Towing Mirrors- The Law - E marks

[LMH]

Never have been a fan of Milenco gear, E marks along with posts here appear to be profit orientated.

Where are all the dead and injured from mirror accidents?

Nigels data also comes from the same government that pedals Speed Cameras as a life saving aid rather than the truth, Cash Cow!

Scare and mug motorists again with yet more legislation.

We've used same caravan mirrors for over twenty years as they do a better jobs than Milenco and others on the market today, they have also been dropped and swiped hard by other vehicles with out breaking.

No doubt I'll be unable to sleep now.

According to Nigel's data getting on for 60O caravanners have died and nearly 3000 will have been seriously injured due to caravan mirrors in our time caravanning no doubt we have missed this news on sites and in the caravanning press

Note ; Nigel says nothing of the size of the industry around changing E marks and type approval regs and of the potential benefit to him if we all go and update our perfectly fine mirrors.

Also what is the eco cost re change for change sake more landfill, plus more bonus in Niges pocket maybe

Thanks Jason

Lisa xx

 

[BrianStAlbans]

What I do find interesting is this..

5.2 Compliance costs for a typical business

5.2.2 Mirror Manufacturer: The proposals do not require any changes in the specifications of the mirrors themselves, so the additional cost to mirror manufacturers should be minimal.

So what exactly is the difference between an old "unsafe" mirror and the new "safe" ones ?

Apart from the "e" of course.

Brian (",)

 

[JasonR_374341560]

ps.

Brians post seems to hi-light that Nige's link and data is re Truck's.

What ever, Milenco is now top of my "to be avoided" list

it's a Milenco mirror

 

[emmerson2]

Nigel, thanks for that post, which I'm sure was well intentioned. However, I shall continue to use my twenty - two year old mirrors on my fourteen year old car.

This is a clear case of spending loads of public money on creating a problem, then spending loads more finding a solution.

No reflection (sorry) on you Nigel, but bl**dy silly.

 

[Lord Braykewynde]

Is this a p...take or what? who the hell is going round checking the date of towing mirrors versus year of the car! - get a life!

Lmaaaooooooo.

 

[BrianStAlbans]

brian (st albans)

Overpaid people finding a solution for something thats not a problem.

emmerson

This is a clear case of spending loads of public money on creating a problem, then spending loads more finding a solution

SNAP !!!

 

[Chrisbee]

Brian

The point I was trying to make (but failing miserably)is that things do get updated for safety reasons but at the time we don't always realise the benefits. I thought my early cars all had good brakes but ABS obviously improves safety greatly although it was a cost option on the first car I had with them fitted.

I doubt if the regulations regarding mirrors and "e" marks have been updated just to generate money. There will be a valid safety reason for it, it's just that without knowing that reason we tend to think it's another scam. As someone who tours abroad and knowing how diligent French police can be when it suits them, the kind of information Nigel imparts may just save me a hefty fine. I think it is exactly the kind of information we need on forums like this.

Chrisbee

 

[Lord Braykewynde]

More EU rulings?

I can understand the need for trying to stop cheap Chinese unsafe imports but cannot understand why my Millenco mirrors that I bought 4 years ago with the smaller E are now unsafe.

 

[Chrisbee]

They aren't unsafe, just not "as safe" I would suspect, just as a car without ABS is not unsafe. However, all new cars must be fitted with them whether you like it or not.

Chrisbee

 

[davedee]

I fear that 'safe or unsafe' won't come into it with the insurance companies. Just another way out of paying a claim ! Dave

 

[nigel_374240528]

Sorry Nigel ,I'm confused I asked

" I wonder how many people are killed and injured each year by "old" e marked towing mirrors."

and you replyed

"I can answer this question in part. According to government research, http://www.dft.gov.uk/consultations/archive/2005/fitmirvis/partialregulatoryimpactasses1593,

Directive 2003/97/ec will save 20 lives and 102 serious injurys.

May I point out this regulation change was only one of very many directives made to save lives."

Now unless I'm missing something this seems only to relate to goods vehicles

1. Title of proposal

Implementation of Mirrors Directive 2003/97/EC on the Approximation of the Laws of the Member States Relating to the Type Approval of Devices for Indirect Vision and of Vehicles Equipped with these Devices and Directive 2005/27/EC Amending Directive 2003/97/EC, for the Purposes of its Adaptation to Technical Progress.

Note: Directive 2003/97/EC also includes provisions that apply only to cars. These have been dealt with in a separate RIA.

2. Purpose and intended fffect

Objective: To improve the exterior field of vision to the side, front and rear of goods vehicles of mass over 3.5 tonnes with full implementation for new vehicles by January 2007.

Background: In 2003, the European Council and Parliament agreed a new Directive (2003/97/EC) on rear view mirrors for vehicles. The main effect of this Directive was to increase the number of mirrors required to be fitted to new goods vehicles above 7.5 tonnes in order to reduce blind spots; particularly those in close proximity to high-sided vehicles, where the driver often has an obstructed view of pedestrians, cyclists and other vehicles. Since this Directive was agreed, a number of Member States have pointed out that there are some goods vehicles under 7.5 tonnes which also have a relatively high cab and share the same blind spot problems to the side as heavier vehicles. As a result, an amendment to Directive 2003/97/EC has been agreed extending the requirement to fit wide-angle and close-proximity mirrors to certain goods vehicles in the 3.5 to 7.5 tonne mass range. Only those with cabs of sufficient height to enable the mirrors to be fitted at least two metres from the ground and still be visible to the driver will be affected. This amendment has been published as Directive 2005/27/EC and it is intended to implement this new Directive at the same time as Directive 2003/97/EC, with full implementation for new vehicles by January 2007.

Rationale for government intervention: On GB roads over 3,500 people have been killed and 40,000 seriously injured annually in recent years. Although it is difficult to estimate how many casualties result directly from the limitations of current vehicle mirror systems, a recent report by ICE Ergonomics indicated that around 16 people a year are killed in the UK just as a result of the blind spot which exists beneath the windscreen of heavy goods vehicles. TRL Limited has also indicated that around 4 people a year are killed in the UK due to lack of visibility at the sides of heavy goods vehicles and, with the new amending Directive (2005/27/EC) requiring these additional mirrors for goods vehicles of mass between 3.5 and 7.5 tonnes, which over a period could save more lives, our broad estimate indicates that approximately 20.5 lives per annum could be saved.

There may be a new ruling on towing mirrors but it doesn't appear to be here.

Brian please read it again. It applys to cars and truck.

See below.

Consultation on the fitment of devices for indirect vision (mirrors) on motor vehicles

1.This consultation concerns amendments to regulation 33 of the Road Vehicles (Construction and Use) Regulations 1986. The amendments are necessary to implement the European Community Directives 2003/97/EC 1 and 2005/27/EC 2 . These Directives impose requirements for additional mirrors to be fitted to new goods vehicles and cars so as to increase the driver's field of vision and reduce blind spots.

2. The changes to be made are:

*******

to put into law the requirement that cars should have two exterior mirrors; ********

that goods vehicles over 3.5 and up to 7.5 tonnes are fitted with additional 'wide angle' and close proximity mirrors (if the vehicle has a high cab);

that heavy goods vehicles over 7.5 up to 12 tonnes are fitted with additional 'wide angle' and close proximity mirrors and a mirror to cover the forward blind spot; and

that heavy goods vehicles over 12 tonnes are fitted with an additional 'wide angle' mirror and a mirror to cover the forward blind spot.

 

[nigel_374240528]

More EU rulings?

I can understand the need for trying to stop cheap Chinese unsafe imports but cannot understand why my Millenco mirrors that I bought 4 years ago with the smaller E are now unsafe.

The milenco mirrors you bought some years ago work fine. I would not describe them as unsfafe and we still supply spares for them.

They do not however meet the latest pedestrian safety regulations.

 

[BrianStAlbans]

Nigel I can see that it says...

"to put into law the requirement that cars should have two exterior mirrors"

but also note this

8. Enforcement, sanctions and monitoring

Although mirrors on cars are already covered by type approval, mirrors on larger vehicles are not currently covered by UK type approval. It is intended that the new Directives will be implemented initially through changes to the UK Construction and Use Regulations which will require that the additional mirrors are fitted to goods vehicles first used on or after 26th January 2007 and are maintained in use on the road. Enforcement of Construction and Use requirements is by means of roadside enforcement and annual roadworthiness checks. In the longer term, it is anticipated that the Goods Vehicle Type Approval Regulations will also be amended to require compliance with these Directives.

I would suggest this is bringing truck mirrors inline with existing car mirror laws and as such does not affect the construction of the towing mirror just the e mark.

Is that correct ?

 

[nigel_374240528]

ps.

Brians post seems to hi-light that Nige's link and data is re Truck's.

What ever, Milenco is now top of my "to be avoided" list

it's a Milenco mirror

Brian misunderstood the directive. 2003/97/ec applys to cars speficically making it law you have mirrors on both side.

I am sorry you are not a fan of our products.

 

[nigel_374240528]

Brian. I used 2003/97/ec as an example of how regulations are designed to save lives and the statistical data justifying the new regulation.

2003/97/ec is only one of many regulations relating to mirrors to get them type approved and e marked.

 

[BrianStAlbans]

Actually you used it to tell me how many people were killed and injured by old e marked mirrors.

Do you know the difference between the 2 mirrors ?

Sorry but no reflection on you or your company but I think a lot of people will have to spend a lot of money buying new mirrors which are exactly the same as their old ones.

Brian

 

[JasonR_374341560]

This again shows the EC trampling through common sense and our spineless government and business men like Nigel going and

Will somebody please set up a department of common sense rather then have our wallets stripped by the EC,politicians and shameless business men.

Within reason a mirror is a mirror, here we have safety being used again for profiteering.

If so many people have been killed and seriously injured by automotive mirrors, surely dangerous imports would have been impounded before they hit the shelves!

 

[emmerson2]

brian (st albans)

Overpaid people finding a solution for something thats not a problem.

emmerson

This is a clear case of spending loads of public money on creating a problem, then spending loads more finding a solution

SNAP !!!

Great minds, b(sa)

 

[nigel_374240528]

I wish dangerous imports would be impounded before they hit the shelves. Milenco limited has complained to both Trading Standards and the VCA, yet you can still find illegal mirrors for sale.

The purpose of the original post was to inform you so you can make a better purchasing decision if buying new mirrors and avoid the dangerous mirrors from china.

I am sorry if you read the post and think we are forcing you to buy new mirrors because of the regulation changes.

If you wish to continue using your old mirrors on a new car than that is your decision. At least now you know that technically, you will be breaking construction and use regulations. This may also invalidate your insurance.

The Police recently had to change some of their blue flashing lights because they had some without e-marks.

With regards to dangerous mirrors may I clarify my previous point. We have tested the Chinese, non e-marked mirrors and were shocked at just how dangerous the glass is. Some of them virtually explode on impact.

This year, we have seen dangerous Chinese mirrors with the obsolete e-marks on. These really should be avoided. We don't think these mirrors were ever legal or even ever tested.

We dont think old e-marked mirrors are dangerous, but clearly they are not as safe as the new ones.

New mirrors for sale should have the current 12mm round e-mark on them.

In response to Brian's question about the difference between the old and new regulations yes I know the difference. We have had to re- design every part of every mirror to get them approved. The most obvious change but not limited to is, all edges must be rounded to protect pedestrians, and there is a gauge to check this.

Please Tow Safely.

 

[Royston]

Reading all the comments,Can some kind person clarify if the following are correct:-

Are my actual car mirrors fitted to my old car illegal, even though the mirror is power driven within the mirror casing.

Has this new ruling been brought about, because the lorry mirrors cannot be adjusted as per my car resulting in a blind spot on the drivers nearside.

I always have my car mirror lenses angled down (something i could not do with those clip on mirrors the clips stopped the lenses from moving) so that I can see the van wheels in relations to the curbs .

 

[JasonR_374341560]

With regular traffic reports on caravan accidents no doubt towing is more dangerous than solo driving.

Yet we now have to worry ourselves about mirror safety as well.

Sure thing broken glass is a danger, but Nigel you have offered up what appears to be factual data on lives to be saved and serious accidents to be avoided with new E marked mirrors. So are these new mirrors going to prevent all deaths and accidents or just reduce them.

You appear to be blatantly scaremongering Nigel without offering up days dates and times re all the serious mirror deaths and serious accidents.

If I and others could face prosecution and become uninsured due to having older mirrors or any other changed E mark products

are we supposed to guess that regulations have changed or just chance that we see such information on a web site forum

I would judge that Government, EC and Manufacturers such as yourself would be liable for not making proper widespread public announcements re such changes if many are now "law breakers". Surely we are not left to break the law and then be prosecuted as powers that be have failed us

If Milenco has sold and is selling E marked products that have a limited useful life due to E mark changes is the company not liable for misleading the public re the useful life of the product. Surely your products should carry a useful life expectancy warning.

Your warning re insurance and breaking the law is scaremongering Nigel as you give no factual evidence that this is the intended action by the authorities. If non E marked dangerous mirrors are on sale, surely retailers would be more liable than the purchaser in the event of a serious accident.

If we are now in such great danger from vehicle mirrors and face prosecution or becoming uninsured are you not duty bound as a responsible manufacturer to make this wider public knowledge if our government has failed in their duty to motoristsIf Milenco has sold and is selling E marked products that have a limited useful life due to E mark changes is the company not liable for misleading the public re the useful life of the product. Surely your products should carry a useful life expectancy warning.

Your warning re insurance and breaking the law is scaremongering Nigel as you give no factual evidence that this is the intended action by the authorities. If non E marked dangerous mirrors are on sale, surely retailers would be more liable than the purchaser in the event of a serious accident.

If we are now in such great danger from vehicle mirrors and face prosecution or becoming uninsured are you not duty bound as a responsible manugacturer to make this wider public knowlege if our governement has failed in their duty to motorists

 

[JasonR_374341560]

With regular traffic reports on caravan accidents no doubt towing is more dangerous than solo driving.

Yet we now have to worry ourselves about mirror safety as well.

Sure thing broken glass is a danger, but Nigel you have offered up what appears to be factual data on lives to be saved and serious accidents to be avoided with new E marked mirrors. So are these new mirrors going to prevent all deaths and accidents or just reduce them.

You appear to be blatantly scaremongering Nigel without offering up days dates and times re all the serious mirror deaths and serious accidents.

If I and others could face prosecution and become uninsured due to having older mirrors or any other changed E mark products

are we supposed to guess that regulations have changed or just chance that we see such information on a web site forum

I would judge that Government, EC and Manufacturers such as yourself would be liable for not making proper widespread public announcements re such changes if many are now "law breakers". Surely we are not left to break the law and then be prosecuted as powers that be have failed us

If Milenco has sold and is selling E marked products that have a limited useful life due to E mark changes is the company not liable for misleading the public re the useful life of the product. Surely your products should carry a useful life expectancy warning.

Your warning re insurance and breaking the law is scaremongering Nigel as you give no factual evidence that this is the intended action by the authorities. If non E marked dangerous mirrors are on sale, surely retailers would be more liable than the purchaser in the event of a serious accident.

If we are now in such great danger from vehicle mirrors and face prosecution or becoming uninsured are you not duty bound as a responsible manufacturer to make this wider public knowledge if our government has failed in their duty to motoristsIf Milenco has sold and is selling E marked products that have a limited useful life due to E mark changes is the company not liable for misleading the public re the useful life of the product. Surely your products should carry a useful life expectancy warning.

Your warning re insurance and breaking the law is scaremongering Nigel as you give no factual evidence that this is the intended action by the authorities. If non E marked dangerous mirrors are on sale, surely retailers would be more liable than the purchaser in the event of a serious accident.

If we are now in such great danger from vehicle mirrors and face prosecution or becoming uninsured are you not duty bound as a responsible manugacturer to make this wider public knowlege if our governement has failed in their duty to motorists

sorry for cut and paste error

 

[nigel_374240528]

Reading all the comments,Can some kind person clarify if the following are correct:-

Are my actual car mirrors fitted to my old car illegal, even though the mirror is power driven within the mirror casing.

Has this new ruling been brought about, because the lorry mirrors cannot be adjusted as per my car resulting in a blind spot on the drivers nearside.

I always have my car mirror lenses angled down (something i could not do with those clip on mirrors the clips stopped the lenses from moving) so that I can see the van wheels in relations to the curbs .

Royston.

Your car mirrors are perfectly legal as they will have been type approved.

 

[nigel_374240528]

Jason.

I have just explained some of the regulations and law to help. I do not make the law. Please don't shoot the messenger.

At the risk of repeating myself, type approval on a mirror lasts 3 years. There is no guarantee that in 3 years time our mirrors will meet the new regulations out at that time.

Regulations change all the time. If you buy a new car, caravan or bicycle, it is probable in 3 years all of these products will have changes because of new regulations.

With these products, like our mirrors, they will still have a useful life of say 20 years.

As a responsible manufacturer we ensure that our products conform to the very latest and correct standard.

If you vehicle is not roadworthy (because of illegal mirrors bald tyres or anything else) and you have an insurance claim, it is very likely the insurance company will not pay out. On UKcampsite last year, it was reported one caravanner was towing without mirrors and damaged his caravan. The claim was not paid out because he was towing illegally.

Please have a nice weekend.

 

[RogerL]

A manufacturer's certification for Type Approval may only apply for three years but a consumers purchase of a type approved product is permitted to be used without time limit.

It's right that only currently E-marked mirrors should be available for purchase and robust steps taken to stop any others.

It's simply not practical to restrict existing mirrors to "older" cars - particularly as Department of Transport have given no publicity to this matter.