA)
then they will go by that.
No, I have no written proof of any of this, anymore than there
is any written proof to the contrary and most of my information was, as I have
said, gathered from lengthy telephone calls to various people in VOSA. And the over-riding impression I got was that
the whole thing will only become clear if there is a test case and it is
unlikely that VOSA would want to go down that route.
Prof John L: (edited)
In a similar vein its like a car where the manufacture
states an MAM of 2000Kg but the sum of the tyre load indexes adds up to 2400Kg
being allowed to run at over 2000Kg. Its an unsafe engineering solution because
the weakest links limit has been exceeded. It is also highly unlikely because
we know the authorities stick to MAM for motor vehicles. I cannot see them
changing that principal for trailers.
PS: I don’t think
the two are really the same thing. Many
commercial vehicles – possibly cars too – have the axles with sum of the axle
loads at a higher rate to allow for reasonable load distribution. It would be almost impossible to load a van/truck
to its maximum weight without this and that would make the van very
inefficient.
In the case of my caravan chassis the gross weight allowed
is 2100 kgs and the axles are both on the plate and individually stamped at
1050kgs. In my opinion that immediately
knocks 100 kgs off the gross weight because if the caravan is to have any
noseweight the front axle will need to be taking a bit more load than the back
axle. So, assumng I could load the
caravan accurately enough to get 1050kgs on the front axle then the back axle
is going to have a bit less.
Prof John L: In the light of
these claims of VOSA ignoring manufactures MAM specifications I would like to
be able to ensure that any future advice I give is accurate. To do that, I need
to be able to see sight of the regulation or legislation that directs the
authorities to work in that manner. So far no-one has supplied links or
information that points to an official document instructing VOSA to work in
that way.
PS: I didn’t say
that VOSA was ignoring the MAM plates, I said that the MTPLM plate had no real
value in law. However, if the MTPLM
plate is missing then VOSA will check the trailer manufacturer’s MAM plate
which is legally binding.
Prof John L: One menber has
claimed he has posted evidence, Unfortunately I do not recall it and the forum
search facility is of no practical help or perhaps it was not definative or
verifiable, but he seems reluctant to repost it, which is a shame, becasue it
might be whats needed to put this matter to bed.
PS: I don’t see how
they can have posted evidence. I could
find nothing in writing that verified this one way or the other.
Prof John
L:
Until that evidence is actually forthcoming and verified, the
only safe option is to continue to assume that the bodywork manufactures
specifications take precedence over the individual parts suppliers
specifications.
PS: Despite what I have
said, this probably is the best option.
My point was that I have decided that I am satisfied that what I am
doing is both legal and safe and will continue to do so. I wouldn’t want anybody to follow in my
footsteps without having satified themselves that this is all OK.
I suppose my other point in starting this was that we live in a
world where there are so many assumptions that things are ‘the law’ when they
are not. How many times have you heard
it said that the ‘85% rule’ was the law?
I’ve even met someone who was told by a dealer that cravans had to be
white, by law. That I could almost believe.
Anyway, if this goes no further, many thanks for an interesting
and well thought out debate.
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