A Frame info

Discussion in 'Tech/Mech General' started by sallylillian, Nov 11, 2014.

  1. sallylillian

    sallylillian Funster Life Member

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    After some useful debates, sometimes with some difficult A Frame company executives with severely biased opinion I started a debate with VOSA technical and I thought I would share the final email from them as it sums up neatly the somewhat tenuous position. And this is not about where you can but if you are in the UK.
    Responding to your follow-up mail on the above subject to DVSA.
    I am providing to you the Department for Transport official line, to give you the official documents and to avoid giving any definite statements that something is or isn't legal. This is because in the end the only legally binding ruling is that of a court of law, rather than that of a government official. However I will try to be some more help, albeit with the same caveat.
    The distinction DfT are drawing about type approval is that this only applies to new unregistered motor vehicle and trailers. Towing frame brackets are invariably installed following car type approval and registration. The towing frame itself can't be type approved in isolation. When type approved the towed car isn't capable of being a trailer. At the point when the brackets and frames are installed "in service" legislation is applied instead. The towed car then becomes a trailer when towed, and the Construction and Use requirements for a trailer apply then instead of the type-approval legislation.
    The Construction and Use Regulations reg 18 (1) requires "each and every part of every braking system and the means of operation thereof fitted to a vehicle shall be maintained in good and efficient working order and be properly adjusted." An interpretation of this raised in the DfT fact sheet is that if the towed vehicle has servo brakes then that servo might need to be operational for the trailer (towed vehicle) brakes to be sufficiently effective to be in "efficient" order. However it is also possible for the overrun brake with shortening cable from the tow coupling to provide too much brake control force input unless the servo is depleted. Some cheaper systems do not provide a vacuum source to reinstate the servo vacuum so have to be designed like this to get any appreciable brake effort from second and subsequent brake applications. Without depleting the servo the trailer brakes then lock up horribly on first application. This then begs the philosophical question about whether a vacuum servo with no vacuum source is a means of operation of a braking system in good and efficient order, even though the residual brakes for the trailer do help provide the necessary braking effort for a vehicle combination. (Trailer braking efficiency is not defined separately in Regulation 18.) That has never been ruled on in court, hence my first paragraph. However a school of thought to avoid any possible argument is to get the servo operational. as well as the ABS if that is also fitted to the towed car.

    You are right it would be good if there actually were some rules or law to specifically address this. However in order to do so would require some amendment to the European braking legislation as UK cannot act in isolation to "gold plate" the existing laws or impose extra-judicial rules. There is no great incentive to do this as we are not aware of incidents of danger arising from towing motor vehicles as trailers . The government view is that strong evidence is required before committing to change, because of the cost of change and a resistance to extra regulation particularly where the political climate is to reduce regulation, and which is why we are where we are.

    So I hope this helps those investigating, and thanks to Larry for some useful pointers.

    Michael
     
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  2. Bailey58

    Bailey58 Funster Life Member

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    So that's cleared that up then!
     
  3. BreweryDave

    BreweryDave Funster Life Member

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    In other words - we're not really sure, but until theres a 'problem we won't worry about it.
    (Back to a similar position as the HGV debate on heavy RV's) - until someone gets taken to court and there becomes some case law - its all open to interpretation, and no-one can really be bothered to take anyone to court! (....until there is an accident!)
     
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  4. DuxDeluxe

    DuxDeluxe Funster Life Member

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    The above email is in context of other correspondence which makes it slightly unclear, however BreweryDave's succinct summary above works for me!
     
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  5. Frentchy

    Frentchy

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    I was under the impression (from past A frame posts) that the use of A frames was at the discretion of individual EU member countries with out European intervention; apparently according to the following " European braking legislation as UK cannot act in isolation to "gold plate" the existing laws or impose extra-judicial rules", there is European legislation involved; If so, how can Spain, Germany, and possibly others Ban their use?
    Please don't say "That's the EEC" because I live here and see how its manipulated too suit them selves, and it Pi$$es me off.
     
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  6. DuxDeluxe

    DuxDeluxe Funster Life Member

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    Unfortunately true - gets my goat as well, especially the French ignoring what they want when it suits them concerning protectionism
     
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  7. toyota

    toyota Funster

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    didn' do much protectionism in the two wars without us
     
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  8. DuxDeluxe

    DuxDeluxe Funster Life Member

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    Spot on!
     
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  9. tonyidle

    tonyidle Funster

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    I don't think that was what was meant. The whole area is open to interpretation & hasn't been tested in court - here and presumably also in other European countries. So each member country will attempt to interpret the law as best it can. Ours (by which I mean VOSA) has chosen an exceptionally free interpretation that suits users of A frames; other countries can interpret it as they see fit. Some countries' interpretations may not suit users of A frames. That's life.

    It interests me that VOSA appears not to have considered the reversing requirement. An A framed car cannot be reversed in any true sense of the word: with gentle use of the accelerator and assuming a reasonably smooth & level road limited straight line reversing will be possible. Under any other conditions, which might also include the need to reverse around obstacles, it will not.
     
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