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apache graham

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Forthcoming Legislation

(24/9/2010)

The current European Type Approval legislation for trailers, 71/320/EEC, is due to be rescinded in 2014 and replaced by UN ECE Regulation 13. Part of this Regulation (section 5.2.2.2) stipulates that inertia braking systems will only be permitted on centre axle trailers. This may mean that it will no longer be possible to use inertia braking systems on A-frames.

 

At the moment it is unclear how this change will be interpreted with regard to A-frames. This type of legislation change is not normally retrospective so A-frames currently in use should not be affected, however it is possible that the Department for Transport may take a different view.

 

The next question that arises is how does type approval apply in the case of a car on an A-Frame? Obviously the car will be type approved in it's own right, but what happens when it is converted into a trailer by the addition of an A-frame? It may be that it will be the original supplier/fitter of the A-Frame who will need to ensure that the braking of the combined unit of car + A-frame conforms to UN ECE Regulation 13 for any A-frames supplied or fitted after this regulation comes into force. However, until the DfT make a decision it would be unwise to make any assumptions!

 

The current situation:

Note on A-Frames and Dollies, issued by the Department for Transport

When an "A" frame is attached to a vehicle (e.g. a motor car) and towed by a motor vehicle (e.g. motorhome) we believe the "A" frame and car become a single unit and as such are classified in legislation as a trailer. As a consequence the car and A-frame are required to meet the technical requirements for trailers when used on the road in Great Britain. These requirements are contained within the Road Vehicles (Construction and Use) Regulations 1986 (SI 1986/1078) as amended (C&U) and the Road Vehicles Lighting Regulations 1989 (SI 1989/1796) as amended (RVLR).

 

Trailers having a combined axle mass not exceeding 750kg are not required to have brakes fitted. However, if the trailer (regardless of mass) is fitted with a braking system, then all brakes in that system must operate correctly. The regulations do not include design constraints on how this should be achieved but, for example, it could be met by direct linking of the trailer brakes to the brake system of the towing vehicle or by automatic inertia (overrun) operation via the towing hitch. Inertia systems can only be used for trailers with a maximum combined axle mass of 3500kg.

 

Regulations 15 and 16 set out the braking requirements - including minimum braking efficiencies for trailer brakes. Subject to certain age exemptions, the regulation requires the braking system to comply with the construction, fitting and performance requirements of European Community Directive 71/320/EEC along with its various amending Directives. The most recent consolidated directive is 98/12/EC. Alternatively the braking system can comply with the corresponding UNECE Regulation No.13.09.

 

In addition, C&U Regulation 18 requires the braking system to be maintained in good and efficient working order. If the brakes of the towing vehicle do not directly operate the trailer brakes the use of an inertia (overrun) system is acceptable. If the trailer braking system has power assistance (i.e. servo or full power) it is likely that this assistance will be required while in motion to meet the required braking efficiencies. This is because once the vacuum reservoir is depleted it is possible that the brakes will not meet the braking efficiency. To prevent the trailer being used illegally a remote vacuum pump, powered from the tow vehicle, could be installed to recharge the reservoir, alternatively a source could be made available from the tow vehicle. From 1 October 1988 the inertia braking system was required to allow the trailer to be reversed by the towing vehicle without imposing a sustained drag and such devices used for this purpose must engage and disengage automatically. This will be very difficult to achieve on an "A" frame using an inertia (overrun) device.

 

Other provisions from Regulation 15 and Regulation 86A of C&U require the fitting and use of a secondary coupling system in which the trailer is stopped automatically if the main coupling separates whilst the combination is in motion. Alternatively, in the case of trailers up to a maximum mass of 1500kg, the drawbar must be prevented from touching the ground and the trailer able to retain some residual steering.

 

Whilst being towed, trailers are subject to the relevant requirements given in RVLR, including the use of triangular red reflectors. There would be further requirements for the display of the appropriate number plate, etc.

 

The use of "dollies" is intended for the recovery of broken down vehicles, not for the transportation of a vehicle from "A" to "B". Under Regulation 83 of C&U a motor car is permitted to tow two trailers when one of them is a towing implement and the other is secured to and either rests on or is suspended from the implement. Therefore as a trailer if the maximum laden weight of the dolly exceeds 750 kg it must be fitted with operational brakes, additionally the brakes on the wheels of the second trailer (the towed car) must work and meet the specified requirements. Again this would be very difficult for the rear brakes of a motor car, on their own, to meet the 50% braking efficiency required for a trailer. The dolly would also be required by Regulation 22 of C&U to be fitted with suspension. Regulations 19 and 22 in C&U permit a broken down vehicle to be recovered without complying with these requirements. However, there is further legislation under the Road Traffic Act that introduces a limitation on the maximum speed that the combination can be driven; this is 40mph on motorways and 20mph on other roads.

 

We do not supply copies of legislation but I have included some information on various sources where they can be obtained. If you would like to purchase printed copies of Statutory Instruments these are available from TSO:

 

The Stationery Office Tel: 0870 600 5522

PO Box 29 Fax: 0870 600 5533

St Crispins e-mail: book.orders@tso.co.uk

Duke Street online ordering: www.tso.co.uk/bookshop

Norwich NR3 1GN

 

Alternatively you can consult "The Encyclopaedia of Road Traffic Law and Practice" published by Sweet and Maxwell. This publication is updated regularly and is available in most city reference libraries.

 

EU Directives can be found at:

http://europa.eu.int/eur-lex/en/search/search_lif.html

 

UN-ECE Regulations can be found at: http://www.unece.org/trans/main/wp29/wp29regs.html

 

From the above I hope it is clear that we believe the use of "A" frames to tow cars behind other vehicles is legal provided the braking and lighting requirements are met. However, while this is our understanding of the meaning of the Regulations, it is only the Courts which can reach a definitive interpretation of the law.

 

 

Alan Mendelson

Primary Safety Branch

Department for Transport

 

 

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Guest 1footinthegrave

Blimey, that's a lot to take in.

 

But playing devils advocate for a minute, someone said something to me that stopped me in my tracks when I was thinking about getting a small citi car to tow when I had my coach built. That was why have a motor-home at all, surely it would make far more economic sense to have the car towing the accommodation. I was stumped for an answer really. :-|

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1foot-

 

I have seen 2 fourbies overturned by the caravan they were towing.

 

I don't want to drive around at home in the size of car I would need to tow a caravan with the facilities I have in the Rapido.

 

Sometimes I want to go away with just my 'caravan' (motor caravan) try that with a car, caravan set up.

 

It upsets people who don't like 'A' frames!

 

I can afford it.

 

Enough reasons for me.

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I will continue to use my a-frame until I am physically stopped and prevented from doing so.

 

Like the above I like and prefer to tow a car.

 

In 7 years of winter travelling in Spain and France I have never been stopped and I have seen many many police etc who have totally ingored us.

 

If it means fitting a brake buddy to comply then as and when I will

 

 

Richard from sunny Conil de la frontera Spain

 

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1footinthegrave - 2011-03-12 1:43 PM

 

Blimey, that's a lot to take in.

 

But playing devils advocate for a minute, someone said something to me that stopped me in my tracks when I was thinking about getting a small citi car to tow when I had my coach built. That was why have a motor-home at all, surely it would make far more economic sense to have the car towing the accommodation. I was stumped for an answer really. :-|

I towed Caravans for many years with no problems at all ,and as long as they are loaded and weight matched to to the tow car etc they are safe and lots of fun. I have had several Motorhomes as well and currently have a Motorhome and can't honestly say that one is better than the other, both have their Pro's and Con's,it is a matter of choice of course, what I will say though is that I would never tow a car behind my Motorhome, I would definately revert back to car and Caravan before I did that.I think that the Car a Tow system will eventually go the way of Bull Bars, [ remember those? ] to the scrap yards .Just my opinion.
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I am partially inclined to agree with vindiboy, I to used to tow a caravan, however, due to an accident 6 years ago it became to much, so I brought a 7.4 metre motorhome which was a revelation and so much easier, although it present the problem of parking?

 

To get aroung this we eventually brought a Toyota Aygo which we tow behind the motorhome using an A frame, so now we are back to square one, I used to put my mobility scooter easily in the back of the towcar, but stuggle to fit it the back of the Aygo?

 

The majority of motorhomes have a limited towing weight, our Autotrail Cheynne 660 has limit of 1040 kg, enough for the Aygo and A frame, but not enough for a Toyota Aygo and Trailer, how many motorhomes are exceeding their limits ?

 

If the 2014 Law outlaws A frames I will be inclined to go back to towing a caravan.

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Melvin - 2011-03-12 1:33 PM

 

Forthcoming Legislation

(24/9/2010)

The current European Type Approval legislation for trailers, 71/320/EEC, is due to be rescinded in 2014 and replaced by UN ECE Regulation 13. Part of this Regulation (section 5.2.2.2) stipulates that inertia braking systems will only be permitted on centre axle trailers. This may mean that it will no longer be possible to use inertia braking systems on A-frames.

 

[snip rest of copied article]

 

I'm glad that you found my piece useful. A credit for the source would have been appreciated.

 

Andy

 

 

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Melvin - 2011-03-12 5:53 PM

 

Sorry had no intention of offending you, your name and title is at the bottom, I just copied and pasted the article.

You missed the copyright statement at the bottom of the page, I take it?

 

The name at the bottom of the article is not mine, it's the name of the person at the Department for Transport who provided the information.

 

Andy

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Guest 1footinthegrave
I said in my OP, "playing devils advocate" has obviously literally bought the devil out in some, oh dear >:-(
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Andy_C - 2011-03-12 6:18 PM

 

Melvin - 2011-03-12 5:53 PM

 

Sorry had no intention of offending you, your name and title is at the bottom, I just copied and pasted the article.

You missed the copyright statement at the bottom of the page, I take it?

 

The name at the bottom of the article is not mine, it's the name of the person at the Department for Transport who provided the information.

 

Andy

 

Andy again I do apologies, I did miss the copyright statement, I think it would be better if the Administrator removed the offending article.

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Andy_C - 2011-03-12 6:18 PM ..........You missed the copyright statement at the bottom of the page, I take it? The name at the bottom of the article is not mine, it's the name of the person at the Department for Transport who provided the information. Andy

So, if I understand, if the the copyright in that piece belongs anyone, it actually belongs to the Crown?  The information was provided by a Civil Servant as part of his normal employment, and the copyright cannot then "belong" to you (or anyone else), even if addressed to you.

The inclusion of a credit to yourself or your forum would have been a courtesy, and would have been nice, but the omission was clearly an oversight for which Melvin has apologised.

Anything placed on the net, in a public forum, is liable to go "viral", it is just a fact of forum life.  That apart, I can't understand what you are trying to achieve: to intimidate everyone here onto http://www.ukmotorhomes.net/?  If so, if I may say, it seems a pretty ham-fisted way to go about it.

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Guest peter
Melvin - 2011-03-12 1:33 PM

 

Forthcoming Legislation

(24/9/2010)

The current European Type Approval legislation for trailers, 71/320/EEC, is due to be rescinded in 2014 and replaced by UN ECE Regulation 13. Part of this Regulation (section 5.2.2.2) stipulates that inertia braking systems will only be permitted on centre axle trailers. This may mean that it will no longer be possible to use inertia braking systems on A-frames.

 

So, please explain how that affects a 4 wheel twin axle trailer.
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Brian Kirby - 2011-03-12 7:37 PM
Andy_C - 2011-03-12 6:18 PM ..........You missed the copyright statement at the bottom of the page, I take it? The name at the bottom of the article is not mine, it's the name of the person at the Department for Transport who provided the information. Andy

So, if I understand, if the the copyright in that piece belongs anyone, it actually belongs to the Crown?  The information was provided by a Civil Servant as part of his normal employment, and the copyright cannot then "belong" to you (or anyone else), even if addressed to you.

The inclusion of a credit to yourself or your forum would have been a courtesy, and would have been nice, but the omission was clearly an oversight for which Melvin has apologised.

Anything placed on the net, in a public forum, is liable to go "viral", it is just a fact of forum life.  That apart, I can't understand what you are trying to achieve: to intimidate everyone here onto http://www.ukmotorhomes.net/?  If so, if I may say, it seems a pretty ham-fisted way to go about it.

The copyright is in the whole work which includes, by permission, and credited, information provided by the Department for Transport.I do take exception to being accused of intimidation, I have not, as you can see, even given a link to the original piece!Incidentally I've also found that entire article, and several others of mine, reproduced in their entirety on another website. I suppose that's 'just a fact of forum life' too, which makes it all right?Anyway, I've made my point about copyright, hopefully it will make people think about at least crediting the original when they copy and paste articles into forums.Andy
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Guest 1footinthegrave

This is what I love ( not ) about these forums, it soon turns into a cyber punch up. If the guy who's objecting as far as I can see about something that he was the original author of perhaps a PM may have been the way to go, but the guy apologized, just get over it.

I do however think there should be as a matter of urgency a way of deleting a post if that is an option the poster would prefer. But you know what, there are far worse things going on in the world, especially right now. :-( :-(

 

P.S a big thank you to Brian Kirby for the UKMotorhomes.net link, this is a new site I had yet to discover, seems a mine of useful information.

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Andy_C - 2011-03-12 9:35 PM .............. The copyright is in the whole work which includes, by permission, and credited, information provided by the Department for Transport.

Then, I have to say I believe you are wrong in that understanding.  Copyright resides with the author of a work, not with someone else who reproduces it, unless they have specifically been granted copyright, usually in return for payment.  Agreeing to publication of a work on an internet site is not a grant of copyright, it is merely an agreement that it may be reproduced without breaching copyright.  As the information reproduced from your piece was, as I stated, produced by a Civil Servant in the normal course of his work, you are not entitled to claim copyright on it.  The copyright, properly, in my understanding, belongs to the Crown but, since the information Mr Mendelson very helpfully sets out is all a matter of public record, and is openly available from a variety of publicly, and freely, accessible government sources, it seems the claim to copyright cannot in any case be exercised.  You may claim as you wish, but the claim does not confer title.

I do take exception to being accused of intimidation, I have not, as you can see, even given a link to the original piece!

I cannot think of any reason other than intimidation for your citing copyright - especially as I believe you must know your claim to hold copyright is erroneous.  The man had apologised for his oversight, so what other purpose for your (rather sarcastic) rejoinder citing (I think fictitious) copyright, could there be?

Incidentally I've also found that entire article, and several others of mine, reproduced in their entirety on another website. I suppose that's 'just a fact of forum life' too, which makes it all right? ............. Andy

To some extent yes, it is a fact of forum life, and one does have to accept that.  Does that make it right?  Not necessarily, but one has to be realistic.  You obtained information from a government source, and sought permission to reproduce it on an internet site.  Your purpose was presumably, to inform, and that purpose was presumably understood by Mr Mendelson in granting permission for its publication.  Its further publication on this forum seems not to breach that understanding, and the more people who are informed on the subject, presumably, the better.  I'm sorry, but I therefore cannot understand why you appear to be seeking to claim ownership of information gained at the public expense, for public consumption, and being so used, of which you were not the author.

As I said, there seems merely to have been a breach of courtesy, for which oversight an apology was given.  I'm rather with Peter on this: what more do you want?

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apache graham - 2011-03-13 12:18 PM

 

Many thanks Melvin,

WOW alot to take in, but I am thinking of a towcar of 400kg (Micro Car) and as it has its own brakes I assume they must work when attached to motorhome via an 'A' frame.

Many Thanks.

 

I did not write the document Andy C is the author, I just copied and pasted it. As regards the forthcoming legislation I would not worry to much, there will always be some genius who will provide a solution.

 

As regards the tow cars brakes you are 100% correct.

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Brian Kirby - 2011-03-13 12:48 PM
Andy_C - 2011-03-12 9:35 PM .............. The copyright is in the whole work which includes, by permission, and credited, information provided by the Department for Transport.

Then, I have to say I believe you are wrong in that understanding. 

We'll have to agree to differ then.
I'm rather with Peter on this: what more do you want?
I think the point has been made that it is not necessarily OK just to copy & paste articles into forums. If, as a result of this episode, more people realise that, so much the better.I'll say no more on the subject now - that should please everyone :-) Andy
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Guest 1footinthegrave

I could not agree more.

 

Sadly this seems par for the course. Someone posts a question, hoping to receive an informed bit of advice, hopefully from someone with first hand experience, then before you know it someone picks up on some perceived slight, or other issue,then what was a useful thread for the original poster all goes belly up. You have to scroll through sometimes pages of sheer dross, a pity really because there are some very useful posters, with good advice, then there's the rest. I've only been using this forum a matter of a few weeks, but the same offenders seem to crop up. Oh well take from it what you can. :-|

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