caravan compliance · ‘atm ’, or specifically ... • transport has seen turntables and large...

1 Vehicle Safety and Standards

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Caravan Industry Association WA State Conference 2013

Caravan Compliance


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Introduction

• Vehicle towing capacity • Approved tow couplings

• Non compliant tow couplings • Fifth wheel couplings

• Access doors • Excessive rear overhang


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• Reassessment of a caravan’s Aggregate Trailer Mass (ATM) to meet the towing vehicles tow capacity.

• It is not necessary to downgrade a caravan’s ATM to the tow vehicle’s lower tow capacity.

• Why? • Vehicle Standards Rules and Regulations 2002 (VSR) requirements.

Vehicle Towing Capacity


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• trailer means a vehicle without its own motive power that is built to be towed, or is towed, by a motor vehicle, but does not include a motor vehicle that is being towed;

• loaded mass, of a vehicle, means the total mass of the vehicle and its load.

• The loaded mass of a trailer that is being towed by a motor vehicle must not exceed the lesser of — a) the towing capacity of the towing apparatus (towbar) fitted to the

vehicle, as specified by the manufacturer of the towing apparatus; or b) the maximum loaded mass of a trailer that may be towed by the

vehicle, as specified by the manufacturer of the vehicle. (tow capacity)

• It is the driver/owner’s responsibility to comply with the law.

WA Vehicle Standards Legislation


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Approved Tow Couplings • Couplings will have correct markings in accordance with the AS 4177 or as

per Australian Design Rule 62/02.


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• Each coupling body shall be legibly and permanently marked in a suitable prominent position with the following information in characters in English not less than 5 mm high: a) Factory mark, trade name or manufacturer's name (if appropriate). b) The mark '50 ' to indicate the size of the tow ball for which it is

intended. c) The manufacturer's approved maximum coupling body rating (e .g.

'750 kg' , '2000 kg' or '3500 kg' ), in kilograms. d) A code to indicate the serial number, batch, production date, or

similar. e) The words 'DO NOT WELD' if the coupling is manufactured from

non·weldable materials. f) The words 'WELD ONLY' if coupling body is specifically designed to be

attached by welding only.

AS 4177.3 Markings


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• Both parts of a ‘Coupling’ specifically designed for use between LA, LB,LC,

LD category and sub category LEM towing vehicles and trailers up to 750kg ‘ATM’, or specifically designed for use between towing vehicles and trailers up to 3.5 tonnes ‘ATM’ must be marked with the following information:

• The ‘Coupling’ manufacturer’s name or trademark; and • the maximum allowable trailer ‘ATM’ and its units of measurement, kg for

an ‘ATM’ up to 750 kg and tonnes otherwise), at which the ‘Coupling’ is rated; and

• the words “use with model (identified model)”.

ADR Markings Up to 3.5 tonnes ‘ATM’


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• Both parts of the ‘Coupling’ specially designed for use between towing vehicles and trailers over 3.5 tonnes ‘ATM’ must be marked with the following information:

• The ‘Coupling’ manufacturer’s name or trademark; and • the words “use with model (identified model)”; and • either the rated ‘D-value’, or the rated ‘D-value’ and ‘V-value’ (kN).

• All markings must be stamped, moulded or printed with letters not less

than 2.5mm high and must be visible when the ‘Coupling’ is installed and connected. The markings may be on a metal plate that is permanently affixed to the ‘Coupling’ or to the vehicle adjacent to the ‘Coupling’.

ADR Markings over 3.5T


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• Non compliant couplings are often incorrectly marked with AS 4177.3 or not marked at all.

• Poly block couplings are not covered in the AS 4177.3. • The AS 4177 standard is for ball type couplings only!

Poly block not marked correctly.

Non Compliant Tow Couplings


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Fifth Wheel & Goose Neck Couplings


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• Transport has seen turntables and large ball couplings mounted solely to the tray of vehicles not on the chassis.

• The current policy is: • All fifth wheel coupling installs must comply with a DOT approved

standard. • The requirements for approval are:

Engineer’s signoff that the coupling meets all relevant regulatory and safety requirements, including:

o P-codes in VSB 6; o vehicle structural strength; o strength of mounting; o coupling rating; and o vehicle GVM / GCM



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Certification can also be performed by a light vehicle signatory (for light vehicles only) or a VSB 6 Authorised Modifier with code P1 or Type approval, for a specified make and model of vehicle, is allowed.

• All fifth wheel coupling installs must be inspected by DOT. • A fifth wheel coupling or turntable is considered a modification and

requires the approval by the Director General, either by the issue of a modification permit, or by a modification plate issued by an Authorised Heavy Vehicle modifier and attached to the vehicle.



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• A caravan or trailer equipped with cooking facilities or living or sleeping accommodation must have only outward opening or sliding doors. At least one such door must be located on the left-hand side or at the rear.

• The intent of ADR44/02, clause 44.8.1 is that the door on the left hand side or rear of motor homes and caravans must be able to function as a door, in the normal sense of the word, providing direct entry to and egress from the vehicle. Whilst this clause does not specify dimensions, the intent is clearly to enable an average size person to easily enter and exit the vehicle without additional external fixtures or fittings. This may necessitate the fitment of permanent steps.

• In addition, there must be no impediments (such as fixed objects) which interfere in any way with the easy use of doors for entry and exit.

Access Doors


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Access Doors


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• Excessive rear overhang occurs when the rear overhang either exceeds the front load space forward or is greater than 3.7 metres.

• Some manufacturers will build a caravan to the maximum rear overhang, the addition of accessories can result in the rear overhang being excessive.

ROH=Rear overhang DBL=Drawbar length

Excessive Rear Overhang


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Excessive Rear Overhang


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Department of Transport Vehicle Safety and Standards

21 Murray Road South WELSHPOOL WA 6106

caravan compliance · ‘atm ’, or specifically ... • transport has seen turntables and large...

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