Second stage compliance: Part I

By Malcolm Street

It’s a phrase that is increasingly being used around the motorhome sector these days, but CW 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 we would like to point out that since both Federal and State government departments are involved, not everything is as straightforward as it could be.

Starting at the beginning all motor vehicles, when first supplied to the market in Australia, are required to comply with applicable Australian Design Rules (ADRs) and, as you’ll understand, there are quite a few of those.

The Federal Department of Transport and Regional Services (DOTARS) through its Vehicle Safety Standards branch (VSS) administers these ADRs. All vehicles should therefore have an ADR compliance plate fitted to show the relevant compliance.

However, 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 (or SSM)” 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) and 0-4-6 (Certification of Vehicles which have undergone a Second-Stage-of-Manufacture).

Both these circulars are available from the DOTARS website. For 0-4-6 visit: http://rvcs-prodweb.dot.gov.au/circulars/0-4-6%20Issue%203%20.html
For 0-4-12 visit: http://rvcs-prodweb.dot.gov.au/circulars/0-4-12.htm

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, NB1, NB2 or NC)”.

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. However, 0-4-12 is being amended as this article goes to press, so we’ll watch with interest.

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.

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 what is termed “low volume” manufacturers/importers, that is, a company that manufactures/imports fewer than 100 vehicles per year.

Applying for SSM full 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 quite comprehensive inspection process involved as well.

Which vehicles comply?
It is relatively easy to check which vehicles have second stage compliance. The Road Vehicle Certification System (RVCS) website address 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 (truck up to 3.5 tonnes GVM), NB1 (truck greater than 3.5 tonnes but less than 4.5 tonnes) and NB2 (truck greater than 4.5 tonnes but less than 12 tonnes).

I looked up a couple of manufacturers as a test. By typing in the make of motorhome, ‘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. If a different chassis were used the SSM process would have to be started again.

Also, in the case of an Iveco cab chassis, for example, if an Iveco 50C15 unit was used for the SSM approval, 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, that cannot be easily obtained, is what second stage compliance approvals have been applied for. Several manufacturers that CW 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 does not appear to be a problem if there is no current SSM certificate.

However, my 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 not having the necessary SSM approval plate.

Although this particular problem will lie mainly with manufacturers and dealers, CW 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.

CW has approached a couple of relevant government departments for clarification on several matters, but at the time of going to press, we had not received a return comment, so we will have some more answers for you in the next issue.