An adequate payload - 2? Correction.

[Brian Kirby]

My thanks to Paul (Rosbotham) for pointing out that I had inverted the dates at which TA is due to come into force for new, and existing models, in my original post on the above. Apologies to all for any confusion caused.

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Maybe some good news on this front, at last!  My thanks to John Meadows (Meadows Engine), and through him the Caravan Club’s technical department, for this.

It seems things have been moving within the EEC, and a new Directive, 2007/46/EC, will come into force on 29 April 2011.  This Directive requires EC Type Approval (TA) for all new motorhomes.  New models (those not yet in production) must be Type Approved by the above date.  All existing models (those already in production) must have gained TA by 29 April 2012.  Vehicles that have not gained TA by the relevant dates may not be sold, or registered, after those dates.  This does not apply to second-hand/pre-registered vehicles, only to new and un-registered.  (I assume there must be provision for dealer’s existing stock, but have no details of this.) 

The Euro sceptics will presumably all now begin groaning about more Euro red tape, and about how the price of motorhomes will inevitably increase with no benefit to the consumer, etc. etc.  But wait, oh ye of little faith, there is more!

Under an earlier Directive, 92/21/EEC, which is embraced by 2007/46/EC, there is already legislation on what is to be taken into account in calculating payloads.  In essence, this is as contained in BS EN 1646-2: but it now becomes mandatory, gains some beneficial clarifications, and a couple of interesting additional requirements.  There are also a few new terms that have been adopted.

To recap, from 29 April 2012 all motorhomes sold and registered new must carry European Type Approval, and all new models must have this by 29 April 2011.  To gain TA, they must have a minimum payload calculated as follows.

Mass in Running Order (MIRO) is changed specifically for motorhomes.  It is now the unladen weight of the motorhome, plus all standard tools (jack, wheelbrace etc), spare wheel or puncture repair kit, and fuel tank 90% full, but without a driver.  (The term “empty” is used in 92/21/EEC for this variant of MIRO.)  Note that MIRO is still subject to a ±5% tolerance.

Mass of Conventional Load (MCL), is a new definition, and is the weight of the passengers that may be carried.  It is calculated at 75kg per belted travel seat, including the driver’s seat.

Mass of Load in Excess (MLE), is also a new definition, and is the allowance for the weight of luggage, equipment, gas, and water.  It includes the weights of the water and gas reservoirs 90% full, plus an allowance for luggage and equipment to be calculated according to the formula (L x 10KG) + (N x 10kg), where L is the vehicle length in metres and N is the number of belted travel seats.  This load is to be distributed “according to the indication of the manufacturer in agreement with the technical service, in all luggage compartments.”  The “technical service”, is the certifying agency, such as MIRA.  It may, but is not required to, include the weights of any optional equipment.

(For vans with gas lockers that can take more than one cylinder, it would be wise to check whether the load used was two cylinders @ 90% or one, of what size, and whether of steel, aluminium, or other, construction.  The weight differences can be considerable: 1 13kg steel cylinder 90% full weighs around 28kg, whereas an 11kg aluminium cylinder 90% full is only 16kg.  Most German converters quote 11kg aluminium cylinders, because they are the most commonly used in Germany.)

The interesting additional requirements are 1) that MIRO + MCL + MLE must not result in any axle being overloaded, and 2) that “Where the vehicle and, at the same time, its rear axle are laden to the technically permissible maximum mass, the mass bearing on the front axle must be not less than 30 % of the technically permissible maximum mass of the vehicle.”  (The latter should be of value for FWD chassis with garage type layouts and long rear overhangs, where traction problems can result.)

What this means is that from 29 April 2012 for existing models, and from 29 April 2011 for all motorhomes, sold new, payload must be calculated in accordance with the above requirement, and the vehicles will only gain TA if they meet these requirements.  Under 70/156/EEC, all TA vehicles must be supplied with a Certificate of Conformity (CoC), that will, among other things, state the MIRO, the Technically Permissible Maximum Mass (TPMM, hitherto MAM), and the individual axle loads at MIRO and TPMM.  (Unless you ask to see the CoC, my guess is that it will merely be handed over with the registration document, so asking for a copy before placing an order will possibly be a wise move.)

The requirement does not establish a maximum payload, but it does establish a minimum payload below which TA will not be granted.  Without TA, the vehicle may not be sold, or registered.

It is still somewhat short of perfect, IMO, but nevertheless represents a huge step forward compared to the status quo.  We shall still have to be mindful of the +5% tolerance on MIRO, that will still have the potential to reduce payload, and that the payload calculation that must be used to gain TA will still represent only a fair minimum.  However, taken together, a lot more light will be shed, more consistently, on weights and payloads than at present, and that, IMO, is a good thing.

The one downside I can see is that if you want a towbar, because the vehicle will be TA, so too must the towbar, as with TA cars: meaning that for coachbuilt motorhomes the towbar will have to come from the motorhome converter (possibly AlKo if an AlKo chassis or chassis extension has been used) because it is improbable that the likes of Witter etc will manufacture towbars to fit every variant, of every make, of motorhome.  For van conversions (PVCs), things should be easier, because the basic bodyshell is unaltered and the designated fixing points should be accessible (unless someone has cleverly mounted the grey water tank to obstruct them!).  Anyone contemplating fitting a towbar would therefore be wise to investigate availability, and fitting access (in the case of PVCs), before buying the motorhome of their dreams.

[rupert123]

Brian reading through that lot it would appear that some of the new vans with the low spare payload might not be as bad as first seen if they comply with these new rules.

[Vernon B]

What I think is surprising is that we, and more importantly the regulatory authorities, appear to have accepted that a weight tolerance of -/+ 5% is unavoidable for this type of vehicle manufacture.

In my view this is more appropriate to the thing being put together by a blacksmith! Given the type of manufacture currently being adopted in the industry there is no technical reason why the tolerance shouldn't be nearer 0.5%- which would go a long way to resolving the problems that all too many owners have encountered.

 

V

[Brian Kirby]

Vernon B - 2010-12-13 9:20 PM What I think is surprising is that we, and more importantly the regulatory authorities, appear to have accepted that a weight tolerance of -/+ 5% is unavoidable for this type of vehicle manufacture. In my view this is more appropriate to the thing being put together by a blacksmith! Given the type of manufacture currently being adopted in the industry there is no technical reason why the tolerance shouldn't be nearer 0.5%- which would go a long way to resolving the problems that all too many owners have encountered. V

It seems to me unreasonable the customer has to accept any of the risk: there is no reason the bar could not have been set at +0%/-10%.  Same spread, but the manufacturer would assume all the risk.  If so minded, he could, in any case, bind himself to that spread.  In fact, I can't see any point in limiting the negative tolerance at all.  Just state the MIRO must be equal to, or less than, Xkg and let the maker sort out his suppliers.

The reason for the tolerance is the amount of wood used in construction.  Being a natural material it is variable in density, and also absorbs and gives off moisture, so changing in weight almost continually.  You can buy kiln dried at a fixed % moisture content, but even after being built into a van, after a couple of damp days out of doors, it will have absorbed atmospheric moisture and will weigh more.

However, all would mean is that the manufacturer would need to work to a worst case figure rather than a mid-point.  Possible, but clearly unattractive to the manufacturers, as the difference is worth 150kg of saleable payload on a MIRO of 3,000kg.  Consumer representation at standards committee meetings is very limited, to none.  Who gets invited?

[Brian Kirby]

rupert123 - 2010-12-13 9:19 PM Brian reading through that lot it would appear that some of the new vans with the low spare payload might not be as bad as first seen if they comply with these new rules.

Some, no, Henry, but it doesn't work so well in all cases.  If you buy a 4 belted seat van for two people it should more or less be OK.  However, buy a two belted seat van, and you can see trouble looming.  Trying to occupy any van to the maximum number of belted seats, especially with adults will also be likely to cause problems.  Oh yes, and don't rely on the formula for happiness if you weigh more than 75kg!  It is, IMO, an improvement, but it is far from being failsafe for the buyer.

[art338]

I consider myself almost skinny yet I weigh 75Kg, without the seat.

 

art

[peedee]

Great posts Brian, thanks. However, I fear for the small manufacturer/converter who is already hard pressed and whose overheads will be increased. It could be the death of some and result in at the very least a more expensive product and possibly less choice for the consumer.

 

peedee

[Guest JudgeMental]

Maybe small bespoke companies product (already to expensive IMO) will become subject to singe vehicle approval. call VCA and you will soon know......

 

Anyway 2 calls to the VCA yesterday and 2 to the DVLA and this really is a nonsense as The situation remains the same for all of us that import vehicles covered by a COC from within the EU. In that you just need to get a speedo overlay, lights changed and fog light moved before registering with DVLA or else at least have the orders for the parts with your paperwork while registering it with local DVLA office. Exactly as I did in 2007

 

as for the +- 5% Mine was under, Brian's was under...whose has been over I wonder? *-) Again if buying from a major European manufacturer no need to worry I would think.

 

Happy camping...but please make sur you buy the right camper to begin with :-D

[pepe63xnotuse]

Probably not the thread to ask this on... :$

..but just out of curiosity,what is the next "threshold up" after 3.5t?

..is it just a clear run to 7.5t,license permitting?

 

Chris

 

 

[Brian Kirby]

JudgeMental - 2010-12-14 9:34 AM ................... Anyway 2 calls to the VCA yesterday and 2 to the DVLA and this really is a nonsense as The situation remains the same for all of us that import vehicles covered by a COC from within the EU. In that you just need to get a speedo overlay, lights changed and fog light moved before registering with DVLA or else at least have the orders for the parts with your paperwork while registering it with local DVLA office. Exactly as I did in 2007 as for the +- 5% Mine was under, Brian's was under...whose has been over I wonder? *-) Again if buying from a major European manufacturer no need to worry I would think. Happy camping...but please make sur you buy the right camper to begin with :-D

But this was never about importing, Eddie, it was about Type Approval being required for UK manufactured motorhomes.  There will be greater clarity on what is included within the payload, because they will all now have to calculate MIRO in the same way. 

Hitherto, they have been able a) to calculate MIRO on any basis they chose, b) not to set out clearly what that basis was, and c) declare the whole of difference between that and MAM as payload.  That is why some vans have appeared to have reasonable payloads when in fact, their payloads were wafer-thin.  At least now the fact of the wafer thin payload will be clear, albeit buyers will still need to know how much payload they will be likely to need.  That problem is not solved, but the baseline for the calculation will be consistent.

German motorhomes have had to have TA for years, which is why you and I have been able to get a CoC on importing, and why their figures have been so much more reliable and transparent.  In effect, the UK manufacturers will henceforth have to play by the same rules as the Germans.

[Brian Kirby]

pepe63 - 2010-12-14 11:10 AM Probably not the thread to ask this on... :$ ..but just out of curiosity,what is the next "threshold up" after 3.5t? ..is it just a clear run to 7.5t,license permitting? Chris

If you mean what is the next base vehicle chassis weight above 3,500kg, there is no fixed increment.  It depends on what the base vehicle manufacturer chooses, and what each converter selects.  They tend to have slightly differing incremental steps, so you have to look at the MAM's of the vans.

[Brian Kirby]

peedee - 2010-12-14 8:53 AM Great posts Brian, thanks. However, I fear for the small manufacturer/converter who is already hard pressed and whose overheads will be increased. It could be the death of some and result in at the very least a more expensive product and possibly less choice for the consumer. peedee

I have far more fear, and concern, for the buyer, than for the converter.  Some of these small production converters - even some with award winning products - have plainly been guilty of serving up vans with ludicrously small, and very poorly explained, payloads.

In part, the imposition of TA is a result of their misleading behaviour: it is because products were being misleadingly described, that TA was first introduced.  When the product in question costs in excess of £30,000, that ambiguity, for which there was no need, is, IMO, inexcusable.

So, if the weak go to the wall, because they now have to do what they should have been doing all along in the interests of their customers, I'm afraid my response is: tough!  Sow dragons teeth etc.

[pepe63xnotuse]

Brian Kirby - 2010-12-14 12:01 PM

pepe63 - 2010-12-14 11:10 AM Probably not the thread to ask this on... :$ ..but just out of curiosity,what is the next "threshold up" after 3.5t? ..is it just a clear run to 7.5t,license permitting? Chris

If you mean what is the next base vehicle chassis weight above 3,500kg, there is no fixed increment.  It depends on what the base vehicle manufacturer chooses, and what each converter selects.  They tend to have slightly differing incremental steps, so you have to look at the MAM's of the vans.

Thanks Brian.I didn't think that there was another increment..but I just wasn't sure if there was any additional legislation which may've "artificially" limited the use of base vehicles with heavier gvw(number of people carried,tachos etc)Thanks againChris

[peedee]

Brian Kirby - 2010-12-14 12:15 PM

Some of these small production converters - even some with award winning products - have plainly been guilty of serving up vans with ludicrously small, and very poorly explained, payloads.

But only some Brian, not all. Even the good ones and those that then conform are going to pass on these overheads. They have no choice because of the volumes they produce. The big boys may well be able to absorb the costs but I doubt the small manufacturer/converter can.peedee

[Brian Kirby]

peedee - 2010-12-15 8:08 AM .............But only some Brian, not all. Even the good ones and those that then conform are going to pass on these overheads. They have no choice because of the volumes they produce. The big boys may well be able to absorb the costs but I doubt the small manufacturer/converter can. peedee

Better a product that does not mislead its buyer, even at a higher price, than one that is cheap, but cheats its buyer.  Depends whose side you are on, buyer, or seller.  I'm on the buyer's side.

[grahamw]

Brian Kirby - 2010-12-16 12:05 AM

Better a product that does not mislead its buyer, even at a higher price, than one that is cheap, but cheats its buyer.  Depends whose side you are on, buyer, or seller.  I'm on the buyer's side.

 

Can I start Brian by thanking you for what has been an exceptionally useful series of posts. I have found them valuable.

 

I post though because I am not sure whether or not we are being entirely fair to constructors here in the UK. My experience has mainly been with PVC vehicles and I have not encountered one constructor yet who in any way has attempted to deceive or conceal information from me. I think the problem arises simply because there has been no binding requirement to present the information in a particular way. Why should one constructor make his vehicle appear inferior to the unknowing customer by stating payload with reserviours 90% full when his neighbour doesn't. His product may not get beyond the brochure viewing stage. One van converter has indeed said to me that it's an important area that he prefers to discuss with potential customers as what will affect payload with his product will do exactly the same with his competitors and he can also point out what has or has not been included in making the calculation with his products and his competitors. I know he welcomes the prospect of all constructors singing from the same hymn sheet as it would make his life easier.

 

Although I understand the issue I look forward to it too. Your quote above I believe says exactly the same thing but I do not believe that the "misinformation" is the result of devious constructors on the whole, more a result of the lack of a legally binding guidance requirement. I'm not saying you have said that constructors are devious Brian but taking the thread as a whole some people may walk away with that view. Now dealers, that's a different ball game!

 

Graham

[Brian Kirby]

I agree that the peer group pressure on converters will be a great concern for them in presenting payload values.  However, it only takes one to set out their calculation clearly for the omission of such clarity by others to become relatively apparent.  They need not do this in their brochure, but they should do it when refining the specification with prospective buyers. 

There are several things about the payload calculation, as now to be used for Type Approval purposes, that are a long way short of perfect.  Most obvious is the way it works if only two belted seats are installed, where the payload will remain adequate for a weekend, but little else, and where buyers expect to have adult sized occupants on all belted seats.

I think one has a right to expect the manufacturer of a product to have some expertise on how it may be used, as well as on how to screw it together.  After all, he makes it to supply a market, so he needs to understand his market to be able to satisfy customer expectations.

I don't really care how they set out the figures, but am of the opinion that they should be set out on the order form, and that this would not be a difficult thing to achieve.  Have a look some time at a Hymer price list.  On that you will find the weights, as well as the prices, of the various options on offer.  Most order forms show the buildup of the price, to confirm the variants and options selected.  An additional column could just as easily be included to show the weights of these items, and their impact on payload.  That would provide proof positive that the manufacturer had confirmed back to the buyer exactly what he had ordered, and what the resulting payload would be.  A covering letter, confirming the manufacturer's understanding of the intended use of the vehicle, and any reservations he may have regarding adequacy of payload, with an invitation to the prospective buyer to advise if he wished to change any of the specification, within a defined period, would ensure both parties understood what was to be manufactured.

I don't see that as particularly onerous: indeed, it seems to me little more than good business practise, and a basic courtesy to his client to do so.

[grahamw]

Brian Kirby - 2010-12-16 5:14 PM

However, it only takes one to set out their calculation clearly for the omission of such clarity by others to become relatively apparent. .

I think in an ideal world that is certainly true. It does assume that clients are informed and aware sufficiently to detect the omissions that makes things unclear. Sadly this is not the case and hence the need for new leglislation. I think your ideas regarding detail on the order form of weights and prices as the order is built up is excellent. Essentially it makes a contractual agreement between the manufacturer/dealer and the buyer as to what has been ordered with the implications for payload spelt out very clearly. I'm not sure how "a covering letter confirming the manufacturer's understanding of the intended use of the vehicle and any reservations he may have regarding adequacy of payload" would have any validity when the understanding is formed between expert and non-expert parties. What might constitute an understanding? Probably at that point I have to exit into the "non-expert" party. Graham

[Guest JudgeMental]

Dont be so naive or dishonest for heavens sake! those producing vans know exactly the situation regards the products they are selling, and if they dont should not be in the business! It was a problem with a UK Murvi PVC that started of all this rash of threads on this subject...

 

 

The sooner some regs and transparency comes into force the better. The smaller manufacturers should be better then this, faster to react to shortcomings dont you think....

[grahamw]

Not sure if your comments Judge are directed at me or not but as I was the last to post prior to you I can only assume they are.

 

If it's me they are directed at they leave me a little confused as I agree with all your sentiments as will be apparent if you read all my postings in this thread, but as for being naive or dishonest I'm really at a loss to understand your reasoning.

 

Graham