There is a problem with the regulation of bodies that equip trucks and trailers.
They can fall through a large regulation hole.
The national standards for road safety aspects of new vehicles are the Australian Design Rules (ADR).
ADRs do not specify design or performance standards for bodies that can be mounted on heavy trailers.
So which technical standards apply to truck and trailer bodies? Well, mostly none.
The problem is this: ADRs focus on minimizing the risk of road trauma and environmental degradation.
Truck bodies are factory equipment. Plant equipment is regulated by various state and federal workplace safety regulations.
None of the factory regulations relate specifically to bodies that go on trucks and trailers.
In other words, there is a fundamental disconnect between road safety regulators and occupational health and safety regulators.
They have no serious dialogue and have not figured out how to regulate finished trucks and trailers.
I recently investigated the failure of a tipping trailer. The body fell as the operator unloaded a heavy load of spoil.
This incident happened on a construction site and the national occupational health and safety regulator was notified and assisted.
He put a notice to the owner of the trailer, who also owned other dump trailers of the same type from the same manufacturer. The cause of the failure immediately became apparent to all investigators. The pivot design was totally inadequate.
This can be seen in picture 1.
Photo 1 shows one of the pivot pins at the front of the dump body.
The body disappeared as it was lying on the ground. Note that the shaft pivot is welded on 6mm mild steel and there is no bracing.
The design is not strong enough for the loads it could sustain.
Photo 2 shows the sister trailer during the modification.
Two additional pivots were added, reinforcements were installed in each welded corner of the back plate, and a cross member was installed between the added pivot side plates.
This tipper has a compliance plate that certifies compliance with ADR. These rules do not impose any requirements on the strength of the tipping trailer.
The trailer manufacturer could obtain approval to register their trailers without formal review of the design by anyone. ADRs only require the body to have acceptable dimensions and lighting.
Simply put, the design is unsafe and the lack of regulation allows it. What happened next surprised me.
Based on the VIN number sequence, there are several dozen models of trailers in question on Australian roads. However, the manufacturer is no longer in business.
A representative from the occupational health and safety regulator told me that he was powerless to fix the safety issue because he had no relationship and power over other trailer owners .
I then contacted the federal ADR regulator. After investigation, the regulator told me that since the trailer manufacturer was no longer in business, there was nothing they could do about it.
No safety recall could be mandated because there was no manufacturer to conduct it. But what about public safety?
The bodies that equip trucks and trailers carry loads or perform useful work, such as lifting, spreading or watering across the country.
Organizations are governed by occupational health and safety regulations. These require the designer and manufacturer of plant equipment to carry out a hazard and risk assessment.
The dangers must be identified, the risks must be quantified and then controlled. Only low or very low risks are acceptable. Once the assessments are completed, four questions must be answered and ranked:
1. What could go wrong? 2. How serious is the hazard? 3. Is the exposure to the hazard continuous, intermittent or occasional? 4. What prevents the danger from occurring and what level of safety exists with the guards?
A proper hazard and risk assessment is documented in the technical file and should be reviewed by an independent engineer. In the case of the tipper design described in this article, the questions answered are:
1. The body can fall. 2. The consequences could be fatal. 3. Exposure is continuous. 4. The countermeasure is the strength of the pivot design, which is inadequate. The level of risk of separation from the bodies is “high” or even “extreme”.
This trailer must not be used. Despite the rating, this tipping trailer model is widely used today in Australia.
The solution to the regulatory problem is to require manufacturers to file a written hazard and risk assessment with the federal regulator when filing for vehicle certification.
Then someone in authority should evaluate it. This then raises the issue that the federal regulator is not responsible for the safety of plant equipment.
Hence the gaping hole in the regulatory structure.
If the body had been installed in the aftermarket, the NHVR would require an accredited engineer, called a Certified Vehicle Examiner, to approve the installation of the body.
The evaluation involves meeting the requirements set forth in the national HV modification code called Vehicle Standards Bulletin No. 6 (VSB 6). Although VSB 6 does not specify minimum safety factors for designs, it does provide the basis for assessment by an independent engineer.
This is not required of manufacturers of new trucks and trailers when installing bodies under the guise of Federal Vehicle Approval. Some body types are regulated equipment.
In other words, approval is required from an occupational health and safety regulatory body. Tank trucks are regulated equipment.
Mobile cranes that lift more than 10 mt are regulated equipment.
I recently learned that a vehicle loading crane capable of lifting more than 10 mt is also prescribed equipment.
It must conform to the AS 1418 series of standards despite no modifiers I know of that have ever gained approval.
There are also no national regulations for tow trucks, despite the existence of AS 5400:2015. I regularly inspect tow trucks with broken frames.
Indeed, the safety factors specified in AS 5400 are often not respected. I advocate that Australia adopt an AE mark.
This would work similarly to the CE marking of the European Union. The CE process has a well-developed regulatory structure based on the “European Machinery Directive”. Machine suppliers in the European Union must make a declaration of conformity with the CE process.
Technical standards for CE marking could be adopted, with modification in Australia. If an AE mark were required for all factory fitted equipment supplied in Australia, there would be a path to better fitting standards on new vehicles. I live in hope!
Dr. Peter Hart, ARTSA-i