flicka Posted January 14, 2007 Share Posted January 14, 2007 I posted an earlier thread regarding BS EN 1646 in respect of Hazard labels for Gas Bottle Lockers. Looking at various threads here and on other forum, I have come to the conclusion that very few M/H manufacturers are actually producing their product to this Specification. As the Specification is now applicable across the EC by it's adoption as an EN Standard, how do they get type approval and CE conformity ? Consumers would not expect to purchase goods which do not have CE marking. I understood that any Manufactured Product sold in the EU has to be CE Marked, or are Vehicles exempt Anyone out there involved in Trading Standards who can elaborate on this, please. Flicka Link to comment Share on other sites More sharing options...
michele Posted January 14, 2007 Share Posted January 14, 2007 Flicka, laymans terms please ..... This is the chatterbox not serious deep deep undercover box .. please explain to a thicko . Thank you :D Link to comment Share on other sites More sharing options...
Derek Uzzell Posted January 15, 2007 Share Posted January 15, 2007 Flicka: There's a lengthy section on motorhome-related Standards and Regulations towards the back of John Wickersham's "The Motorcaravan Manual". I'm sure you'd find this valuable for background. I haven't delved deeply into CE Markings but I'd take an educated guess from what I've seen that, although a huge number of the components used in a new vehicle will clearly need to be CE Marked, the complete vehicle itself will be exempted from marking requirements. Anyway, it's evident via GOOGLE that there's plenty of internet-available information out there on CE Marking for you to get your teeth into if you are prepared to spend the time. I'm doubtful that EN 1646 (or any of the other ENs applying to motorhomes) has any direct bearing on European Whole Vehicle Type Approval (EWVTA). The EWVTA Certificate of Conformity (CoC) for my 2005 Hobby carries a mass of 'vehicle-related' data, but there's nothing that's specifically 'motorhome-related'. I suppose it's possible that a motorhome's payload (as defined in EN 1646-2) might affect the number of seats datum shown on the CoC, but I think it far more likely that, for Type Approval, this figure will be controlled by seat-belt regulations. Returning to Square One, what has made you conclude that the majority of motorhome builders are producing vehicles that fail to conform to EN 1646 codes of practice? It's an unfounded criticism in my view, so can you provide some convincing examples, please? (I agree with Michele - you'd have more chance of reasoned responses if you'd posted to the Motorhome section.) Link to comment Share on other sites More sharing options...
flicka Posted January 15, 2007 Author Share Posted January 15, 2007 Sorry for posting in Chatterbox, forgot which forum I was in & don't know how to move it across. Derek I agree the Equipment in a van is all CE marked, but what about the Van itself , what applies. I understood the "type conformity" is subject to Crash testing ? and I don't see any evidence of this with coachbuilts. Van conversions are different as the crash test on the base vehicle (Fiat, Peugeot, et al) will be applied presumably. The addition of a coachbuilt body is a different matter, as it changes the characteristics of the vehicle, height width, weight distribution, etc.. Regarding your view that my conclusion is unfounded criticism My conclusion is drawn from reviewing numerous M/H manufacturers brochures/websites and physically viewing alot of vans throughout last summer. I only found 3 manufacturers who mentioned EN 1646 in their literature or websites. (or 6 if you break it down into "brand names") and did not see many vans displaying the EN1646 badging. Please note I have only looked at Coachbuilts. So ratio wise, those manufacturers not stating EN 1646 compliance are in the majority. I stand to be corrected, but would assume if compliant with the Standard, the manufacturers would be singing it from the rooftops (or perhaps that should that be their Van roofs.) Flicka Link to comment Share on other sites More sharing options...
Brian Kirby Posted January 15, 2007 Share Posted January 15, 2007 JohnI think you'll find that EN 1646 is treated in most other EC states as it is in UK. That is to say it has been adopted as a national standard, in our case a British Standard. It thus becomes BS EN 1646, and I know that in Germany it is DIN EN 1646. The standards are not, in themselves, mandatory: in other words it is not obligatory to comply with them. However, if the standard is cited by a manufacturer as having been complied with, the product must, so far as I am aware, comply fully - they cannot cherry pick, and then claim to meet the standard, on the basis of only partial compliance.The purpose of these standards is to establish a reasonable minimum standard for whatever sphere of activity they relate to. Thus, manufacturers can claim compliance while exceeding the requirement, but may not do so if falling below the prescribed measures. What it seems some may be doing, is selectively meeting some of 1646, but not all of it. Provided they do not calim to comply, there is nothing to stop them doing this. It seems likely the major safety related issues would probably be met, because that would give the manufacturer a good defence in court were his product to be cited as dangerously defective. His defence probably be along the lines that it fully met the minimum prescribed safety standard, although he did not claim full compliance. As is traditional, someone would then have to prove otherwise!In the case of the labels, if there is only a recommendation that the hazard warning should be attached to the gas locker door, and one is not fitted, it is arguable that no one, in fact, suffers - so long as the vehicle stays clear of road accidents where fire is involved! I also suspect it would be the vehicle owner who, actually, had responsibility for ensuring the label was present and correct. I don't think he/she could get back at the manufacturer for failure to supply the van with the label, since there would have been no gas cylinders present when the 'van left the factory. The dealer selling, if they supplied the cylinders: maybe, but it is all a bit tenuous and would probably turn on whether the dealership had a duty of care that extended that far. Incidentally, Eurotunnel insist they are there and on our one trip, supplied the label with the boarding documents and insisted it was put in place.Have a look at Hymer, Burstner, Dethleffs and I think Knaus catalogues. I believe all these, in effect, claim EN 1646 compliance, since they all refer to the standard in setting out the MIRO (not in fact 1646, but empodied in it) and payload calculations. However, as I was trying to show with my payload post, although much better than nothing, complying with the (minimum) standard can't guarantee satisfaction. One still has to be very choosy what one buys. Link to comment Share on other sites More sharing options...
Administrator Posted January 16, 2007 Share Posted January 16, 2007 Moved. Link to comment Share on other sites More sharing options...
Mel E Posted January 16, 2007 Share Posted January 16, 2007 Flicka, I think there are three points in answer to your query: 1. As Brian says, many of the BS/EN standards are voluntary: if you say you comply, then you must do so properly, but there is no compulsion to comply. 2. Although most motorhomes build by the larger series manufacturers in Europe have ECWVTA (EC Whole Vehicle Type Approval), there is, as yet, no compulsion for them to do so. Smaller manufacturers tend not to go through the process. 3. Motohomes are also exempt (along with ambulances) from the SVA (Single Vehicle Approval) test, though they may be voluntarily submitted. This is one of the reasons why it is so easy to import motorhomes from the USA. Mel E ==== Link to comment Share on other sites More sharing options...
Derek Uzzell Posted January 17, 2007 Share Posted January 17, 2007 Flicka: Gas-locker labels. At the close of our off-forum discussion about gas-locker 'diamond' labels you were, apparently, happy to accept that there was no legislation that compelled new motorhomes being sold in the UK to carry such labels. Being an inquisitive soul, I still wondered why many leisure vehicle manufacturers (and some importers) were labelling their products when there was no obligation to do so. I said I would try to find out and let you know the answer. Having previously suggested to you that the Caravan Club should know, I decided to ask the CC the following question: "I wonder if you can tell me, please, why some new UK-marketed motor caravans carry a Hazardous Substances diamond-shaped warning label on (or near) their gas-bottle storage lockers, while others don't? The rule of thumb seems to be that virtually all new UK-built motorhomes carry the diamond-shaped label, whereas most (but not all) new 'foreign-built' motorhomes sold in the UK are unlabelled. This practice appears to be confined to this country, but (as far as motorhomes are concerned) my research shows there is no legal requirement for it." The CC's reply was as follows: "It is not a legal requirement to display the hazardous warning symbol on caravans/motorhomes. It is the manufacturers' discretion if these symbols are displayed or not." (I also e-mailed the National Caravan Council (NCC) to check if they recommend gas-locker labelling to UK manufacturers/vendors, but I've so far had no reply.) Based on (rather tenuous) magazine test-report evidence some UK motorhome converters began to label lockers in the early 1990s. Historically, this may have been when adhesive 'diamonds' became easily and cheaply available. Alternatively, as I suggested to you earlier, one UK manufacturer (Auto-Sleepers looks like a good candidate) may have chosen to do it (safety consciousness, inexpensive selling-point, their interpretation of Health & Safety regulations - who knows the reason?) and the others gradually followed suit. Over 10 years having passed, managing to contact someone who actually KNOWS may now be impossible. Motorhome 'conformity' 1. CE Marking: this system does not apply to complete motor vehicles. 2. Crash testing: the testing required for Type Approval will have been carried out on the commercial base-vehicle 'chassis' and motorhome designs based on those chassis will piggy-back on that approval. It's no more logical to suggest (say) a Transit-based coachbuilt motorhome should experience its own crash-testing regimen than it would be to suggest an ordinary commercial Transit-based delivery- or removals-van with a box-body should do the same. 3. EN 1646 compliance: For conclusions to be valid, they need to be based on careful research and reliable information not on guesswork. When a motorhome manufacturer introduces a new model, they may choose to submit a sample vehicle for scrutiny by NCC Certification Engineers. If that vehicle meets EN 1646 standards the manufacturer is then allowed to affix an 'EN 1646 compliancy badge' on all identical models. MMM reports usually state in the technical data section whether or not the motorhome under test is "Badged as NCC EN 1646 compliant" and it takes no great statistical expertise to spot the pattern. Excepting prototypes and exhibition models, all motorhomes from the UK Big Guns (The "Autos", Explorer Group, Swift Group, Lunar(UK)) will be 'badged'. If you had examined a selection of new motorhomes (coachbuilt or otherwise) on the forecourts of dealerships selling UK Big Gun marques, you should have found a NCC EN 1646 compliancy badge (fairly) prominently displayed on them all. Conversely, smaller UK panel-van converters, not being in the mass production game (and because NCC Certification isn't free), will generally opt not to go down this route and, consequently, when MMM tests their products, these are normally reported as unbadged. There is no equivalent badging system abroad and 'foreign' motorhome builders targeting Continental markets will have little incentive to involve themselves with the UK's National Caravan Council. So you wouldn't reasonably expect imported motorhomes to be badged and, sure enough, they aren't. What I'm leading to is that, if you don't appreciate the background to this badging thing, any conclusions you draw based on the presence, or not, of a EN 1646 compliancy badge can easily be skewed by the mix of vehicles you've studied. Examine 5 Auto-Sleepers, 5 Swifts, 5 Hymers and 5 Rapidos (all new coachbuilts): the first 10 should have NCC badges and the last 10 definitely won't. You could conclude, just on the badging, that the UK-built models (certified as meeting EN 1646 standards) are superior to the Continental products, or even that the latter are in some way unsafe. Although it's rational to assume that the badged vehicles are indeed EN 1646 compliant, it's poor science to assume the foreign-built vehicles aren't just because they are unbadged. Similarly, it would be unsound to assume Devon or Timberland (etc.) are constructing non-compliant panel-van conversions merely because they carry no badges. As far as advertising brochures not mentioning EN 1646 compliance is concerned - well that don't surprise me much. Even if a motorcaravanner has heard of EN 1646, it's most unlikely he/she will be familiar with the standards' scope, so mentioning 'standardisation' in a brochure is most unlikely to cause prospective buyers to move a motorhome model up their shopping lists. Tell them it's got a big bed, a garage or an oven - well that's quite another matter... Ratio-wise, you are both right and wrong. If you take the overall EU motorhome market-place, only UK converters compliancy-badge their products so manufacturers not stating EN 1646 compliance are decidedly in the majority. Take the UK market alone and it's vice versa. So what - it's just statistics? ENs are geeky things and geeky things don't sell many motorhomes. I'm sure that the badge on UK-built 'vans is seen as a selling-point, and equally sure it's the magic "NCC" bit that counts not the reference to EN 1646. I'm probably as geeky as anybody and the lack of an EN compliancy badge and no reference to EN compliancy in the manufacturer's brochure had absolutely no bearing on my decision to buy a Hobby. However, what would have made me sit up and take notice is if someone had told me Hobby motorhomes didn't conform to EN 1646 and gave me chapter and verse to justify that statement. I've seen lots of iffy design in new motorhomes, some rough build quality and plenty of evidence of inadequate quality control. But I've seen nothing to make me think a manufacturer is failing to conform to EN 1646. What I was hoping was that you could provide specific examples to support your argument rather than rely only on gut-feeling and supposition. Link to comment Share on other sites More sharing options...
Brian Kirby Posted January 17, 2007 Share Posted January 17, 2007 Just a little addition to that. I have the 2007 Hobby brochure and, although they do not claim EN 1646 compliance, they do claim TUV certification to EN ISO 9001:2000, which is the QA standard established by the International Standards Institution and adopted by the EC, and hence the member states. Still without claiming EN1646 compliance, Hobby then sets out the calculation they use in arriving at the payload, MIRO and MTPLM, exactly as set out for those measures in EN 1646-2. This doesn't prove they do, or don't, comply with 1646, of course; but it does mean that they should be consistent, under ISO 9001 QA procedures, in meeting the weight criteria from EN 1646-2 that they claim they meet.Convoluted, isn't it? Would NCC certification for all vans sold in UK be easier? I think so. Could NCC sell their QA certification across Europe? I'm sure they could, if they so chose, but as they're UK industry backed, why should they? Why doesn't the importer get the imported vans NCC assessed? Maybe he wants to favour British built vans (for which the NCC cert would be provided by the manufacturer), maybe he doesn't want to spend money on NCC certification, maybe NCC won't play, maybe he knows something! Link to comment Share on other sites More sharing options...
flicka Posted January 17, 2007 Author Share Posted January 17, 2007 Hi Derek & Brian I take every thing you say on board & there are some very interesting points raised, but EN1646 covers a lot of areas regarding Motorhomes, including design and payload. How does a potential customer assess the design is built to a recognised standard where none is stated, whilst another product identifies the standard.? ISO 9001:2000 is basically only a method of measuring that a company complies with it's own procedures, not anything regarding product compliancy with Standards specific to a product. It is of course possible that EN1646 is now redundant or needs updating from a Manufactures' point of view, as their "systems" no longer comply due to improvements intechnical advances since it was written, but I suspect not. A further thought, relating to another thread by Vernon - "Do manufacturers listen....." Under ISO9001:2000 there is a requirement for any accredited company to obtain feedback form their Customers, be they Manufacturer or Dealer, so Brian's comment could very well be valid. PS - I did say I had not looked at the Panel van market. So I can not comment regarding Devon or Timberland. Flicka Link to comment Share on other sites More sharing options...
Derek Uzzell Posted January 18, 2007 Share Posted January 18, 2007 Flicka: These are some motorhome-applicable ENs (there could well be more). EN 13878 - defines terms relating to leisure accommodation vehicles used in EN 721, EN 722-1, EN 1645-1, EN 1645-2, EN 1646-1, EN 1646-2, EN 1647, EN 1648-1 and EN 1648-2. NOTE Leisure accommodation vehicles are caravans, caravan holiday homes and motor caravans. EN 27418 - Leisure accomodation vehicles. Vocabulary EN 721 - specifies the minimum safety ventilation requirements for leisure accommodation vehicles. It provides alternative methods of calculation or testing of safety ventilation. EN 1646-1 - specifies requirements intended to ensure the safety and health of persons when they use motor caravans for temporary or seasonal habitation. It also specifies the corresponding test methods. However, certain requirements of this standard do not apply to motor caravans where the overall length multiplied by the overall width does not exceed 12 m2 plan area. EN 1646-2 gives requirements relating to user payloads for motor caravans. Requirements applicable to road safety are not included in the scope of this document. This document is applicable exclusively to motor caravans as defined in EN 13878. EN 1646-2 - specifies the method of calculation of minimum user payloads to be allowed for when designing motor caravans. It also sets out the information relating to user payload to be included in the user´s handbook. It applies to motor caravans as defined in EN 27418. EN 1648-2 - specifies safety, health and functional requirements for 12 V direct current (DC) extra low voltage (ELV) electrical installations for habitation aspects of motor caravans. It applies only to installations which are electrically connected with the electrical installation of the base vehicle or which can be electrically connected with it by means of change-over devices. This document also specifies the ELV output requirements of low voltage (LV) equipment that may be used to provide an ELV supply but it does not specify safety, technical and functional requirements for LV appliances and installations. Requirements for LV installations are specified in HD 384-7-708 S1. EN 1949 & 1949/A1 - specification for the installation of LPG systems for habitation purposes in leisure accommodation vehicles and in other road vehicles. It's pretty clear that you quoted EN 1646 in your original posting because you had a passing acquaintance with it and it's the one that's mentioned on the NCC badge. However, I believe it could easily be argued that conforming to EN 721 or EN 1949 is at least as important as conforming to EN 1646. In any case, as long as conformance to a standard remains voluntary, it's surely perverse to complain that motorhome manufacturers aren't stating whether or not they choose to conform. Why should they? Your criticism smacks of "When did you stop beating your wife?" somehow! You won't find long lists of regulations or standards being quoted in car advertising brochures and this omission doesn't seem to prevent people from being able to decide which cars to purchase. Why should motorhome brochures be different? How much intimate technical detail does a potential buyer need at the brochure-browsing stage? At the beginning you said "Looking at various threads here and on other forum, I have come to the conclusion that very few M/H manufacturers are actually producing their product to this Specification". You've still not provided any evidence to support that view. Link to comment Share on other sites More sharing options...
Brian Kirby Posted January 18, 2007 Share Posted January 18, 2007 flicka - 2007-01-17 10:58 PM Hi Derek & Brian ..........ISO 9001:2000 is basically only a method of measuring that a company complies with it's own procedures, not anything regarding product compliancy with Standards specific to a product. ........... Flicka Just on that point, because, if they claim to met certain criteria for measuring payloads, even without reference to 1646, even if the criteria are their own, they would be obliged, under 9001, to adhere to those stated criteria. The penalty, if they were found failing to do so, would be loss of their ISO 9001 certification. Wouldn't help the buyer much in practical terms, but his/her only recourse in any case, is under Sale/Supply of Goods legislation for a contractual breach by the seller, and not the manufacturer. That would apply equally whether or not the vehicle had NCC approval. Link to comment Share on other sites More sharing options...
flicka Posted January 18, 2007 Author Share Posted January 18, 2007 Mi Lud's and Learned Gentlemen. On the basis of the evidence presented I retract my conclusion, which had been based on personal experience. However I still maintain that in many cases more information could be made available to buyers. Regards Flicka Link to comment Share on other sites More sharing options...
Brian Kirby Posted January 18, 2007 Share Posted January 18, 2007 I still think we consumers are at least a part of the problem. We do rather want it all, toilets, showers (sepatate of course), cookers with ovens and grills, big fridges, running hot water, central heating, reading lights, lots of lounge, comfortable beds, plenty of dining space, loads of cupboards, the aspirational list is almost endless.Manufacturers, on the whole, do hear what we say. That is why, compared to European 'vans, ours give the full cooker precedence over more kitchen storage space, the convertable lounge over the fixed bed, the separate shower over using site facilities, etc. They are listening, and what they supply reflects, broadly, what we indicate we want - by buying it.The problem is that all this desirable kit increases the size, and the weight, of the van that can accommodate it. However, our driving lisences, in many cases, forbid us from driving 'vans heavier than 3,500Kg. The manufacturer is left with a bit of a hard choice. If his competitor makes a highly desirable van, on a 3,500Kg chassis, but the payload is a bit skimped, and it sells, what is he to do? Make a van on a heavier chassis that excludes a growing proportion of his market, exclude the desirable features to keep the weight down, or jump on the bandwagon. Survival, in the end, dictates his course for him. Thus we end up with bloated vans and inadequate payloads. Oh, and it's caravans as well. They have gone the same way, to the extent that more and more require SUVs/4x4s to tow them.One response might be a bit more attention to the weight of all that kit. I'm sure Dometic could lighten their fridges if they tried. Ditto the cookers, if there was market demand. Intelligently designed washrooms could incorporate a shower without imposing too much weight and bulk. The structural framing and cladding could surely be made lighter, and I'm sure some of the furniture could be lightened as well.However, all those changes would, it seems to me, require much greater use of aluminium, perhaps even titanium, and carbon fibres. That, of course, would have its impact on prices, which we shouldn't like either.The answer has, in the end, to come from us. We have to prioritise a bit better, and communicate with the manufacturers about our priorities. We have really got ourselves into a "quart into a pint pot" situation, and only we can get ourselves out. I think we need to do this in any case, because I'm fairly sure we shall have to accept economies in the near future. Economies that will be imposed on us, by the need to reduce our hydrocarbons consumption. If green taxes really catch on, and I reckon they will, they will increasingly penalise high fuel consumption leisure vehicles, LPG, and coal/oil generated mains electricity. That will force us to accept smaller, lighter, more fuel efficient vehicles with much greater use of renewable energy built in.Whatever the outcome of that may be, I don't think any set of regulations, EC or NCC, will ever be able to achieve anything more than establish a minimum level of provision. What I think consumers really need is more, and more accurate, pre-purchase guidance, not greater regulation, and that, I guess, just has to come from the magazines. These vehicles are far more difficult to understand, than most of us realised when we first decided to get one! In that respect, although it ain't quite perfect yet, our very own MMM stands us in very good stead. Link to comment Share on other sites More sharing options...
fred grant Posted January 18, 2007 Share Posted January 18, 2007 when all said and done, i makes sure me car complies with the mot standards every year - but it always seems to fail the test. I wanders why? Fred and alice Link to comment Share on other sites More sharing options...
flicka Posted January 18, 2007 Author Share Posted January 18, 2007 Hi everyone Reading through my last post on this thread, I think I it appears a bit too condiscending and flippant. It was not my intention, I was attempting to lighten the subject, but if I caused any offence I apologise. I do appreciate all the comments/information, the time taken to research and compile them, let alone typing them all up. Especially Derek & Brian, thank you for your efforts. The coontain a wealth of information which I am sure will be useful to other New M/H'ers, besides myself. If they were compiled from existing knowledge, I applaud you. Flicka Link to comment Share on other sites More sharing options...
Brian Kirby Posted January 19, 2007 Share Posted January 19, 2007 flicka - 2007-01-18 10:32 PM Hi everyone Reading through my last post on this thread, I think I it appears a bit too condiscending and flippant. It was not my intention, I was attempting to lighten the subject, but if I caused any offence I apologise. I do appreciate all the comments/information, the time taken to research and compile them, let alone typing them all up. Especially Derek & Brian, thank you for your efforts. The coontain a wealth of information which I am sure will be useful to other New M/H'ers, besides myself. If they were compiled from existing knowledge, I applaud you. Flicka Didn't bug me, John. About right, I thought :-) Link to comment Share on other sites More sharing options...
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