Engineering Perspective on Responsibilities in Road Trailer Manufacturing.

CSA Engineering Gold Coast update on Road Trailer Manufacturing responsibilities.

Designing and manufacturing a trailer is one thing, while ensuring the safety is another.

When it comes to safety, it is the responsibility of the manufacturer or importer. To design a trailer that must be safe, when on the road. As well as meet the requirements according to Vehicle Standards Bulletin 1 Version 6(VSB1). Which follows Australian Design Rules, (ADR’s).

New Trailer Manufacturers Responsibilities

As of the 1st of July 2022, any trailer that is sold to a customer is considered to be 100% safe by the company selling it. This is irrespective of the trailer or parts being imported by others, other countries or states. This put’s the trailer companies liable for any casualty that happens. Companies must assess and ensure their trailers are safe by carrying tests. This includes consulting with a certified engineer and getting a report for each trailer they are selling. This includes meeting the initial requirements of the Roads Vehicle Safety Act 2018, and the Trade practices Act 1984.

Whilst trailer manufacturers and importers are exempt from submitting detailed evidence at the time of application based on the ADRs to the Australian Government. The manufacturers and Importers still must declare that all due diligence has been done to ensure 100% safety for road usage of the trailers.

Road Trailer Manufacturer Retaining Records.

In addition to this the Road Trailer Manufacturer must retain records relating to the manufacture, testing or inspection of road trailers. This is for the life of the model and for a period of 10 years after the last road trailer is supplied to the market. These records must contain sufficient information to establish compliance. Including the Vehicle Standards Bulletin (e.g., written confirmation from the State or Territory that the LPG installation meets the requirements for road registration). In addition, to this the Road Trailer Manufacturer must also identify any components that may have been fitted to a particular road trailer. This is for the purposes of tracing components in the event of a safety related defect recall notice.

Trailer Road Tests.

The Road tests for trailers must be conducted in such a way that the trailer is used as would the customers who purchase one. The certification of the strength of the drawbar and safety chain must also be tested. By testing them at the end, the ‘Drawbar’ and safety chain attachments shall withstand forces applied at the centreline of the intended ‘Coupling’. Without incurring loss of attachment or any distortion or failure which will affect the safe drawing of the towed trailer.

It’s the responsibility of the manufacturer or importer to conduct a safety investigation for a non-compliance trailer. As well as stop the supply and notify the trailer owners that the vehicle does not comply. This investigation shall report on the cause of the non-compliance, the number of road vehicles affected and any other relevant facts or circumstances. This report should then be forwarded to the Administrator of Vehicle Standards within 14 days.

The trailer manufacturer must assess if the noncompliance is connected to safety, in which case a voluntary or obligatory recall is required. This is in line with the ‘Procedures for the Rectification of Safety Related Defects in Vehicles and Related Products’ (the Recall Code). In cases when the noncompliance is found to be unrelated to safety, a field service campaign by the manufacturer or importer may be used to rectify the noncompliance.

Importing a trailer might seem easy option. But this isn’t the case as import approval is required for it to be delivered in Australia. If the import application is not approved, you will have to either export the vehicle. Or have it destroyed at your own expense. While the destruction of the trailer will need to take place under Customs supervision.

The Range of ADRs apply to road trailers.

Depending on the type of trailer, these ADRs can include:
ADR 1,6,13,23,38,42,43,44,45,47,48,49,51,61,62,63 and 74.
Topics include mechanical connections, lamps, reflex reflectors, tyres, brakes, trailer dimensions and trailer markings.

Safety of the entire trailer needs to be assured by the importer or manufacturer, and just because an ADR does not cover a certain area does not mean that due diligence in not required for that item.

At CSA Engineering Gold Coast we have been designing and certifying Road trailers for over 4 years. CSA Engineering provide the right kind of quality service that is required by customers who are ready to embrace the new system.

Under RVSA new guidelines importers and manufacturers don’t operate in the same way as they have been for years. They will be fully liable for everything under their required quality management system.

CSA Engineering your South East Queensland Structural Engineers
Noel Singh – Engineering Fellow with Engineers Australia, RPEQ
Phone : 0452 292 355

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