Second stage compliance

By Malcolm Street

It’s a phrase that is increasingly being used around the motorhome sector these days, but MHG hopes to clarify some of the confusion that currently exists over the issue of second stage manufacture compliance for motorhome and campervan builders.

From the outset MHG would like to point out that since both Federal and State government departments are involved, not everything is as straightforward as it could be.

In a nutshell, Second Stage of Manufacture (SSM) approval for Australian-built motorhomes is achieved by proving to the Vehicle Safety Standards (VSS) branch of the Federal Department of Transport and Regional Services (DOTARS) that a particular motorhome complies with all the relevant Australian Design Rules (ADRs) and, as you’ll understand, there are quite a few of those.

All vehicles should therefore have an ADR compliance plate fitted to show the relevant compliance. So when an ADR-compliant vehicle, say, a Mercedes-Benz Sprinter cab chassis, is substantially modified by having a motorhome body built on the back, then the original ADR plate is no longer going to comply. 

It gets even more complicated when something like the front-wheel-drive Fiat Ducato is imported as a cab (sans chassis) only.

All kinds of items are added or changed in a motorhome build – passenger seats and seatbelts, external lights, external mirrors, vehicle weights, windows – the list is quite extensive, hence the need for the “Certification of Vehicles which have undergone a Second Stage of Manufacture” procedure.

If you are interested in reading some of the relevant certification procedures, as opposed to the veritable mountain of ADRs, then DOTARS puts out helpful “circulars”.

The two most relevant to the motorhome world are 0-4-12 (Certification of Campervans and Motorhomes), which is currently being amended, and 0-4-6 (Certification of Vehicles which have undergone a Second Stage of Manufacture).

These circulars are available from the DOTARS website. For 0-4-12 visit: http://rvcs-prodweb.dot.gov.au/circulars/0-4-12.htm

For 0-4-6 visit: http://rvcs-prodweb.dot.gov.au/circulars/0-4-6%20Issue%203%20.html

What’s in a name?

Some interesting things can be learned from these circulars. For instance, from 0-4-12, item 3.1 states “A motorhome is a road vehicle designed and constructed to provide sleeping accommodation for the number of occupants that the vehicle is designed to carry” and item 4.1 states, “A motorhome is considered to be a goods vehicle and its Gross Vehicle Mass (GVM) determines its vehicle category: either NA (truck up to 3.5 tonnes GVM); NB1 (truck greater than 3.5 tonnes but less than 4.5 tonnes); NB2 (truck greater than 4.5 tonnes but less than 12 tonnes) or NC (12 tonnes or greater)”.

From these two items you might ponder why it’s the sleeping accommodation that determines the seating and not the other way around, and why it is that motorhomes are categorised as trucks – with the relevant problems this brings – and not in their own right.

In addition to the above, Circular 0-4-12 specifies a number of details with headings such as Vehicle Mass, Sleeping Accommodation, Seats, Seat Belts, Seat Belt Anchorages, Child Restraint Anchorages, Glass and LP Gas and Mains Wiring – it’s quite a comprehensive list. Circular 0-4-6 details all the necessary requirements for SSM approval to be given.

You can apply for SSM approval for Australian-built campervans and motorhomes using two slightly different methods – based on whether the motorhome model (and it is a particular model) is classed as a ‘low volume’ or ‘high volume’ product.

SSM approval is a requirement only for new vehicles that have been modified, not used vehicles, and there are slightly different requirements (which mostly mean less testing) for low volume manufacturers/importers, that is, a company that manufactures/imports fewer than 100 vehicles per year; application has to be made to the VSS branch of DOTARS for its approval.

Applying for SSM high volume approval is not something that can be done overnight. There is a certain amount of testing involved, particularly in areas like seat fittings and seatbelts and there is also a comprehensive inspection process.

The difference between low and high volume approval is that while all vehicles must have full ADR compliance, a lesser standard of evidence of proof is required for low volume SSM. While this may be easier to obtain, it restricts manufacture to 25 models of a particular motorhome per year. There are no manufacturing limits on high volume approval.

Which vehicles comply?

It is relatively easy to check which vehicles have second stage compliance. The Road Vehicle Certification System (RVCS) website is http://rvcs-prodweb.dot.gov.au.The simple Vehicle/RVD search is best done by manufacturer and vehicle size, if you don’t know anything else. To use it, the category of vehicle must be known. For motorhomes it is either NA, NB1 or NB2.

I did a test run on this and looked up a couple of manufacturers (not many are listed). By typing in the make of a motorhome, for example “Winnebago”, and the marketing model as “Free Spirit”, I learned that the Winnebago Free Spirit motorhome SSM was issued on May 19, 2004, and is for a Fiat Ducato cab with an Al-Ko chassis, Certification Unit ID no. 32518.

Note the SSM approval is quite specific: in this case it is for an Al-Ko chassis only. Any changes to the vehicle from its original design or changes to ADRs means the SSM process has to start again!

Further, in the case of an Iveco cab chassis, for example, if an Iveco 50C15 unit was used for the SSM approval, then even if the same motorhome body was used on an Iveco 65C15 a different SSM approval would be required.

Some useful information for intending purchasers, which cannot be easily obtained, is what second stage compliance approvals have been applied for.

Several manufacturers that MHG spoke to indicated that they have applied for SSM approval, but the necessary paperwork was ongoing as we went to press.

What does it all mean?

A question that no doubt comes to mind is: what are the implications of SSM approval, or lack thereof, for a new motorhome?

At present, from a registration and insurance point of view, there doesn’t appear to be a problem if there is no current SSM certificate.

However, our conversations with various industry and government persons suggest that things are changing and in the future both registration and insurance cover may well be refused for any new motorhome without the necessary SSM approval plate.

Although this particular problem will lie mainly with manufacturers and dealers, MHG heard of a very recent case where a motorhome owner moved interstate and was not able to get his relatively new motorhome registered because of a problem with the exhaust pipe location!

The SSM approval process

In the first instance, all motorhome manufacturers seeking any SSM approval must be registered with VSS/DOTARS.

This is required so that VSS/DOTARS can effectively check the manufacturer is a legal company. Once given the all-clear, the manufacturer can then apply for SSM compliance approval.

To do this, evidence of compliance with the relevant ADRs must be supplied and that includes full test reports, which have to be supplied by an authorised test laboratory.

This may incorporate items in the original ADR compliance for the base vehicle, for instance, if a motorhome body increases the GVM of the vehicle from that originally specified by the vehicle manufacturer, then items like the brakes must be shown to be able to cope with the extra weight.

VSS/DOTARS inspect both the documents and the prototype vehicle to ensure that all is correct and once that is done a legal document is issued to allow the manufacture to build and supply that particular vehicle to the Australian market. In the case of fully imported motorhomes, a similar ADR compliance process applies.

When an SSM-approved vehicle is built and registered for the first time, the State motor vehicle registry should validate all vehicle details with VSS/DOTARS approval details.

It has been suggested to us that some State registry authorities may not be up to speed with SSM approvals and when we checked with the East Coast states, we received the following replies.

From a NSW Roads and Traffic Authority (RTA) spokesperson:

“In NSW motorhomes or campervans can be accepted for registration in a number of ways. If an individual modifies a previously registered vehicle as a motorhome or campervan, then the owner only needs to supply an engineering certificate to register it with the Roads and Traffic Authority. If a company, such as Winnebago, is manufacturing or modifying new vehicles as motorhomes or campervans, then they must have a first or second compliance plate for the conversion before it can be registered with the RTA. Any motorhome that is built from a base vehicle not previously supplied to the market in Australia, which is already fitted with a first stage compliance plate, would not be registered in NSW unless it had a second stage compliance plate fitted.”

A Queensland Department of Main Roads spokesperson had this to say:

“Certification of motorhomes has always been a Federal government issue. The State complies with circulars issued by the Federal government. These determine the guidelines for motorhome registration. Under the current circular, second stage compliance plates are required on Australian-made vehicles.”

Now, we are not sure whether the Vic Roads spokesperson understood the question but this reply was offered:

“At present Vic Roads does not require a second stage of manufacture compliance plate for new vehicle registration; instead the Vehicle Assessment Signatory Scheme (VASS) is used whereby modified, imported and individually constructed vehicles are certified by a VASS signatory – someone who is authorised by Vic Roads to certify a particular class of modification or vehicle.”

This is not quite what VSS/DOTARS assured us, but we suspect that will change soon.

The process is quite lengthy, and in some cases expensive. It’s now MHG’s understanding that all motorhomes built on unregistered new vehicles should have, or be in the process of getting, SSM approval, prior to initial registration.