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Redevelopment of VSB 1 - Light Trailers Consultation paper 4 March 2019

TABLE OF CONTENTSChapter 1: Strategic intentions...........................................................................................................2

Chapter 2: Purpose of this document................................................................................................3

Chapter 3: Revision 6 of VSB 1 - Process of development...............................................................4

Chapter 4: Legislative and policy changes........................................................................................7

Chapter 5: VSB 1 (Revision 6) Scope..............................................................................................13

Chapter 6: VSB 1 (Revision 6) Document style and structure.........................................................15

Chapter 7: VSB 1 (Revision 6) Proposed technical requirements...................................................18

Appendix 1 - Mock-up of proposed VSB 1 (Revision 6) style..........................................................24

Appendix 2 - Example of existing light trailer inspection checklist (based on VSB 1 - Revision 5)..26

NomenclaturePlease note that the current version of Vehicle Standards Bulletin 1 (VSB 1) is Revision 5, June 2009. The revised version of VSB 1 will be Revision 6.

Within this document, the two different versions are shown like this:

VSB 1 (Revision 5)

VSB 1 (Revision 6)

1 Redevelopment of VSB 1 - Light Trailers

Chapter 1: Strategic intentions

The revision to the existing Vehicle Standards Bulletin 1 (VSB 1 Revision 5) is being undertaken with four strategic intentions:

1. New legislation for the regulation of road vehicles in Australia is being introduced. The new legislation, known as the Road Vehicle Standards legislation, will include a new Road Vehi-cle Standards Act, Road Vehicle Standards Rules and several determinations. VSB 1 (Re-vision 6) needs to reflect this new legislation.

2. Since VSB 1 (Revision 5) was last updated, changes have occurred to the Australian De-sign Rules. These changes need to be reflected in VSB 1 (Revision 6).

3. Light trailers are currently over-represented in consumer complaints. A major aim of VSB 1 (Revision 6) is to address the underlying causes of consumer complaints.

4. Compliance audits frequently show failure to meet safety standards. A major aim of VSB 1 (Revision 6) is to improve compliance with the Australian Design Rules by light trailer man-ufacturers.

Note that changes to the Australian Design Rules are not within scope of this VSB 1 revision.

2 Redevelopment of VSB1 - Light Trailers

Chapter 2: Purpose of this document

This document is designed to introduce to stakeholders:

The changes in procedures, processes and expectations resulting from the introduction of the new Road Vehicle Standards legislation.

The proposed changes in content of VSB 1 (Revision 6).

The proposed changes in style, layout and design of VSB 1 (Revision 6).

It seeks feedback and discussion on:

Specific approaches to technical requirements incorporated in VSB 1 (Revision 6), reflec-tive of current Australian Design Rules (ADRs).

Proposed changed content in VSB 1 (Revision 6) to better achieve the strategic intentions shown in Chapter 1.

Proposed changed emphases in VSB 1 (Revision 6) to better achieve the strategic inten-tions shown in Chapter 1.

Ambiguities, errors and other shortcomings in VSB 1 (Revision 5).


Chapter 3: Revision 6 of VSB 1 - Process of devel-opment

The redevelopment of the VSB 1 (Revision 5) is a process that is occurring over about 6 months. The timeline for the process is as follows.

3.1 Analysis of differences between the ADRs and VSB 1 (Revi-sion 5)

Due date: 7/01/2019

A report was prepared on the differences between current ADR requirements and VSB 1 (Revision 5).

Within the context of the identified strategic intentions shown in Chapter 1, this report found:

A relatively small number of outright errors, or of guidance that does not reflect the current ADRs. An example of this is in the VSB 1 (Revision 5) section on lighting.

Some areas of coverage that did not provide sufficient guidance. An example of this is in the VSB 1 (Revision 5) coverage of braking.

Some areas where there was insufficient emphasis on the requirements of trailer manufac-turers or importers. An example of this is in the requirement that under Australian consumer law, a trailer must be fit for the purpose for which it is sold.


3.2 Consultation paper

Due date: 25/02/2019

A Consultation Paper has been prepared for use in discussion with interested stakeholders. (This is the document you are currently reading.)

Those stakeholders include:

the Department States and Territories manufacturers and importers of trailers, including of caravans, horse floats, boat trail-

ers, box trailers and plant trailers trailer users

Prior to the development of this document, informal phone discussions were carried out with a range of stakeholders - Federal and State and Territory governments, industry representatives, trailer manufacturers and consumer groups.

3.3 Stakeholders’ consultation meetingA stakeholders’ consultation meeting will be held. The primary purpose of this meeting is to canvass responses to the proposals contained in this Consultation Paper. This meeting will also be used to introduce participants to the requirements of the new Road Vehicle Standards legislation.

Note: it is encouraged that, especially in the case of specific ADR / VSB 1 (Revision 5) anomalies, participants submit their points in writing by email to:

[email protected]

While we believe these anomalies to be important and that they should be addressed, in this meeting we would like discussion to focus more on the ‘big picture’ changes required in VSB 1 (Revision 6), especially in the context of meeting the Strategic Intentions shown in Chapter 1.

It is expected that this meeting will be held in Melbourne on March 14, 2019.

3.4 Draft VSB 1 (Revision 6)Due date: 3/05/2019

A draft version of the VSB 1 (Revision 6), incorporating all the major changes that have been canvassed will be prepared and published for stakeholder feedback.


3.5 Final VSB 1 (Revision 6)Due date: 21/06/2019

The final version of VSB 1 (Revision 6) will be released.


Chapter 4: Legislative and policy changes

Since 2014, the Australian Government has been reviewing the framework under which road vehicles can be supplied to the market in Australia. This framework, underpinned by the Motor Vehicle Standards Act 1989 (the MVSA), did not overtly cover the regulation of light trailers. Instead, a concessional arrangement known as Vehicle Standards Bulletin 1 (VSB 1) set requirements for light trailers based on the Australian Design Rules. Vehicles complying with VSB 1 were acceptable for supply and subsequent use.

The review of the MVSA determined that additional regulation of light trailers was necessary to improve compliance, and more broadly, the review advised that changes should be made to the framework to improve enforcement and to modernise it.

On 10 December 2018, the Road Vehicle Standards Bill received Royal Assent. Over the next 2 years, the Road Vehicle Standards Act (RVSA) will be phased in as the MVSA is phased out.

One of the key changes in the RVSA is to replace identification plates with an online register. This online register will be known as the Register of Approved Vehicles, or RAV. Manufacturers and importers wishing to supply vehicles (including light trailers) for road use will need to have the details of the vehicle entered onto the RAV. Vehicles on the RAV will be generally accepted as suitable for road use.

4.1 RAV entry pathwaysThe RVSA includes two pathways through which vehicles may be approved for entry onto the RAV. These are:

Type Approval pathway Concessional RAV Entry pathway.

Either pathway is available to light trailer manufacturers and importers, but only if the applicants and trailers comply with a variety of eligibility and technical criteria.

The Type Approval pathway is used when the applicant is the trailer manufacturer and / or has strong connections to the design of the trailers. Only new trailers can be covered by a type approval.

The Concessional RAV Entry pathway is used when not more than four light trailers are to be provided by the applicant within a 12-month period.


4.1.1 Type Approval pathway

A trailer ‘type’ is group of trailers of the same make and the same vehicle category.

‘Make’ means the name by which the range of vehicles is popularly known. ‘Vehicle category’ refers to TA, TB or TC trailer categories.

Manufacturers and importers of light trailers may be able to obtain a Type Approval for new trailers.

Each Type Approval will state that vehicles covered by the approval are acceptable for entry to the RAV. As trailers are manufactured or imported, the Type Approval holder can add the details of each trailer to the RAV. Once on the RAV, the vehicles may be sold to end-users, registered and used on public roads.

To obtain a Type Approval for light trailers, the manufacturer or importer must make an application that includes all the following declarations:

That at the time the application is made, the applicant can provide the supporting informa-tion for the approval.

While the approval is in force, and for the period of 7 years after it expires, the applicant can provide the original, and any subsequent versions, of the supporting information.

While the approval is in force, the applicant will ensure the supporting information is kept up to date.

A separate application for Type Approval must be made if vehicles in the type are non-compliant. This non-compliance may be minor and inconsequential, or more substantial.

4.1.1.1 What is ‘supporting information’?

For the purposes of a light trailer type approval, the Road Vehicle Standards Rules (the Rules) define supporting information as:

(a) in relation to the design and componentry of each variant of vehicle covered, or to be covered, by a road vehicle type approval—information that sets out the details of every aspect of vehicle design and componentry (including the source material and manufacturing process of each


component) that affects compliance with the applicable national road vehicle standards, as in force at that time.

(b) in relation to the manufacturing process that is used, or will be used, to produce each variant of vehicle covered, or to be covered, by a road vehicle type approval—information that sets out the details of every aspect of the manufacturing process (including the material, vehicle components and equipment used in that process) that affects compliance with the applicable national road vehicle standards, as in force at that time.

Note: if a person does not possess the information mentioned above, a copy of any contractual (or other) arrangement under which the person may access the information is also suitable.

Please see Section 4.4 below for more information on what comprises acceptable evidence of compliance.

4.1.1.2 Conformity of production

It is a condition of a road vehicle Type Approval that the holder of the approval implement a conformity of production system that:

(a) governs the manufacturing process detailed in the supporting information for the approval; and

(b) ensures that, at the time that a vehicle is entered on the RAV under the approval, the vehicle satisfies the requirements of the Type Approval pathway.

4.1.1.3 Compliance with standards

The Rules require light trailers to comply with the National Road Vehicle Standards (the ADRs) applicable at the time the vehicles are entered onto the RAV. The Department proposes to allow applicants to make another declaration that all of the trailers covered by each Type Approval will comply with the applicable ADRs.

In some cases, trailers won’t comply with the applicable ADRs. The Rules allow the Secretary to approve an application for Type Approval where the type complies substantially with the ADRs and:

The non-compliance is only in minor and inconsequential respects orThe type complies to an extent that makes it suitable for use on public roads – where:

i. The trailer would not pose an unacceptable risk to public safety; andii. The trailer would be appropriate to use.

In these cases, applicants will be required to provide evidence and a justification explaining why the Type Approval should be issued, despite the non-compliance.


4.1.1.4 RAV entry

Type Approval Holders must arrange to submit all vehicle details to the RAV themselves. The Department has prepared a RAV guide to explain how to submit details to the RAV. For more information visit the Department’s website at https://infrastructure.gov.au/vehicles/rav/index.aspx

4.1.2 The Concessional RAV Entry pathway

For manufacturers or importers that are not eligible to obtain a Type Approval, or where the number of trailers does not justify the additional rigour, the concessional RAV entry option is available.

Concessional RAV entry is the only way a used imported trailer may be added to the RAV.

Trailers using this pathway must comply with the same technical standards as for the Type Approval pathway, but applicants do not need to comply with the same criteria for aspects such as supporting information or conformity of production.

Each application will be for a single trailer and must include a declaration by the applicant that the:

trailer complies with the applicable Australian Design Rules or if the trailer does not comply with the Australian Design Rules, the applicant must

include information explaining why the trailer does not comply and justification for why it should be entered on the RAV.

4.1.2.1 Number limits

Applicants for concessional RAV entry will be limited to 4 light trailers in any twelve-month period.

4.1.2.2 Conditions

Concessional RAV entry applications may include conditions where the applicant is required to advise the Department when the trailer is:

in Australia in a condition suitable for addition to the RAV.

The Department may require concessional trailers to be inspected before they are added to the RAV.


https://infrastructure.gov.au/vehicles/rav/index.aspx

4.1.2.3 RAV entry

The Department will send the details of each concessional trailer to the RAV when each of the relevant conditions on the approval have been complied with.

4.2 Where does VSB 1 fit in?For both Type Approval and Concessional RAV Entry pathways, the Department will accept compliance with VSB 1 (Revision 6) as evidence of compliance with the ADRs.

Note that VSB 1 (Revision 6) will cover only the most commonly-used ADR requirements for light trailers. The ADRs and their alternative standards may contain additional options that are also acceptable for these vehicles.

4.3 OffencesOne of the important changes to the legislative framework is the addition of more offence provisions, and additional enforcement options.

These include offences for:

making false or misleading declarations adding a vehicle’s details to the RAV when it wasn’t eligible to be added to the RAV providing vehicles to another person when the vehicle is not on the RAV modifying a vehicle that is on the RAV before it is provided to an end-user.

The Department will enforce these offences using a risk-based approach and variable enforcement tools including:

negotiation infringement notices enforceable undertakings suspension or cancellation of approvals civil penalties criminal prosecution.

4.4 Evidence of complianceIn both the Type Approval and Concessional RAV Entry pathways, the applicant is expected to have and keep evidence that each vehicle, when added to the RAV, complies with the relevant standards, or complies to the extent required by the approval.


It is expected that holders of approval can demonstrate compliance by holding evidence that is traceable to reliable sources. Such sources include:

The reports of testing for vehicles or components conducted at testing facilities approved under the RVSA.

Approvals for vehicles or components issued by contracting parties to the 1958 agreement (where the Australian Government has applied particular regulations or where the regula-tion is an acceptable alternative to the ADR).

Component Type Approvals (where the approval holder can show the component has been fitted in accordance with any instructions provided with the component type approval).

4.5 RecallsThe RVSA now includes provisions for the recall of road vehicles and approved road vehicle components. Manufacturers and importers of light trailers are expected to voluntarily recall and rectify trailers they have provided to the market if:

the trailer will or may cause injury to any person; A reasonably foreseeable use (including misuse) of the trailer will or may cause injury to

any person; or The trailer does not comply with an applicable national road vehicle standard and is not

exempt from the standard because of its approval.

When undertaking recalls, light trailer manufacturers and importers are expected to comply with the notification and reporting requirements set out in the rules. If the Minister is satisfied that a recall is necessary or is not happening quickly enough, the Minister can issue a compulsory recall notice.


Chapter 5: VSB 1 (Revision 6) ScopeThe extent to which VSB 1 (Revision 6) will cover all light trailers, or just a subset of light trailers, will heavily impact on the approach taken within the document. In this section we look at the proposed scope of VSB 1 (Revision 6).

5.1 The ‘90 per cent’ approachOne of the issues with VSB 1 (Revision 5) is that it tries to cater for a very wide variety of potential trailer designs and approaches. This makes it a relatively complex document to follow. However, inspection of trailers on the road shows that the vast majority are very similar to one another.

It is therefore proposed that VSB 1 (Revision 6) attempts to cater for about 90 per cent of trailers. Those building or importing trailers that make up the remaining 10 per cent will be directed to the ADRs.

The benefit of this approach is that VSB 1 (Revision 6) can be made simpler, and easier to read and understand.

Should the following trailer types therefore be included in VSB 1 (Revision 6)?

narrow trailers (less than 980mm) trailers over 3.5t ATM pole trailers

There are advantages and disadvantages in including or excluding these categories, and feedback from stakeholders is sought.

5.2 ConsumersWhile it was originally prepared for the guidance of manufacturers and importers, VSB 1 (Revision 5) is widely used by consumers. (For example, the Australian Caravaners Forum [http://www.caravanersforum.com] has more than 1,000 search results under ‘VSB1’.

It is proposed that VSB1 (Revision 6) take into account this broader audience.

5.3 Advice and good practiceVSB1 (Revision 5) contains breakout box notes and cautions. It is unclear to the reader whether these are ADR requirements, or just recommendations, and so these are a source of confusion for both manufacturers and consumers. However, in many cases, these notes and cautions are important.


It is proposed that this type of information be included in VSB1 (Revision 6) through the use of ‘reader questions’ placed in breakout boxes. An example is shown below.

“My trailer’s safety chain attachment points scrape on the road when the trailer is uncoupled but the safety chains are still connected. Is this an issue?”

While it is not required by the Australian Design Rules, in the situation you have described the attachment points for the safety chains should not touch the road.

This approach allows the inclusion of important information, without causing confusion as to its regulatory significance.


Chapter 6: VSB 1 (Revision 6) Document style and structure

The readability of a document depends heavily on its structure and style. In this section, we examine some of the proposed VSB 1 (Revision 6) style and structure aspects.

6.1 Style

VSB 1 (Revision 5) is poorly laid out, is inconsistent in diagram styles, and is difficult to skim (e.g. to quickly find a single requirement). With its lack of white space and photographs, it is also visually daunting.

It is proposed that VSB 1 (Revision 6) use a dramatically different visual style. The key ingredients are the use of:

a lead photo at the beginning of each new section, to visually establish context a summary opening paragraph to establish key areas covered by the section bullet point structure of text extensive use of white space, making the document appear much less dense grey breakout boxes showing relevant expansions (e.g. marking of chain to meet Australian

Standard) cream/yellow breakout boxes containing ‘reader’ questions and their answers re-drawn, and additional, diagrams having a consistent style photos.

A full-size mock-up of this approach is shown in Appendix 1, and a smaller version is shown on the next page.


Example of suggested design and layout (full-size version in Appendix 1):

6.2 StructureIn terms of structure (i.e. where material is placed within the document, and how it is organised), we suggest that the structure of VSB 1 Revision 6 remain similar to the current Revision 5.

However, we envisage the additional use of:

checklists (the current Departmental ‘Light Trailer Inspection Check Sheet’ is an example - see Appendix 2)

procedural flowcharts.


6.3 LanguageStandard register (i.e. a standard degree of language formality) will be used in the main body of VSB 1 (Revision 6). Breakout boxes containing reader questions will use a less formal register. (Note: register is defined in the Australian Government Style Manual - see https://www.australia.gov.au/about-government/publications/style-manual)

The language will be unambiguous, clear and direct. Assessment should be able to be made of all content on the basis that the direction is one of the following:

obligatory (a formal requirement that must be done) restrictive or prohibiting (must not be done) permissible (it may be done if wished) advisory (for information only)


https://www.australia.gov.au/about-government/publications/style-manual

Chapter 7: VSB 1 (Revision 6) Proposed technical requirements

There are number of areas where VSB 1 (Version 5) is in error, needs updating to match revised ADRs and Road Vehicle Standards, or is unclear.

Following are suggestions for changes in technical requirements, or changed emphases in those requirements.

Note 1: These suggested changes have been made in the context of the strategic intentions shown in Chapter 1.

Note 2: Changes involving the new Road Vehicle Standards Act are shown in Chapter 4.

7.1 Rear overhang versus front load space

ADR 43/04 states that:

For a ‘Pig Trailer’, the ‘Rear Overhang’ must not exceed the length of the load space forward of the line from which ‘Rear Overhang’ is measured, or 3.7 metres, whichever is the lesser.

VSB 1 (Revision 5) states that:

Rear overhang must not exceed the lesser of 3.7 metres or the front load space.

ADR definitions state that the rear overhang is:

The distance measured horizontally and parallel to the longitudinal axis of the vehicle between the ‘Rear End’ of the vehicle and the ‘Centre of an Axle Group’

However, ‘front load space’ is not described in the ADR definitions.

In many trailers - e.g. box trailers - the front load space is demarcated by the forward position of the edge of the peripheral enclosure. However, in some trailers (e.g. caravans where gas bottles may be mounted on the drawbar) the front load space is ill-defined.

Therefore, a situation develops where the compliance of rear overhang depends on items present or not present on the drawbar. In fact, anecdotally, one trailer that failed a state inspection because of an overly long rear overhang, subsequently passed inspection when a tool box was added to the drawbar.


The danger is that gradually the drawbar length becomes accepted as being part of the front load space, thus resulting in axles positioned further forward than ideal.

We suggest that (e.g. by the answer to a ‘reader’ question) the exposed area of the drawbar ahead of the main body of the trailer be excluded from the definition of front load area, irrespective of the placement of items on the drawbar such as gas bottles, tool boxes and spare tyres.

7.2 Tow-ball weight

Caravan rollovers in Australia appear to be more common than would be expected. There are at least 70-80 caravan rollovers each year in Australia.

A variety of reasons has been suggested for this. They include:

use of inappropriate tow vehicles lack of driver skill and education regarding towing poor loading of caravans inappropriate caravan design.

Trailer stability has been extensively researched by Dr Jos Darling of the University of Bath, UK.

His research indicates towed vehicle instability is primarily related to:

ball weight (6-7 per cent of total trailer weight recommended) trailer yaw inertia (weight should be concentrated near axle rather than towards ends) trailer axle position (further rearwards = better)

(See for example: An experimental investigation of car–trailer high-speed stability, Proc. IMechE Vol. 223 Part D: J. Automobile Engineering, 2009)

In terms of weights, caravan manufacturers are currently required to specify on the trailer plate only ATM.

We suggest that a recommendation be made in VSB 1 (Revision 6) that the following additional material be displayed on the trailer plate:

Minimum tow-ball down-weight Recommended fully-loaded tow-ball down-weight

VSB 1 (Revision 6) could also include the following note:

Note: the minimum tow ball down weight should occur with the trailer unloaded. In the case of a caravan, in this configuration water and waste tanks should be empty.


This approach would help achieve the following.

Listing the minimum tow-ball down-weight would ensure that:

Manufacturers are more conscious of axle position versus fixed weight distribution.

Consumers would realise that ball weights can be too low. Currently, much of the emphasis is on maximum ball weights i.e. tow bar and tow vehicle capability.

Listing the recommended fully-loaded tow-ball down-weight would ensure that:

Manufacturers would be more conscious of the locations of variable loads e.g. positions of caravan water and waste tanks.

Consumers could better assess towbar and tow vehicle requirements in terms of permiss-ible ball weights at maximum trailer load.

Via the use of a cheap ($50) ball weight scale, consumers could easily confirm that their loading of the caravan was likely to be appropriate.

The approach does not prevent a consumer from overloading the caravan (i.e. exceeding ATM).

The approach does not prevent a consumer from poorly distributing loads such that actual ball weight is still within the minimum-maximum designated range, but the proportion of total trailer weight on the ball is less than an appropriate percentage. However, this is much less likely to occur than with the current situation.

We further suggest that via the use of ‘reader questions’ in the VSB, good practice be explained re-garding distribution of loads within trailer lengths. As part of this response, manufacturers would be encouraged to label maximum load weights of provided compartments and storage areas.

7.3 Braking

We suggest that the section in VSB 1 (Revision 6) be expanded and clarified over that in VSB 1 (Version 5).

7.3.1 Efficient brakes

ADR 38/05 specifies that a trailer over 0.75t GTM must be fitted with an ‘efficient’ service brake system. We propose that an ‘efficient’ service brake be defined as a braking system that:


Has sufficient capacity to stop the trailer by itself; Has the ability to dissipate the heat generated by multiple brake applications; Is able to provide the braking force to stop the vehicle in about the same distance the tow

vehicle would stop by itself; Is able to be adjusted and balanced so that the appropriate proportion of braking is done by

each wheel; and Effectively varies the stopping force based on the rate at which the tow vehicle is stopping.

7.3.2 Over-run braking up to 3.5t (GTM)

UN regulation 13: 5.2.2.2, an alternative standard mentioned in ADR38/05, allows over-run brakes on trailers of up to 3.5t (GTM). As such, in VSB 1 (Revision 6) these will be permitted, but only if they can be demonstrated to comply with the technical requirements of the UN standard.

7.3.3 Emergency brakes

ADR 38/05 requires that every trailer with a GTM over 2 tonnes must be equipped with an efficient emergency brake system. We propose that an ‘efficient’ emergency brake system is one that:

Has sufficient capacity to stop the trailer by itself and Has sufficient stored energy to apply the brakes for at least 15 minutes.

7.4 Lighting

7.4.1 Location and type

We suggest that in VSB 1 (Revision 6), lighting requirements be simplified and clarified.

This could be achieved by using diagrams showing the front, side and rear of typical trailer designs, for example:

box trailer caravan car carrier horse float boat trailer plant trailer.


These diagrams would show the most common, compliant lighting approaches. Some examples of non-compliant approaches would also be shown; these would have a large red cross placed through them.

Where more unusual trailer designs are being considered, the reader would be directed to the ADRs.

7.4.2 Visibility

Diagrams to show the geometric visibility requirement of each lamp will be included. An additional note will emphasise that equipment cannot be placed that impedes these visibility requirements.

7.5 Fit for purpose

Trailer manufacturers and importers have a legal responsibility, under Australian law, that the trailers they sell to consumers are fit for the purpose for which they are sold. In the VSB 1 (Revision 5) this is only very briefly covered.

It is proposed that this section in VSB 1 (Revision 6) be expanded to better illustrate the roles and responsibilities of light trailer manufacturers and importers.

From https://www.accc.gov.au/consumers/consumer-rights-guarantees/consumer-guarantees:

Products must be:

safe, lasting, with no faults

do all the things someone would normally expect them to do.

be fit for the purpose the business told you it would be fit for and for any purpose that you made known to the business before purchasing

Products must be of acceptable quality. Acceptable quality takes into account what would normally be expected for the type of product and cost.

Note that for trailers being provided to non-consumer purchasers (i.e. commercial purchasers), occupational health and safety laws are applicable.


Manufacturers and importers should ensure that their description of the functionality and purpose of the trailer that they are making available is accurate.

For example, a trailer sold for off-road use should be capable of off-road use. If in fact the trailer is designed instead for all-road use, the description of the trailer should reflect that.

The claimed functionality of the trailer must be achievable by the consumer in normal use. For example:

A trailer sold for off-road use should be able to perform in this environment, in a way that a consumer would normally expect, without premature failure.

A trailer sold for the carriage of cars should be able to carry a typical current model car without exceeding ATM.

A horse float should be able to carry a full load, made up of typical horses, without exceed-ing ATM. (See http://www.dpi.nsw.gov.au/__data/assets/pdf_file/0008/109988/estimating-a-horses-weight.pdf)

A caravan, loaded with regard to the trailer and tow vehicle manufacturers’ guidance, should tow stably.

Legally required caravan doors should be useable by people of average stature, weight and fitness.

Electric trailer brakes should be capable of passing a roller brake test when the trailer is first made available to the end-user.

A boat trailer should remain compliant (eg in lamps and reflectors) while carrying the boat for which it was designed.

Manufacturers and retailers are reminded of the following. Under the new Road Vehicle Standards legislation, it may be an offence to modify a vehicle that is on the RAV, prior to it being provided to a consumer. The offence occurs if the modification would cause the vehicle to not satisfy the requirements of the entry pathway that applied at the time the vehicle was entered on the RAV.


This requirement has implications for ‘fit for purpose’, in that a vehicle that no longer meets the entry pathway requirements may not be able to be registered.


Appendix 1 - Mock-up of proposed VSB 1 (Revision 6) style25.0 Drawbar safety chains and their mounting

The Australian Design Rules specify the: type of trailers to which safety chains must be fitted number of safety chains that must be used strength rating of those chains strength rating of the chain attachment points on the trailer.

25.1 Drawbar safety chainsSafety chains or cables must be fitted to:

trailers with rigid drawbars, excluding converter dollies all trailers without breakaway brakes.

Trailers that do not exceed 2.5t ATM Must use at least one safety chain. The chain must comply with Australian Standard AS 4177.4-2004, or be a safety cable with the

same certified load rating.

Trailers over 2.5t but not exceeding 3.5t ATM Must use two safety chains. The chains must comply with Australian Standard Australian Standard AS 4177.4-2004, or be a

safety cable with the same certified load rating.

Trailers over 3.5t ATM Must use two safety chains. The chains must be made from steel of a minimum 800 MPa breaking stress that conforms to the

mechanical properties of Grade T chain as specified in Australian Standard AS 2321–2006. Each chain must have a minimum breaking load greater than the trailer ATM and use a 6mm chain

size with a minimum breaking load of 5.1t.

25.2 Drawbar Safety Chain Attachment PointsSafety chains are attached to the trailer’s drawbar.

The chain attachment points must be located as near as practical to the trailer coupling. Where two safety chains are used, they must be mounted one each side of the centreline of the

drawbar. Each safety chain attachment point must withstand at least the following forces without:

any residual deformation that would interfere or degrade the function of the assembly any breaks, cracks or separation of the components.

The test forces must be maintained for at least 10 seconds.


Safety chain attachment point test forces: Longitudinal tension (N) = 9.81 x trailer ATM (kg) Vertical tension (N) = 0.5 x 9.81 x trailer ATM (kg)

The requirement for safety chain attachment longitudinal load is the same force on the attachment as that created if the fully-loaded trailer were suspended vertically by one safety chain. The requirement for safety chain attachment vertical load is the same force as that created by half the weight of the fully-loaded trailer pulling upwards or downwards on one safety chain.

Safety chain markingsChain that complies with Australian Standard 4177 is marked in the following way:

manufacturer or importer identification 4177 a hyphen and two digits.

For example, 4177-35 indicates a 3500kg rating.

Safety chain for trailer ATMs not exceeding 3.5t should be selected using the following table.

Chain designation (kg)

Trailer ATM (kg)

1000 0-1000

1600 Up to 1600

2500 Up to 2500

3500 Up to 3500

Grade T chain is marked with T, 8, 80 or 800. Note: T-rated safety chains should not be welded.

Questions“Should the safety chains for a 3-tonne caravan be marked with the Australian Standard?”Yes! A 3.0t ATM trailer must use two chains, each marked with the AS 4177 standard. For a trailer of this ATM, the designation should be: (name of manufacturer or importer) 4177-35.

“My trailer’s safety chain attachment points scrape on the road when the trailer is uncoupled but the safety chains are still connected. Is this an issue?”


While it is not required by the Australian Design Rules, in the situation you have described the attachment points for the safety chains should not touch the road.


Appendix 2 - Example of existing light trailer inspection checklist (based on VSB 1 - Revision 15)

Motor Vehicle Standards Official(s) Details

Inspectors Signature



Inspection location

Date of inspection

Trailer Identification - affixed trailer plate information

Manufacturers Name

Trailer Model

Vehicle Identification Number

Date of Manufacture

Aggregate Trailer Mass kg

Vehicle Import Approval number (If applicable)

Does the trailer plate contain the following statement:

“This trailer was manufactured to comply with the Motor Vehicle Standards ACT 1989”

Y N NA

VIN Grid location

Trailer plate location

Trailer Dimensions - note: If dimensions exceed specified limits a non-standard trailer approval is required.

Overall length mm


Front load space mm

Forward radius mm (max 1,900mm)

Rear Overhang - Max distance is the lesser 3,700mm or front load space

mm

Width - (Must include all equipment fitted to vehicle excluding lights and mirrors)

mm (max 2,500mm)

Height mm (max 4300mm)

Ground clearance - Min 100mm within 1000mm fore or aft of any axle.

mm (min 100mm)

Trailer Mass

Gross Trailer Mass (GTM) kg

Laden Mass kg

Unladen Mass kg

Braking System Identification

Braking system component identification number

i.e. Make / part number or markings.

Braking system type

Hydraulic Air Electric Over run Break away etc.

Record hydraulic brake hoses markings provide details from at least one hose

(1) Location

(2) Markings

Tyres

Manufacturer

Model

Tyre size, speed category Load rating of tyre kgs

Tyre Placard (Part Number)


Rims

Manufacturer Model

Rim size Rim offset mm

Trailer Coupling

Hitch type Hitch Capacity kgs

Ball Coupling size (if applicable) mm

King Pin Coupling size & D rating below (if applicable)

KN D rating

Safety Chain(s)

Safety chain(s) fitted? Y N NA

One safety chain < (Less Than) 2500kg Y N NA

Two safety chains > (Greater Than) 2500kg Y N NA

Manufacturers name

Is safety chain marked with AS 4177? Y N NA

Safety chain link diameters 6mm 8mm 10mm

Trailer Lighting

FeatureRecord Lens markings

Height (#) (5) Apart (6) Edge

(3) MAX (4) MIN (#) (#)

Front reflex reflector

(Non-triangular)

Colour – White

900mm

May be increased to 1,500 mm if the body work makes it impractical to keep within 900mm.

250mm 600mm

May be reduced to 400mm if trailer width is 1,300mm.

150mm




(3) MAX (4) MIN (#) (#)

Front. Position Lamp

Required on vehicles more than 4 metres in length. Two white lamps are required if the trailers width exceeds 1600mm. May be amber if incorporated with side marker lamp

1,500mm /

2,100mm

350mm 600mm

Reduced to 400mm if trailer width is 1,300mm.

150mm

Side Reflex Reflector 900mm

May be increased to 1,500mm if the body work makes it impractical to keep within 900mm.

250 The distance between two adjacent side markers shall not exceed 3,000mm. If the structure of the vehicle makes it impossible to comply, this distance may be increased to 4,000mm

Note: Front side reflector to be fitted within 3 metres of the front of the trailer (The front is deemed to be from the coupling rearwards). The rear side reflector must also be within 1,000mm of the rear of the trailer. At least one side reflector also needs to be installed in the middle third of the trailer. The distance between any side reflectors must not exceed 3,000mm. 4,000 mm if body does not allow




(3) MAX (4) MIN (#) (#)

Side Marker Lamps 1,500

Maybe increase to 2,100mm if the body work makes it impractical

600mm The distance between two adjacent side markers shall not exceed 3,000mm. If the structure of the vehicle makes it impossible to comply, this distance may be increased to 4,000mm

150mm

Two side marker lamps showing amber to front and red to rear must be fitted on each side of trailers over 2,100mm wide or having a total length exceeding 7,500mm (including drawbar). Must be fitted within 3,000mm from the front of the trailer. (The front is deemed to be from the coupling – rearwards). The rear side marker must also be within 1,000mm from the rear of the trailer. The distance between any side marker must not exceed 3,000mm. 4,000mm if body does not allow.

End-Outline Marker Lamp

As high as the bodywork will allow. Note Max height requirements for 43/04

>200mm

from Position Lamp

400mm

Required on vehicles more than 2.1 meters wide. If a trailer has no structure at the front or rear, then fitting one end-outline marker lamp midway on each side is acceptable.




(3) MAX (4) MIN (#) (#)

End-Outline Marker Lamp

Required on vehicles more than 2.1 meters wide. If a trailer has no structure at the front or rear, then fitting one end-outline marker lamp midway on each side is acceptable.

As high as the bodywork will allow. Note Max height requirements for 43/04

Direction Indicator Side

1500 /

2,300

350mm

Direction Indicator Rear

1500mm

Maybe increase to 2,100mm if the body work makes it impractical.

350mm 600mm

Maybe reduced to 400mm if the overall width is less than 1,300mm.

400mm

Stop Lamp 1,500

Maybe increase to 2,100mm if the body work makes it impractical.

350mm 600mm

Maybe reduced to 400mm if the overall width is less than 1,300mm.




(3) MAX (4) MIN (#) (#)

Rear Position Lamp 1,500mm

May be increase to 2,100mm if the body work makes it impractical.

350mm 600mm

Maybe reduced to 400mm if overall width is 1,300mm

400mm

Reversing Lamp

Optional

If Fitted One Lamp < 6,000 mm

If Fitted Two Lamps > 6,000 mm

1,200mm 250mm

Centre High Mounted Stop Lamp

<150mm

below bottom edge of rear screen or

> 850 above ground

Reflex Reflector Rear

Colour: - Red.

Non-triangular

900mm

May be increased to 1,500mm if the body work makes it impractical to keep within 900mm.

250mm 600mm

Maybe reduced to 400mm if overall width is 1,300mm

400mm




(3) MAX (4) MIN (#) (#)

Rear Registration Plate Lamp

Such that the device illuminates the site of the registration plate.

Rear Registration Plate

Is there a provision to mount a 372mm x 136mm registration plate on the rear of the trailer and no higher than 1,300mm?

Y N NA

General Trailer Safety Items - Electrical Wiring

Is all wiring support at intervals at not more the 600mm along it length(except for pole trailers)

Y N NA

Is all wiring insulated at the joints and protecting from chafing Y N NA

Wheel Guards (Mudguards)

Do the wheel guards protect other road users against thrown-up stones, mud, ice, snow and water and to the wheel in a collision

Y N NA

Does the rear of the wheel guard including a mudflap (if fitted) need not be less than 230 mm from the ground, or 300 mm in the case of vehicles designed for off road operation.

Y N NA

Visibility of Wheel Guards (Mudguards)

If the trailer’s width is 2.2 meters or more and is of a tray type body, that portion of the external surface of any wheel guard which is visible to the rear. Is the external surface of the wheel guard fitted with white or silver coloured band having a uniform depth of at least 75mm clearly visible?

Y N NA


Sharp edges or protrusions

Is any object or fitting, not technically essential to such vehicle, which protrudes from any part of the vehicle so that it is likely to increase the risk of bodily injury to any person

Y N NA


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