# A Frame Braking UK & Germany!!!!



## guzzijim (May 1, 2005)

Must say the Towing in Germany with an A Frame has livened up the forum, anyway I do not wish to comment on that topic.
I do feel and have posted on the subject before, if towing a car on an A frame that has a servo fitted, then for safety’s sake you should either have an electric vacuum pump fitted or use a Brake Buddy. Not having a Brake Buddy I cannot shed any light on how efficient these are at improving the braking of the towed car.
I can however say, that relying only on the car brakes operating without it’s servo working greatly increases the outfits stopping distance, I would put a figure on it of about 30%.
Having fitted an electric vacuum pump to my Atoz ,I would never tow again without one fitted. On the one occasion the pump failed (faulty fuse holder) I realized how inefficient and dangerous it was to rely on the vacuum-less braking of the car. It maybe that the braking on your towed car needs only be 30% (there about) efficient to conform with the law, but there may come a day when you wish you had invested in your safety.
PS. The only exception I can think of is a Fiat Panda that had no servo fitted as standard and therefore softer brake pads, which kept up the braking efficiency and was my previous towed car for many years.


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## 88724 (May 9, 2005)

Hi Jim

Having read the relevant braking laws for a trailer it apears to say that using anything other than Mechanical means is not acceptable.

_Braked trailers must be fitted with a parking brake that operates on at least two road wheels on the same axle. At all times it must be capable of being maintained in operation by direct mechanical action without the use of hydraulic, electric or pneumatic systems - i.e. Operated by rod or cable action. The efficiency of the handbrake must also comply with EEC Directive 71/320/EEC; i.e. It must be capable of holding a stationary trailer on a gradient of at least 16% (1 in 6.25) _


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## DJP (May 9, 2005)

*Brakes*



> . Not having a Brake Buddy I cannot shed any light on how efficient these are at improving the braking of the towed car.


The Brake Buddy is capable (so I am told by a dealer) of exerting upto 6 tons of pressure on the brake pedal! In the USA they tow far bigger vehicles behind thier RV's than we would ever consider.
So stopping a towed car without the servo operating is not a problem.
Also


> Braked trailers must be fitted with a parking brake that operates on at least two road wheels on the same axle. At all times it must be capable of being maintained in operation


Refers to a PARKING BRAKE only. To the best of my knowledge all trailers (where they are motor vehicles) have a parking brake which is operated by rod or cable or combination of both.

BTW Thanks George, I put the switch in the inverter yesterday, works a treat, as one would have expected! :lol:


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## guzzijim (May 1, 2005)

So George, are you refering to the hand brake only? which remains unchanged or are you refering to the hydraulic footbrake system? The hydraulic footbrake system remains in tact, but the vacuum line/hose has an electic vacuum pump fitted in-line, which if it becomes non operational leaves brakes working in original manor.We all know it is said "the law is an ass", it it not better to forget the law if we are if fact breaking it and looking out for our and others safety ?


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## 88724 (May 9, 2005)

Hi Jim

I am simply quoting trailer law, which is what your car becomes when on an A frame, you may have a system there that is far better than the system specified in the law, but regardless of that it is still ilegal.

The reality is that even by towing a car on an A frame for non recovery purposes is ilegal here and in Europe. so whethor the braking system is better or not is a mute point.

Carrying blanks would make an ilegal firearm safer, but it would not make the firearm legal.


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## 88724 (May 9, 2005)

Hi all

Just had everything I have been saying confirmed by the relevant authourities.

Just had a conversation with Bob Taylor of VOSA technical and Legal Dept and also Lawrence Thatcher of Construction and Use Marsham just phoned back

If a trailer below 750KG has brakes fitted (which the car obviously does) then they must be fully operational, to make it legal you could remove the brake shoes and all associated brake parts.

According to Reg 15 through to 18 of the road vehicle contruction and use regulations (as amended)

For vehicles over 750 they must be fitted with overun braking system that allows reversing automatically, but this must be done mechanically and not electrically

Brake buddies are ilegal (Lawrence Thatcher), they do not conform to uk Law for trailer braking. The brakes on a trailer must be operated mechanically by the driver or on overun principle.

So there you have it towing a vehicle on an A frame (whethor over or under 750KG) for anything other than recovery is ilegal.


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## guzzijim (May 1, 2005)

guzzijim said:


> .We all know it is said "the law is an ass", is it not better to forget the law if we are if fact breaking it and looking out for our and others safety ?


Lets face it George none of us are going to throw away our A frames no matter how many regulations you and other may quote, well not until someone get prosecuted and only then if the case goes against them.
I'm not interested in laws & regs and intend to carrying on A framing as I have done so for the past 14 years, but what *I am trying to convey *is that if we are going to A frame lets have some *efficient brakes*!!!! bugger the regs.


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## 88724 (May 9, 2005)

Hi Jim

At least now you know you are breaking the law.


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## guzzijim (May 1, 2005)

Nothing to add on the subject then George? was expecting something more!


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## 88724 (May 9, 2005)

Hi Jim

What more is there to add? is there something else you would like to know?


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## olley (May 1, 2005)

We will just have to want until someone is prosecuted for driving an RV that's too long, too wide, over 7.5 tons on a car licence while pulling a car on an unbraked "A" frame, they chuck the book at him and resolve all the issues at once. :lol: 

Olley


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## 88724 (May 9, 2005)

Hi Olley

There are no issues regarding the A frame it is clearly against the law, not a grey area.


Too wide as been settled (for now) by Bramhill Versus Edwards(Destination RV)

The driving licence law is also clear, motorhomes are not weight restricted regardless of what the DVLA tell you. But I agree with DVLA that you should get an HGV licence if you want to go over 7.5 Tonnes, I just canny stand the lies they use to justify their opinion.


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## 97022 (Dec 22, 2005)

GeorgeTelford said:


> Hi all
> 
> "Just had a conversation with Bob Taylor of VOSA technical and Legal Dept and also Lawrence Thatcher of Construction and Use Marsham just phoned back"
> 
> ...


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## olley (May 1, 2005)

Hi george not trying to start an argument, but until something has been proved in a court of law to be illegal, surely its just an opinion (however well studied).

It would be nice to have it all in black and white, we would all know exactly where we stood.

olley


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## 88724 (May 9, 2005)

Hi David, Olley

In some cases things can be read (nterpreted) differently, in this case it is all very clearly written.

If a trailer is fitted with brakes they must be operational, even if the trailer is under 750KG. I knew this from years back when I inquired about using mini brake drums (unless all the internals ie shoes and any brake relevant part was removed, the they had to be serviceable and operational) 

If the vehicle is over 750KG then the brakes must be 

a) operated via the driver operated (like air brakes on an Artic) 

or 

b) be over-run brakes mechanically operated not electrically (ie not via brake buddy)

Its all quite clear, A frames are ilegal in UK and also throughout europe. Its clear and in black and white
Brake buddies are ilegal too.

According to the its not been tried in a court of law routine you should be able to smoke in a public space in Scotland on the 27th March then? I think not.


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## guzzijim (May 1, 2005)

We do seem to be going *off subject here!!!!!!!!!!!!! *the thread was about *vacuum pumps/servo's and braking distances,safety*. Must say I'm feed up to the teeth with all this A frame/ regulations quoting, besides it been done a hundred times before. 
If I hear another regulation I will scream!!!!!!!!! I use an A frame *it's illegal*, did you hear* illegal*, come and arrest me please.

Come lets have some views about my thread, we've heard all of yours George, I hope!


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## DJP (May 9, 2005)

*A frames*

guzzijim


> I use an A frame it's illegal,


*I thought illegal was a sick bird (ill eagle)*

THE END


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## 88724 (May 9, 2005)

Hi Jim

Sorry mate, but you mentioned the law in your very first post and the all of your subsequent posts.

Why would anyone want to invest in braking system which is obviously ilegal, what are they going to do with it when it becomes junk?

_is it not better to forget the law if we are if fact breaking it and looking out for our and others safety ?_

No, you are not looking out for others when you are driving round ilegally and uninsured, with an unaproved braking sytem.


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## guzzijim (May 1, 2005)

There's going to be a lot of A frames on Ebay for sale then? do you think I should sell mine now and beat the stampede George?

It's now 14 years this illegal thing been going, why does't somebody have a bloody accident and get it sorted.


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## TonyHunt (Oct 10, 2005)

Hear, Hear guzzi. Dont you just love these argumentative know alls with verbal dirrohea. My heads spinning from reading all the crap tonight on one subject.


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## 88724 (May 9, 2005)

Hi Tony, Jim

No need at all to be rude Tony, would You or Jim like to put yourself forward for a test case? Getting all huffy and sarcastic with me doesnt change the facts.

As it stands you have gotten away with it to date, so far so good and for all I know you may carry on getting away with it, but that is all that is happening, there is no grey area or loophole.

You must be interested or you would not have bothered reading "all that crap" but getting angry at the conclusion doesnt help.


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## DABurleigh (May 9, 2005)

"We will just have to want until someone is prosecuted for driving an RV that's too long, too wide, over 7.5 tons on a car licence while pulling a car on an unbraked "A" frame, they chuck the book at him and resolve all the issues at once.
Olley"

That's the MHF spirit! Aren't volunteers wonderful? Laying themselves down for their fellow man. Shall we shart the whip-round for you now, Olley?

Well done that man!

Dave


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## guzzijim (May 1, 2005)

Quote
You must be interested or you would not have bothered reading "all that crap" but getting angry at the conclusion doesnt help.

Sorry Mr Mathews but each time try to and air my views (Vacuum pump) it seems that you’re sole purpose in life is to be aggressive, I’m sure it cannot be just this website that makes you so, it must be your normal attitude to whoever you see as being wrong.
A little tack and understanding would be appreciated, I am disabled and rely on my car, I do not wish to be confined to a campsite, neither do I wish to wild–camp and spoil others enjoyment. I think we all know by now that it’s an illegal/grey area, have you ever though of putting your energy in trying to get the relevant regulations changed or amended, it would be much appreciated by those of us who are less physically able that you.


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## olley (May 1, 2005)

[quote="DABurleigh Shall we shart the whip-round for you now, Olley?
Well done that man!
Dave[/quote]

Yes please all donations greatfully accepted, to keep the pressure of the postal service I suggest notes only please :lol: :lol:

Olley


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## sallytrafic (Jan 17, 2006)

guzzijim said:


> Quote
> You must be interested or you would not have bothered reading "all that crap" but getting angry at the conclusion doesnt help.
> 
> Sorry Mr Mathews ......


Who's Mr Mathews?


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## guzzijim (May 1, 2005)

sallytrafic said:


> guzzijim said:
> 
> 
> > Quote
> ...


 Hand my mind on other things,was thinking of someone else,sorry.


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## 88724 (May 9, 2005)

Hi Jim

Sorry you see it that way, I have not been aggressive at all, when disagreed with I presented the evidence to back my position, but I didnt run off topic, you mentioned legality from the start. Again you mention grey area, there is nothing grey about it the law is clear only the policing is lax.

And if you think about it what is the point of discussing an ilegal brake augmentation system? other than it costs a lot of money, its not legal and if they police the law it will become a relatively valueless piece of junk.

Please dont try playing the disabled card on me, it changes nothing, all the facts remain the same, I am not going to say ah Bless thats alright then, what exactly did you hope to achieve by telling me you are less abled? I cannot see the relevance at all.


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## guzzijim (May 1, 2005)

George
I don't normally wish my disability on anybody but-----------. but I think your latest remarks prove you are an unsympathetic bastard and sorry moderator I mean it! no regrets.
Why don't you do something useful and as I suggest and put your efforts in trying to make this method of towing legal, instead of relentlessly and boringly quoting chapter and verse, or do you just enjoy be a bore.


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## 88724 (May 9, 2005)

Hi Jim

You wanted the sympathy vote? You have it. Did the law just change? Nope

Is it relevant to the discussion in any way at all, NO

At no point in this discussion have I resorted to rudeness or sarcasm.


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## 88741 (May 9, 2005)

OK Guys that is enough, please try and keep a cool head even though you may feel you have been provoked. I do not want to delete this thread as it has some useful information, but the last few posts are unneccesery and both of you should know better :wink:


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## 88724 (May 9, 2005)

Hi Helen

Please dont imply I have been abusive or provocative, a quick look through, shows that the abuse as been a one way street.

Jim announced his disability and I simply and politely questioned its relevance to the discussion.


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## 92180 (May 1, 2005)

I spoke to the VOSA in Perth before I chose a trailer for my car. They offered the opinion that that an A frame was for recovery only, that the fact that people had them was not a reason to purchase one--so I didn't. 
They said that due to lack of manpower they had not been as active as they should have been on overloading, towing and unsafe loading. They advised me that the A9 one of the busiest tourist routes in Scotland was to be given a higher priority with spot checks being set up in 06. 

Having looked at a couple of very professional installations I can see the merit of the A frame, I just went for what I thought was the sensible option for me. I do travel to Germany and would not like to have to convince a German police officer of the validity of my equipment. 

This post has become a bit to personal - no need for that , one person offering an opinion that you don't like is no grounds for an attack. If you want the matter clarified and you have an A frame you make robust enquiries. Unless you think the outcome will be less than favourable . 

Remember:- Ignorance is no defense in law


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## beyondajoke (Jun 24, 2005)

*A Frames*

Are A frames iliegal then?


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## 88724 (May 9, 2005)

Hi

*Are A frames iliegal then?*

Yes totally in UK and Europe, except in certain instances for recovery.


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## Fatalhud (Mar 3, 2006)

picking up on the original post what worries me is that you mention how you lost 30% braking efficiency when a fuse blow

must admit it would worry me as i set myself up for a corner to find i have suddenly lost a large amount of braking power

i can understand why braking system should be mechanical and not rely on technology

being fairly new to this game i found it great to find this forum which answers all my questions and queries

i must admit i would sooner here the views of the likes of goerge who seem to at least research their answers instead of the 2 wrongs make a right brigade


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## 88781 (May 9, 2005)

That was only an opinion by VOSA, not a legal statement, until someone shows me clear evidence that the use of an A frame for (other than recovery) towing a car behind a motorhome in this country is an offence, then I will continue to support their use for motorhomers.

Regards Dave


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## 88724 (May 9, 2005)

Hi Dave

Its not only the opinion of VOSA, it is clearly stated in the trailer law. There is no grey area. 

Would you say its not ilegal to smoke in Scotland because no-one as been prosecuted yet?, thats clearly an absurd interpretation of when something actually becomes ilegal.

You want clear evidence of ilegality? read the thread with all the relevant trailer law quoted, an A frame clearly cannot comply, no if's but's or maybe's.


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## TonyHunt (Oct 10, 2005)

Fully agree with you Dave on this one as do hundreds of others who are towing with A frames. Maybe it isnt legal but so many are doing it and the authorities have good as rubber stamped things by not clamping down on the practice and turning a blind eye. Until such time as they start taking people to court for towing using A frames I shall keep on doing it as will most others I imagine. Its such a much easier and less stressful way of taking a car away with you than using a trailer. MPG is better by 2-3 miles per gallon also. 
I have returned mpg with my Fiat 740 Bessacarr of 22 towing our Agila on a trailer, 24 using A frame & 30 not towing the car at all. Thats on motorways doing 55mph on average.. 
I fully agree with george on his insistance that i can drive a 40ft RV on a car licence as they are not technically a goods vehicle. Dont know that I'd have the nerve to test the theory out though but I have no worries bout towing the car around on its A frame because I see too many people using them. Both these arguments will go on and on unitl such time as the courts sort it out if they ever do.


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## 88781 (May 9, 2005)

> You want clear evidence of ilegality? read the thread with all the relevant trailer law quoted, an A frame clearly cannot comply, no if's but's or maybe's.


 George, are we becoming infected by a new virus that causes folks to believe without question every groundless story, legend, and dire warning that shows up in their inbox or on their browser. The Gullibility Virus.

I strongly urge people examine themselves for symptoms of the virus, which include the following:

the willingness to believe improbable stories without thinking 
the urge to forward multiple copies of such stories to others 
a complete lack of desire to take three minutes to check to see if a story is true.

It smacks of the 'gassing' thing no grounds for conviction no bobbies activley handing out fines to motorhomes with cars on the back, no penalty points on licenses, no court convictions an d most of all no bad feeling mate..just my views :wink:

Dave


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## 88724 (May 9, 2005)

Hi Dave

_*Abscence of proof is not proof of abscence.*_

It is totally ilegal, nobody has been prosecuted (as far as I am aware) but that doesnt change the fact that it is ilegal, you would have no excuse if pulled and charged, with the motorhome weight thing of course you would win because the body of evidence and the legislation says there would be no case to answer (as evidenced by the only attempted prosecution)

Abscence of proof is not proof of abscence.

You may get away with using an A frame but that does not make it legal, People are not "getting away" with driving mega RV's because the law supports the Driver not the DVLA.

I am probably the last person who would catch the gullibility virus (famous last words) I dig and dig till I find the answer.

This is not something you can have a view or opinion on, opinion would be something like my favourite colour is Blue, no-one can change that or prove it wrong, but if you held the opinion that Blue is the best colour for keeping a motorhome roof cool, it would be incorrect, it is easily refuteable.

The best that can be said of A frames is that at present no-one is bothering to enforce the law.


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## 97022 (Dec 22, 2005)

Hi everyone

I think you will find that towing on an A-frame is only illegal if the A-frame (or the person using it) doesn't comply with the relevent legislation. It is wrong to simply state that towing on an A-frame is illegal.

When I chose to have mine fitted I also took as much advice as possible which included talking to the manufacturers. Those nice people at Car A Tow (because it is in their commercial interest to ensure it is legal) have also been in constant contact with the authorities to try and ensure their product complies. They have carried out tests on many of the most popular tow cars to ensure that a towed car without the benefit of an operating servo still complies with brake efficiency requirements and published an open letter to that effect some time ago. 

It certainly appeared to me that they had taken a responsible approach to ensuring the A-frame met all the mechanical requirements contained in trailer law and I, for one, have no qualms about towing my car using this method. The area they are not able to address is whether or not the person using the equipment complies and, for instance, can actually reverse a trailer when required.

I'm looking forward to some warmer weather though!

Regards, david


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## 88724 (May 9, 2005)

Hi David

Its in their commercial interest to sell it, this doesnt mean it is legal. An A frame cannot meet the legal requirements, it is legal for towing in recovery situations but not for people to tow a car for leisure purposes.

I cant remember the name but a Trailer representive body worked out that there was only one car which would meet the weight requirements for an Ubraked trailer, but even then it would be ilegal under the legislation because the vehicle had brakes they must operate at full efficiency which they cant.

I spoke to Marsham and the only way round that was to remove all the braking system Pads Pipes the lot, its easy enough to check ring Marsham.

For braked trailers besides the licencing requirements the braking system cannot be electrically operated it mus have an external handbrake that anyone can use when stood outside the vehicle can you do that? if not you are towing ilegaly.

The Spanish case often gets quoted too, they were lucky and got off on a technicality under recovery towing (which was obviously not true, why would they tow a broken down vehicle from UK to Spain?)

Bottom line coming up

Towing with A frames is ilegal (except for recovery usage)


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## olley (May 1, 2005)

So's not practicing Archery on a sunday

Olley


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## 88724 (May 9, 2005)

Hi Olley

I get your point, but this is more likely to be enforced at some point than antiquated "laws"

The main point here is to get people to realise/understand that A frame Towing is ilegal.

They may never get done for it, but if a case ever does go though there are going to be an awful lot of unhappy bunnies.

The chances are good that you will not be the first person prosecuted, its of course your gamble, you may buy one tommorow and they never bother prosecuting anyone or they may prosecute the first person later this week and suddenly the scrap yards will be full of useless A frames

The thing I would be more worried about would be if a Fatal accident occurs and they find some way to blame the A frame suddenly they would look very closely at the legality then, even if they knew about it, ie they do not have to worry about that until claim time. But this would be a complex issue.


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## guzzijim (May 1, 2005)

*rventhusiast* you have PM


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## guzzijim (May 1, 2005)

*GT* you have PM's


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## 97022 (Dec 22, 2005)

Hi George

OK this is it - I promise this is my last posting on this subject.

The open letter I referred to was dated April 2004 and was penned by Alan Bee the designer of the Car A Tow system. In it he documents the findings from their brake performance tests on a broad range of small to medium cars with the result that all cars tested not only met the requirement of 50% braking force in relation to maximum weight (without using the servo assistance) but far exceeded the requirement.

He also states that the Car A Tow system can meet the requirement to be able to reverse as contained in UN-ECE Regulation No. 13, Annexe 12, Page 137, Paragraph 3:4 and 3:5 - providing (as I said) the system is fitted and operated correctly and is in good condition.

Yes, my A-frame does have a manually operated handbrake (on the A-frame) that can be operated by anyone standing outside the car with both feet on the ground - it also has a built in skid that keeps the A-frame from touching the ground should it become detached from the tow vehicle and a breakaway cable fitted.

In his letter he quotes from a recent (at that time) statement by the Department for Transport:
*"When an A-frame is attached to a vehicle (e.g. a motor car) and towed by a motor vehicle (e.g. a motorhome) we believe the A-frame and car become a single unit and as such are classified in legislation as a trailer" - "we believe the use of A-frames to tow cars behind other vehicles is legal provided the braking and lighting requirements are met".*

Alan Bee says that anyone wishing to challenge any points he makes in his letter is invited to contact him at Pro-Tow Frames with details of which aspect of A-frame towing they consider is not legal. He can be contacted (by anyone wishing to do so) on 01202 632456.

I would certainly agree that there are some A-frames out there that definitely would not comply with the law and are, therefore, illegal. However, towing with an A-frame is not illegal if it complies with the requirements of the relevent law. I believe that my A-frame meets all the requirements and for the foreseeable future, I am going to carry on using mine in the way it was designed to be used.

Happy motorhoming everyone.

Regards, david

PS - guzzijim - I am sorry but I am not permitted to see my PM as I do not subscribe - please e-mail me if you need to speak [email protected]


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## 88724 (May 9, 2005)

Hi David

Reading that may lead people to believe that A frame towing is legal. PS note the goverment letter says IF

I still say It does not meet the legal requirement for braking, braking eff is not the end of it, was the braking electrically controlled? if so its ilegal.

OK its got an outside handbrake, does this operate all 4 wheels? or just the rear wheels ala a normal handbrake? If only the rear wheels its ilegal

Does the braking system *on all four wheels* get operated by an overun system or directly from the driver of the towing vehicles pedal and this must be by a Mechanical NOT electrical means. If not its ilegal

Reversing can this be done without mechanical intervention? if not its ilegal.


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## TonyHunt (Oct 10, 2005)

Theres shed loads of laws like that Olley that get ignored because of their uselessness and stupidity. Keep using the A frames I say until such time as the (muck) hits the fan, if ever. Those that are worried about getting stopped are the losers on what is a very useful and effective invention. Car A Tow and the other suppliers have all gone to a lot of trouble to ensure that the equipment is up to the job and is as safe as it can be. Nobody can make something 100% idiot proof.
This subject must have run its course. There will always be the users who are perfectly happy and will continue using the A frames until such time as somebody bothers to prove they cant. And at the same time there will always be somebody like george who is trying hard to single handedly frighten and stop us all from using such a wonderful invention. Lets change the record.


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## 88724 (May 9, 2005)

Hi Tony

Obviously people can and do use A frames, the point is that they should know they are breaking the law, not be encouraged to believe that its legal or even a grey area. The fact is that it is against the law here and in europe to to with an A frame (other than for recovery)

Tony can you reverse it like a proper trailer? if the answer is no thats one good safety reason for them to be ilegal


The other point of course is if someone gets killed or seriously injured and the insurance company start looking for an "out" They can easily say your covered, but then not pay out due to ilegality.


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## 88927 (May 10, 2005)

Hi all
I do not wish to get embroiled in this heated discussion or have abuse heaped upon me, and I have no intention of buying/using an A frame, however I believe a lot of people are doing so or wish to do so.
George you seem to be extremely knowledgeable about this subject but I have noticed on this thread that you seem to have contradicted yourself on a couple of points and made mistakes in quoting other peoples comments. Now please do not take this as a jibe or a poke and I ask this question in an impersonal manner.
George can you please point me at the relevant regulation / law that you are alluding to, to substantiate your claims. I am very confused about the yes/no arguments and if we can be permitted to view the material as requested then hopefully we will all be able to interpret the words and know whether any action relating to the proposed or actual use of an A frame does in fact break the law as you are suggesting.

Many thanks

Keith


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## 98266 (Mar 22, 2006)

I do not mean to spoil the fun, however a little bird has just informed me that the EU is bringing rules that mean all motor vehicles towed behind a mobile home must be on a trailer ? Are they right or is someone telling my porkies ?

Hudders


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## 88724 (May 9, 2005)

Hudders

Its already true

Kands

If you are going to say that you think I have contradicted myself at least say over what point, same with saying I have misquoted, please show where exactly.

The law is in this and the other thread, it was dissected pce by pce.

But here are a few snippets

Braked trailers must be fitted with a parking brake that operates on at least two road wheels on the same axle. At all times it must be capable of being maintained in operation by direct mechanical action without the use of hydraulic, electric or pneumatic systems - i.e. Operated by rod or cable action. The efficiency of the handbrake must also comply with EEC Directive 71/320/EEC; i.e. It must be capable of holding a stationary trailer on a gradient of at least 16% (1 in 6.25)

Here is a previous thread were the Law was dissected pce by pce, also some good external links to NTTA etc.

http://www.motorhomefacts.com/ftopic-12810-days0-orderasc-0.html


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## 2point (Jun 10, 2005)

Quote - "OK its got an outside handbrake, does this operate all 4 wheels? or just the rear wheels ala a normal handbrake? If only the rear wheels its ilegal"

Sounds contradictory to what you have just posted.

Quote "Braked trailers must be fitted with a parking brake that operates on at least two road wheels on the same axle."


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## 88927 (May 10, 2005)

GeorgeTelford said:


> Hudders
> 
> Its already true
> 
> ...


Thanks for the reply George.
I said at the outset that I was not going to get embroiled in this , I just wanted clarification. Regarding the contradiction I will point you to one... In one post you refer to the requirement for two wheels on the same axle being braked and later your reference is that if all four wheels are not braked it is illegal to use....
I only point to this for your information and to show why I am confused about the whole thing.
To be honest I have read through the threads and as you say it has been dissected many times however, unless I am missing something here all I see are interpretations and understandings by individuals. My question to you, as you seem to know the relevant laws and regulations, was to please point me in the direction of these articles so that I may read them for myself and get a true understanding of what they say and imply.
I look forward to you posting this information for me and hopefully once everyone has had an opportunity to also read the law for themselves, all the arguments will be a thing of the past because one may not agree with any given law but one cannot dispute it, in my honest opinion.

Thanks George

Keith


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## artona (Jan 19, 2006)

_Extract below taken from: http://www.ntta.co.uk/faq/default.htm_

*I have a motor home and want to tow a Fiat Seicento behind it using an A-frame. This car has a kerb weight under 750 kg so am I legal with this outfit?*

Sorry no is the answer. The law regards this as an unbraked trailer and you are allowed to tow up to 750 kg Gross Trailer Weight, not a car's kerb weight. The figure you have to use is the car's Gross Vehicle Weight or Maximum Permitted Weight. This is usually at least 300 - 400 kg more than the kerb weight. We have no knowledge of any car sold in the UK that has a GVW under 750 kg. The only vehicle we know that is completely legal to tow with an A-frame is the French Aixam small "car". This is a full four seater and details can be obtained from Aixam UK on 01926 886100. An A-frame or dolly can only be used to recover a broken down vehicle to a place of safety. Transporting a car is, therefore, illegal. A-frames may be offered with a braking system that applies the car's brakes. These do not conform to the law as the car then becomes a "braked trailer" and has to conform to European Directives contained within the Construction and Use Regulations. It does not conform to the European Directive 71/320/EEC and amendments regarding braking requirements in any way. The use of this A-frame for transportation is illegal. It is still OK for use to recover a vehicle to a place of safety


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## 88724 (May 9, 2005)

Hi

This is because there are two distinct sets of laws coming into play

On the non braked trailer below 750 KG, this is often sited as ok ie it doesnt need brakes, not true if brakes are fitted they must all be operational C&U Regs, trailer regs are quoted above, see? because the car has brakes on all wheels they MUST all be operational, if it were a straight trailer only the minimum number of wheels would have to be braked BUT if there were drums on a seperate axle they would have to be operational too. No contradiction.

I have only quoted the parts of the law that an A frame cannot seem to overcome, there are literally reams of pages on trailer law


Follow the links, the laws are named in the threads, Google them, you will get the original in all their glory.


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## 88927 (May 10, 2005)

Thanks for the response Stewart, that seems to clarify the situation a little, in a very easy to read way. I appreciate the info and I think everyone else will now be able to understand this complex situation.

Thanks again.

Keith


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## 88724 (May 9, 2005)

Hi Keith

Forgive me, but your having a laff aint ya, wth does that say that I have not already said?

I said it simply way back, did you not read my earlier posts

Towing with an A frame is ilegal unless for recovery, I even explained in the simplist terms why an A frame could not comply with the law, only when people disagreed did it get complex. same old same old


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## DJP (May 9, 2005)

*A frames*

I have watched this topic and numerous other topics regarding A Frame towing.

Do people understand the difference between an A Frame and a towing "dolly"?
It is frequntly posted as per the quote below


> Towing with an A frame is ilegal unless for recovery


My A frame will ONLY fit a car fitted with the neccessary modification to the towed vehicle NOT just ANY car. So you are unlikely to spend £400+ to have a recovery facility fitted permamently to one car. 

It is more likely people are refering to a towing "dolly" when mentioning "Towing with an A frame is ilegal unless for recovery"
That in itself muddies the water. Recovery? What, where from, why?
Can I disable the car by some means whilst I am towing and say I am just recovering it? 8O 
It's all illegal and down to common sense by the parties involved as is the view on speeding, illegal parking and overweight motorhomes etc etc.
Whilst my insurers for the MH and Smart car are aware and DO cover me for towing I am prepared to carry on towing or at least until someone somewhere sets a precident in a court case in the UK, to my knowledge that has not happened YET.


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## artona (Jan 19, 2006)

Hi DJP

I think this might be the case.


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## 88927 (May 10, 2005)

GeorgeTelford said:


> Hi Keith
> 
> Forgive me, but your having a laff aint ya, wth does that say that I have not already said?
> 
> ...


You are forgiven George :lol: :lol: 
No you are wrong I'm afraid. I hear and see so many references to what is legal/illegal and asked for a definitive pointer to the laws which you stand upon in order to substantiate your claims. In this instance the subject was A Frame towing.
Stewart was kind enough to provide the link to that information in a clear, unclouded way, and I thanked him. Simple really. I realise that you have already put that pointer into your several posts however I wanted to see the actual text document of the specific laws/regulations that you quote people are falling foul of, and I am sure I am not the only one (I am not invoking the masses here, just stating the obvious from the interest generated by the topic).
I have to say that I still have not had sight of the legal texts in there original form, but there would appear to be enough circumstantial evidence to presuppose that these laws actually exist within our legal system. I cannot be bothered to spend my life looking for these documents which is why I asked for a pointer.
Laff??? I think not George.

Many thanks

Keith


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## peejay (May 10, 2005)

I think I might just buy myself an 'a' frame or whatever you call them, attach my fiesta to the back of the van and reverse it into the wall of my local police station running over the toes of pc plod in the process and be the first test case so that this issue gets sorted once and for all. Will the MHFacts kitty stump up for my leagal fees do you think ? :roll: :wink: 

Nice to see you're all keeping it civil guys (I think) and above all, keep your sense of humour in this thread!

pete.


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## 88724 (May 9, 2005)

Hi DJP

There are no muddy waters, in this thread and the other The EU directive's and the C&U for this country are absolutely clear towing with an A frame is ilegal, that is its ilegal here and in EU. A frames cannot meet the legal requirements. There is no grey area at all.

Hi Keith

If you had read the thread's you would have seen that I had already quoted that passage, because a certain troublemaker (no longer with us, under the Jeeps Pseudonym anyway) Said that the NTTA had stated that A frame towing was legal, I had already quoted that passage and shown that it did not support legal A frame towing even for the Axiom which they have incorrectly said is OK is in contrevention of the UK construction and use regs. ie _*The only vehicle we know that is completely legal to tow with an A-frame is the French Aixam small "car". *_ utter rot it as brakes and so they must work, so that blows the only car the NTTA say is legal straight out of the water.

Al the eu dierectives have been quoted and linked to as well.


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## 2point (Jun 10, 2005)

Is it true to say that using an A Frame for the purposes of recovery is legal then?


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## 88724 (May 9, 2005)

Hi 2 Point 

I got fed up of writing except for recovery

so bite me


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## 2point (Jun 10, 2005)

No problem.

That seems to be the clause that would be able to be used to get off from a charge if it went ot court. Very little diffeence between transporting and recovering. It's all down to definition, intent and proving that intent.


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## TonyHunt (Oct 10, 2005)

Quite right DJP. I made doubly sure with my insurers the NFU and I have it in writing from them that I am covered fully whilst towing my car behind my motorhome on an A frame. Safeguard are another insurer who do this also. Surely their legal departments have studied these laws before commiting themselves. Im the same DJP I will continue to use our A frame until somebody in authority proves to me otherwise that Im breaking any laws. Theres too much heresay and Im right jack amongst all the posts on the subject. With all due respect to george, hes the main or only person on here that continually preaches that we are breaking the law. On another hand hes telling us that we are not breaking the law if we jump in an overweight RV without more than a car licence or drive on a ferry etc with our gas taps turned on. Its enough to flumox the best of us. All we are hearing is one mans interpretations of the laws. I have in the last few days seen dozens of cars on A frames being towed along our local stretch of the main A31 near the New Forest. Take that country wide and there must be many hundreds being used. Its going to be difficult to police all that lot and the companies who are making them have at least a months waiting list and full order books.


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## 88927 (May 10, 2005)

Hi
I have given in and tried to research (albeit quickly) to find absolute reference to a legal document and the following is somewhat limited but does provide good clear information.

http://www.motorcaravanning.co.uk/vehicles/towing.htm
(with thanks to motorcaravanning.co.uk for this helpful text)

http://www.towitall.co.uk/faq/faq4.htm
which points to:
http://certification.mira.co.uk/Braking.htm

And so far I have not been able to find any relevant legal texts that say "this is illegal"....
So maybe someone who can spend more than an hour on this would care to undertake to find this actual law.
Unless I am missing something here????????

Thanks

Keith


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## billym (Dec 17, 2005)

We used to tow on an a frame but find it much easier to travel in two vehicles. The only extra expense is the diesel and the flexibility it offers far outweighs the A frame dilema.
I don,t know about their legality but I have a copy of a letter written by the Direccion General de Trafico in Madrid. It is in Spanish with a small relevant translation. It was sent to someone who was fined in Spain for his A frame. He contested the fine which was recinded. This suggests that the Spanish police in a formal manner accept A frames. It does make reference to the directive 94/20 whatever that is. It might be the Spanish police know their stuff or it might be as I suspect, that like all Police all over Europe neither know nor care about it. I agree that it may be a get out for insurance companies but if you can prove you told them you will use an A frame they will have absolutely no leg to stand on.


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## 88724 (May 9, 2005)

Hi 2 point,

There is a world of differencve between recovering a broken down vehicle and lugging for leisure, ones legal the other is not for a start.

Billym

The spanish case

They got away with it on the grounds of recovering the vehicle, hello anybody home? why did the spanish court accept that they towed a broken down car all the way to Spain and back? That makes sense. The Spanish court must have been having a special dumb day.

Knads,

no you are missing nothing it is and always as been ilegal to tow using and A frame (cept rec.)

Tony,

_*Surely their legal departments have studied these laws before commiting themselves*_

The fact of insurance as nothing to do with legality they will/may look into it in the event of a major crash.
_*
proves to me otherwise that Im breaking any laws.*_

Your are breaking the law, its clear that A frames are ilegal for this kind of towing, you are only deluding yourself if you think optherwise.


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## 88927 (May 10, 2005)

Thanks for the reply Gorgee.
Still dont see the actual law though, so I am confused that if no-one can produce a copy of the pertinent law I find myself asking if it actually exists.
All....
Maybe I will ask my daughter to find out (she is training to be a solicitor) and then maybe we will have a definitive answer.
I thought with all the strong opinions demonstrated on this and the other threads that it would be quite simple for someone to provide a link to the law that all you A Framers are breaking, but no wonder no-one has ever been charged with the offence if it is this difficult to find out which law has been broken.

Many thanks all 

Keith


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## 92180 (May 1, 2005)

I just picked up the May edition of Practical Motorhome . In an article on towbars it also details the A frame topic. 

A-frame towing 
The Department for Transport 
states: 

"The use of A-frames 
to tow cars behind other 
vehicles is legal, provided 
that the braking and lighting 
requirements are met." 
The department considers 
a car and A-frame to be a 
trailer, which implies that if 
the total weight is under 750kg 
(see Aixam in 'contacts'below) 
the trailer does not need to be 
braked. Significantly, it is the 
stated MAC that is printed 
on the VIN plate of the towed 
vehicle that applies here, not 
the kerb weight, regardless of 
its actual weight. 
Above 750kg, regulations 
require that all wheels are 
braked, and this is usually 
achieved by activating the 
towed car's brakes through 
a direct link from the towing 
vehicle's own brakes. These 
braking systems, when in 
compliance with ECU Directive 
71/320, are considered suitable 
for use in the UK. 
There are difficulties, 
however, in complying with 
this regulation. An A-frame 
system cannot legally be fitted 
to a motorhome in mainland 
Europe but that does not 
necessarily prevent a 
UK-installed A-frame from 
being used on the mainland. 
It is permissible to temporarily 
import a 'van into another 
member country without 
the need for modification. 
This is provided, however, 
that the motorhome complies 
with the use and construction 
regulations of its country 
of registration. 
Without clarification and 
consolidation of the many 
regulations, the situation 
remains a little murky and 
is likely to be interpreted 
by the courts. But towing 
and A-frame specialists will 
happily advise on proper use. 
Towing dollies, which 
are used by garages for 
the recovery of broken-down 
vehicles, are exempt from 
many regulations. However, 
it is illegal to use them for 
the private transportation of 
a working, driveable car. 

Sorry about the layout scanned the column. Hope this is of some use.


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## sallytrafic (Jan 17, 2006)

Sorry this is just a cheap rehash, we've seem most of this before copied in these Forums. I can see one error in law, and one big IF.


Regards Frank


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## 92180 (May 1, 2005)

Sorry I just took time to scan a section from a current magazine. 

I really don't care I have a trailer. So I know that I am definitely legal.


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## TonyHunt (Oct 10, 2005)

Its becoming more obvious methinks that poor old george must have some connection to a trailer manufacturer :lol: 
Dont think hes ever going to convince the vast majority of us how ever many times he repeats himself. Im happy, my insurance company have written saying they are happy, Plod doesnt seem to give a stuff so no problem as far as im concerned.


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## 2point (Jun 10, 2005)

George, curious how I stated that the law could be interpreted with some fluidity and in your very next reply you confirm a case that used that defence.

I think that is evidence enough that this is not black and white.


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## Fatalhud (Mar 3, 2006)

why don't you all just agree to disagree


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## 88724 (May 9, 2005)

Hi 2point

No I showed one stupid decision by a Spanish court, it is obvious to anyone that they would not have lugged a duff car, they bluffed on a technicality. Simple logic says they lied and got away with it. They bought and had an A frame fitted simply to transport a duff car on holiday? Lucky the Spanish were not thinking that day.

Tony 

I have no connection with a trailer manufacturer and I resent the snide implication (and of course the uncalled for personal comments), only a desire to see the facts and truth promoted. Fact it is ilegal to lug for liesure, nobody with the slightest amount of grey matter can read the law and think otherwise. It cannot be interpreted to say this is legal. 

You and others are getting away with breaking the law due simply to lax policing, you want to gamble that the lax policing will continue? fair enough, but dont try to convince people its legal.

I would hope that the personal comments you have included in your post will be removed asap.

Serious question, do you want to be a "test" case? this is not a threat, but a genuine question.


Frank

What's the error in the law

Hi Asgard

The Dept of transport have got it wrong, a trailer below 750 does not have to have brakes fitted, BUT if they are they must be working.


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## gaspode (May 9, 2005)

OK gent's, this topic is just going round in circles now. We are at a position where the opposing views do not and will never agree, such that further discussion is likely to lead to personal insults. It would be a shame to delete or lock the topic in case someone comes along with a new angle on the subject but I think it's on the brink of being locked at the very least.

Please could you all refrain from posting any more on this thread unless you have some entirely new and relevant information - or if you wish to apologise!


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## 97993 (Mar 5, 2006)

The whole world is saying it's legal to tow with an A frame* if the relevant regulations are adhered to*

George is saying it is *imposable* to adhere to the regulations ergo it is illegal to use A frames for pleasure use
whats more i have one and use it both legal and illegally and agree with him on this one
In a previous post I pointed out that cars carried on trailers were not in fact insured unless you have goods in transit insurance (if all wheels are off the road its not covered by Mh or car policy 
I find that more concerning than the A frame issue, Insurance companys have said it's ok to use A frame and by ok I suspect they mean as the wheels are in contact with the road your covered from an insurance point of view not a legal point of view
Geo


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## sallytrafic (Jan 17, 2006)

GeorgeTelford said:


> Frank
> 
> What's the error in the law


George I didn't say "in the law' I said 'in law' The error to which I refer in the piece by Practical Motorhome (which purports to be a direct quotation from the DfT) is as follows:

"The department considers 
a car and A-frame to be a 
trailer, which implies that if 
the total weight is under 750kg 
(see Aixam in 'contacts'below) 
the trailer does not need to be 
braked."

The error is that if the trailer has brakes then they must work and obviously the car has brakes ergo they must work as indeed I'm sure you have said previously. Without a facsimile of the DfT letter I can't say absolutely if the error lies with the DfT, the person who selectively quoted it or whoever made the implication but I don't think it matters. If a trailer has brakes they have to work. I once saw the Statutary Instrument (ie Law) that said that in black and white but these days I expect it would cost money to get a copy of it. There is also case law on this particular point.

I have seen the DfT letter copied in full but not I regret a facsimile ie showing their letter head and a signature the sentence read as follows

"Trailers having a combined axle mass not exceeding 750kg are not required to have brakes fitted. However, if the trailer (regardless of mass) is fitted with a braking system, then all brakes in that system must operate correctly."

So a car towed with an A frame is considered a trailer then if it has brakes regardless of weight they must work then all the references to a car that meets these requirements as an unbraked trailer are nonsense unless of course the French make a car with no brakes but then I guess new laws would come into play once it was disconnected :shock:

Regards Frank


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## 88724 (May 9, 2005)

Hi Frank 

yes thats inline with what I have been saying all along, I just anted to be sure you had not spotted something that I had missed.


George


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## 88927 (May 10, 2005)

Hi Ken
Please do not lock this thread because I am waiting in the vain hope that someone can provide me with a link to the actual text of the laws and regulations that are being discussed here. I have read what everyone has SAID but I personally would like to READ the document for myself.
I am not claiming anyone is right or wrong, I would just like to be able to make my own mind up on this issue, and I am afraid that the constant restating of "facts" will not suffice. I want to see the facts.
So please if any of you legal experts can provide a link to the actual text of the laws regarding the legal/illegal use of an A Frame I will be very pleased to read it.

Keith


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## sallytrafic (Jan 17, 2006)

kands said:


> Hi Ken
> Please do not lock this thread because I am waiting in the vain hope that someone can provide me with a link to the actual text of the laws and regulations that are being discussed here. I have read what everyone has SAID but I personally would like to READ the document for myself.
> I am not claiming anyone is right or wrong, I would just like to be able to make my own mind up on this issue, and I am afraid that the constant restating of "facts" will not suffice. I want to see the facts.
> So please if any of you legal experts can provide a link to the actual text of the laws regarding the legal/illegal use of an A Frame I will be very pleased to read it.
> ...


Keith its not that simple to read a stautary instrument you have to buy it and all the amendments, there is going to be a database of all SIs in 2006 but you will still have to pay. For the majority of users the original letter from the DfT is as close as we are likely to get but let me give you a sense of what you might expect to see then you probably won't want to pursue it

Statutory Instrument 1992 No. 352
The Road Vehicles (Construction and Use) (Amendment) Regulations 1992

© Crown Copyright 1992

The legislation contained on this web site is subject to Crown Copyright protection. It may be reproduced free of charge provided that it is reproduced accurately and that the source and copyright status of the material is made evident to users.

It should be noted that the right to reproduce the text of Statutory Instruments does not extend to the Royal Arms and the Queen's Printer imprints.

The text of this Internet version of the Statutory Instrument has been prepared to reflect the text as it was Made. The authoritative version is the Queen's Printer copy published by The Stationery Office Limited as the The Road Vehicles (Construction and Use) (Amendment) Regulations 1992, ISBN 0110233522. Purchase this item. For details of how to obtain an official copy see How to obtain The Stationery Office Limited titles.

To ensure fast access over slow connections, large documents have been segmented into "chunks". Where you see a "continue" button at the bottom of the page of text, this indicates that there is another chunk of text available.

STATUTORY INSTRUMENTS

1992 No. 352

ROAD TRAFFIC

The Road Vehicles (Construction and Use) (Amendment) Regulations 1992

Made	24th February 1992
Laid before Parliament	28th February 1992
Coming into force	1st April 1992
The Secretary of State, in exercise of the powers conferred by section 41(1), (2)(g) and (5) of the Road Traffic Act 1988[1] and of all other enabling powers, and after consultation with representative organisations in accordance with section 195(2) of that Act, hereby makes the following regulations:-
Commencement and Citation
1. These Regulations may be cited as the Road Vehicles (Construction and Use) (Amend ment) Regulations 1992 and shall come into force on 1st April 1992.
2. The Road Vehicles (Construction and Use) Regulations 1986[2] shall be further amended in accordance with the following provisions of these Regulations.
Amendments to Regulation 15 (braking systems of certain vehicles first used on or after the 1st of April 1983)
3.-(1) Regulation 15 shall be amended as follows.

(2) In the Table for sub-paragraph (c) in column 2 of item 1 there shall be substituted-
"(c) vehicles with three wheels, an unladen weight not exceeding 410 kg, a maximum design speed not exceeding 50 km/h and an engine capacity not exceeding 50 cc;" .

(3) In paragraphs (3)(d)(i) and (4) for "or 13.05" there shall be substituted ", 13.05 or 13.06".

(4) For paragraph (5) there shall be substituted-
" (5) Instead of complying with paragraph (1A) of this regulation, a vehicle to which this regulation applies may comply with ECE Regulation[3] 13.05 or 13.06.

(5A) Instead of complying with paragraph (1C) of this regulation, a vehicle to which this regulation applies may comply-
(a) in the case of a trailer manufactured before the 1st April 1992, with ECE Regulation 13.05 or 13.06; or
(b) in the case of any vehicle not falling within sub-paragraph (a), with ECE Regulation 13.06."

Amendments to regulation 16 (braking systems of other vehicles)
4.-(1) Regulation 16 shall be amended as follows.

(2) In paragraph (2) for the words "regulation 15(1)" onwards there shall be substituted the words "regulation 15(1), (1A) or (1C), or which complies with Community Directive 79/489, 85/647 or 88/194 or ECE Regulation 13.03, 13.04, 13.05 or 13.06".

(3) For paragraph (5) there shall be substituted the following paragraphs-
" (5) Subject to paragraphs (5B) and (6), the braking system of a motor cycle to which this regulation applies and which is-
(a) of a class specified in an item in column 2 of the Table below; and
(b) first used on or after 1st April 1987 and before 22nd May 1995;
shall comply with ECE Regulation 13.05, 78 or 78.01 in relation to the category of vehicles specified in that item in column 3.

(5A) Subject to paragraph (6), the braking system of a motor cycle to which this regulation applies and which is-
(a) of a class specified in an item in column 2 of the Table below; and
(b) first used on or after 22nd May 1995;
shall comply with ECE Regulation 78.01 in relation to the category of vehicles specified in that item in column 3.
TABLE
(Regulation 16(5) and (5A))
1	2	3
Item	Class of Vehicle	Vehicle Category in ECE Regulations
1	Vehicles (without a sidecar attached) with two wheels, an engine capacity not exceeding 50 cc and a maximum design speed not exceeding 50 km/h.	L1
2	Vehicles with three wheels (including two-wheeled vehicles with a sidecar attached) and with an engine capacity not exceeding 50 cc and a maximum design speed not exceeding 50 km/h.	L2
3

Vehicles with two wheels (without a sidecar attached) and with-
(a) an engine capacity exceeding 50 cc, or
(b) a maximum design speed exceeding 50 km/h.

L3
4

Vehicles with two wheels, a sidecar attached and-
(a) an engine capacity exceeding 50 cc, or
(b) a maximum design speed exceeding 50 km/h.

L4
"

(4) Paragraph (5A) shall be renumbered as paragraph (5B).
Amendments to Regulation 17 (vacuum or pressure brake warning devices)
5.-(1) In regulation 17(2)(a)-
(a) for the words "paragraph (1) or (1A)" there shall be substituted the words "paragraph (1), (1A) or (1C)"; and
(b) for "or 13.05" there shall be substituted ", 13.05 or 13.06".

Amendments to Regulation 18 (maintenance and efficiency of brakes)
6.-(1) Regulation 18 shall be amended as follows.

(2) After paragraph (1) there shall be inserted the following paragraph-
" (1A) Without prejudice to paragraph (3), where a vehicle is fitted with an anti-lock braking system ("the ABS"), then while the condition specified in paragraph (1B) is fulfilled, any fault in the ABS shall be disregarded for the purposes of paragraph (1).

(1B) The condition is fulfilled while the vehicle is completing a journey at the beginning of which the ABS was operating correctly or is being driven to a place where the ABS is to undergo repairs." .

(3) In item 1 in Table I and in paragraph (8) for "or 13.05" there shall be substituted ", 13.05 or 13.06".
Amendments to Schedule 3 (braking requirements)
7. In the Table in Schedule 3, in items 4 and 6, for "or 13.05" there shall be substituted ", 13.05 or 13.06".
Consequential amendments
8. In Table II of Schedule 2-
(a) item 5 shall be re-numbered as item 4A;
(b) after item 4A as so re-numbered there shall be inserted the following item-
4B	13.06	13	29.5.69	Brakes	22.11.90	--
(c) after item 9, there shall be inserted the following items-
9A	78	78	15.10.88	Brakes	-	--
9B	78.01	78	15.10.88	Brakes	22.11.90	--

Signed by authority of the Secretary of State for Transport

Christopher Chope

Parliamentary Under Secretary of State, Department of Transport

24th February 1992

EXPLANATORY NOTE

(This note is not part of the Regulations)
These Regulations further amend the Road Vehicles (Construction and Use) Regulations 1986 in relation to braking requirements.
Regulation 15 of the 1986 Regulations requires certain vehicles to comply with the brake requirements set out in various EEC Directives or various ECE Regulations. Previously, three-wheeled vehicles were exempt from this requirement if they had a maximum gross weight of not more than 1,000 kg, a design speed of not more than 40 km/h and an engine capacity of not more than 50 cc. As a result of the amendments, this exemption will apply to vehicles with an unladen weight of not more than 410 kg, a maximum design speed of not more than 50 km/h and an engine capacity of not more than 50 cc. An exemption for motor cycles with a sidecar attached is not affected.
Regulation 15(1C) of the 1986 Regulations specifies the Directive applicable to motor vehicles first used on or after 1st of April 1992 and trailers manufactured on or after 1st October 1991. These vehicles were previously, in all cases, given the option of complying instead with ECE Regulation 13.05 (see regulation 15(5)). With the exception of trailers manufactured e.g. before the 1st April 1992, the option will now be to comply with ECE Regulation 13.06 and not 13.05.
Previously, regulation 16(5) of the 1986 Regulations imposed certain requirements on motor bicycles (with or without a sidecar) first used on or after the 1st April 1987. Regulation 16(5) is replaced by provisions which apply to all motor cycles first used on or after the 1st April 1987 which are not subject to regulation 15 as stated above. "Motor cycle" is defined in regulation 3 of the 1986 Regulations as a mechanically propelled vehicle, not being an invalid carriage, having less than four wheels and the weight of which unladen does not exceed 410 kg.
Previously, a vehicle to which regulation 16(5) applied had to comply with ECE Regulation 13.05. The vehicles to which the new provisions apply will have to comply with ECE Regulation 13.05, 78 or 78.01 if they are first used before the 22nd of May 1995 or with ECE Regulation 78.01 if they are first used on or after the 22nd May 1995.
Regulation 18(1) of the 1986 Regulations requires every part of a braking system to be in good order. The regulation is amended so that in certain circumstances it is permissible to drive a vehicle with a fault in its anti-lock braking system ("ABS"). The exemption enables a vehicle to complete its journey if the fault arose after the journey began or to be driven to a place where the ABS is to be repaired. However, the vehicle could not be driven if the braking system did not meet the braking efficiency requirements of regulation 18(3).
Other amendments are consequential upon the making of ECE Regulation 13.06. Various other provisions in regulations 15 to 18 of the Regulations require vehicles to comply or give vehicles the option of complying with ECE Regulation 13.05. In all these cases, vehicles are given the option or further option of complying with ECE Regulation 13.06.
Copies of the ECE Regulations referred to in these Regulations can be obtained from Her Majesty's Stationery Office. The details of the ECE Regulations are set out in the Table below.
Principal Instrument	Relevant Amending Instruments
Regulation 13 annexed to the Agreement concerning the adoption of uniform conditions of approval for motor vehicle equipment and parts and reciprocal recognition thereof concluded at Geneva on 2nd March 1958 (Cmnd 2535) as amended (Cmnd 3562) to which the United Kingdom is a party by an instrument of accession dated 14th January 1963 deposited with the Secretary General of the United Nations on 15th January 1963 ("the ECE Agreement").	Revised on 11th July 1974; amended on 4th January 1979; amended on 11th August 1981; amended on 26th November 1984; amended on 1st April 1987; amended on 5th October 1987; amended on 29th July 1988; amended on 22nd November 1990.
Regulation 78 annexed to the ECE Agreement	Amended on 22nd November 1990.

ISBN 0 11 023352 2

Notes:

[1] 1988 c. 52. back

[2] S.I. 1986/1078; relevant amending instruments are S.I.s 1987/676 and 1990/1981. back

[3] "ECE Regulation" is defined in regulation 3(2) of, and Table II of Schedule 2 to, the Road Vehicles (Construction and Use Regulations) 1986. Table II of Schedule 2 is amended by regulation 8 of these Regulations.back


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## sallytrafic (Jan 17, 2006)

And if you find all that a bit heavy let me remind you that this is an amendment but there is a gem in it see explanatory note about half way down: 

"Regulation 18(1) of the 1986 Regulations requires every part of a braking system to be in good order"


Regards Frank


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## 88724 (May 9, 2005)

Hi Keith

You have asked this same thing before and I have already pointed out that the legislation is named and linked to, why do you find it so hard to read through the threads and follow the links? as someone else really got to trawl through the threads to save you the trouble?

Unless you want to buy Maxwell Sweets automotive law book's (and if you see the price you wont) you will have to ring Marsham and ask, or trust that me and Frank are not liars on the construction and Use front, basically thats just the law on brakes ie if fitted must work. The EU directives are linked to.


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## 88724 (May 9, 2005)

Here is the first part of (71/320/EEC) you want the rest Keith ?

COUNCIL DIRECTIVE of 26 July 1971 on the approximation of the laws of the Member States relating to the braking devices of certain categories of motor vehicles and of their trailers (71/320/EEC)

THE COUNCIL OF THE EUROPEAN COMMUNITIES, 

Having regard to the Treaty establishing the European Economic Community, and in particular Article 100 thereof; 

Having regard to the proposal from the Commission; 

Having regard to the Opinion of the European Parliament1; 

Having regard to the Opinion of the Economic and Social Committee2; 

Whereas the technical requirements which motor vehicles must satisfy pursuant to national laws relate, inter alia, to the braking devices of certain categories of motor vehicles and of their trailers; 

Whereas those requirements differ from one Member State to another ; whereas it is therefore necessary that all Member States adopt the same requirements either in addition to or instead of their existing rules, in order, in particular, to allow the EEC type approval procedure which was the subject of the Council Directive of 6 February 1970 on the approximation of the laws of the Member States relating to the type approval of motor vehicles and their trailers to be applied in respect of each type of vehicle3; 

Whereas the harmonised requirements must ensure road safety throughout the whole Community; 

HAS ADOPTED THIS DIRECTIVE:


Article 1

1. For the purposes of this Directive, "vehicle" means any motor vehicle falling within one of the international categories listed below and intended for use on the road, such vehicle being with or without bodywork, having at least four wheels and a maximum design speed exceeding 25 km/h, and its trailers, with the exception of vehicles which run on rails, agricultural tractors and machinery and public works vehicles: (a) Category M : Motor vehicles having at least four wheels or having three wheels when the maximum weight exceeds 1 metric ton, and used for the carriage of passengers: - Category M1 : Vehicles used for the carriage of passengers, and comprising not more than eight seats in addition to the driver's seat; 

- Category M2 : Vehicles used for the carriage of passengers, comprising more than eight seats in addition to the driver's seat, and having a maximum weight not exceeding 5 metric tons; 

- Category M3 : Vehicles used for the carriage of passengers, comprising more than eight seats in addition to the driver's seat, and having a maximum weight exceeding 5 metric tons. 



(b) Category N : Motor vehicles having at least four wheels or having three wheels when the maximum weight exceeds 1 metric ton, and used for the carriage of goods: - Category N1 : Vehicles used for the carriage of goods and having a maximum weight not exceeding 3 75 metric tons; 

- Category N2 : Vehicles used for the carriage of goods and having a maximum weight exceeding 3 75 but not exceeding 12 metric tons; 1 OJ No C 160, 18.12.1969, p. 7. 2 OJ No C 100, 1.8.1969, p. 13. 3 OJ No L 42, 23.2.1970, p. 1. 

- Category N3 : Vehicles used for the carriage of goods and having a maximum weight exceeding 12 metric tons. 



(c) Category O : Trailers (including semi-trailers): - Category O1 : Trailers with a maximum weight not exceeding 0 775 metric tons; 

- Category O2 : Trailers with a maximum weight exceeding 0 775 but not exceeding 3 75 metric tons; 

- Category O3 : Trailers with a maximum weight exceeding 3 75 but not exceeding 10 metric tons; 

- Category O4 : Trailers with a maximum weight exceeding 10 metric tons. 





2. Articulated category M vehicles made up of two non-separable but articulated units shall be considered to be single vehicles. 

3. In the case of a category M or N drawing vehicle designed to be coupled to a semi-trailer, the maximum weight to be taken into consideration when classifying that vehicle shall be the weight of the drawing vehicle in running order plus the maximum weight transferred to the drawing vehicle by the semi-trailer and, where appropriate, the maximum weight of the drawing vehicle's own load. 

4. In the case of category N vehicles, the equipment and fittings of certain special vehicles not intended for the carriage of passengers (such as crane vehicles, workshop vehicles, publicity vehicles) shall be considered to be goods. 

5. The maximum weight to be taken into consideration when classifying a category O semi-trailer shall be the weight transmitted to the ground by the axle or axles of the semi-trailer when coupled to the drawing vehicle and laden with a maximum load. 


Article 2

No Member State may refuse to grant EEC type approval or national type approval of a vehicle on grounds relating to its braking devices if that vehicle is fitted with the devices specified in Annexes I to VIII and if these devices satisfy the requirements set out therein. 


Article 3

The Member State which has granted type approval shall take the necessary measures to ensure that it is informed of any modification to a component or characteristic mentioned in item 1.1 of Annex I. The competent authorities of that State shall decide whether the modified prototype should be submitted to fresh tests and whether a fresh report should be drawn up thereon. If such tests reveal failure to comply with the requirements of this Directive, the modification shall not be authorised. 


Article 4

Pending the entry into force of a separate Directive on the definition of an "urban bus", such vehicles shall continue to be submitted to the Type II A test described in Annex II where their maximum weight exceeds 10 metric tons. 


Article 5

The amendments necessary for adjusting the requirements of the Annexes so as to take account of technical progress shall be adopted in accordance with the procedure laid down in Article 13 of the Council Directive of 6 February 1970 on the type approval of motor vehicles and their trailers. 


Article 6

1. Member States shall put into force the provisions containing the requirements needed in order to comply with this Directive within eighteen months of its notification and shall forthwith inform the Commission thereof. 

2. With effect from 1 October 1974, the provisions of item 2.2.1.4 of Annex I shall also apply to vehicles other than those in category M3 or category N3. 

3. Member States shall ensure that the texts of the main provisions of national law which they adopt in the field covered by this Directive are communicated to the Commission. 


Article 7

This Directive is addressed to the Member States.



Done at Brussels, 26 July 1971. 

For the Council 

The President 

A. MORO 




ANNEX I DEFINITIONS, REQUIREMENTS, CONSTRUCTION AND FITTING 

1. DEFINITIONS 1.1. "Type of vehicle with respect to the braking devices" 

"Type of vehicle with respect to the braking devices" means vehicles which do not differ in such essential respects as: 1.1.1. In the case of motor vehicles 1.1.1.1. the vehicle category, as defined in Article 1 of this Directive 

1.1.1.2. the maximum weight, as defined in item 1.14 

1.1.1.3. the distribution of weight among the axles 

1.1.1.4. the maximum design speed 

1.1.1.5. a different type of braking device with particular reference to the presence or otherwise of devices for braking a trailer 

1.1.1.6. the number and arrangement of the axles 

1.1.1.7. the engine type 

1.1.1.8. the number and ratios of gears 

1.1.1.9. ratio(s) of rear drive axle(s) 

1.1.1.10. the tyre dimensions 



1.1.2. In the case of trailers 1.1.2.1. the vehicle category, as defined in Article 1 of this Directive 

1.1.2.2. the maximum weight, as defined in item 1.14 

1.1.2.3. the distribution of weight among the axles 

1.1.2.4. a different type of braking device 

1.1.2.5. the number and arrangement of the axles 

1.1.2.6. the tyre dimensions 





1.2. "Braking device" 

"Braking device" means the combination of parts whose function is progressively to reduce the speed of a moving vehicle or to bring it to a halt, or to keep it stationary if it is already halted. These functions are specified in item 2.1.2. The device shall consist of the brake control, the transmission and the brake proper. 

1.3. "Graduated braking" 

"Graduated braking" means braking during which, within the normal range of operation of the device, during either the application or the releasing of the brakes, - the driver can, at any time, increase or reduce the braking force through action on the control, 

- the braking force acts in the same direction as the action on the control (monotonic function), 

- it is easily possible to make a sufficiently fine adjustment to the braking force. 



1.4. "Control" 

"Control" means the part actuated directly by the driver (or, where appropriate, in the case of a trailer, the driver's mate) to supply to the transmission the energy required for braking or controlling it. This energy may be the muscular energy of the driver, or energy from another source controlled by the driver, or in appropriate cases the kinetic energy of a trailer, or a combination of these various kinds of energy. 

1.5. "Transmission" 

"Transmission" means the combination of components situated between the control and the brake and connecting the two operationally. The transmission may be mechanical, hydraulic, pneumatic, electrical, or mixed. Where the braking power is derived from or assisted by a source of energy independent of the driver but controlled by him, the reserve of energy in the device shall likewise be regarded as part of the transmission. 

1.6. "Brake" 

"Brake" means the part in which the forces opposing the movement of the vehicle develop. It may be a friction brake (when the forces are generated by the friction between two parts of the vehicle moving relatively to one another) ; an electrical brake (when the forces are generated by electromagnetic action between two parts of the vehicle moving relatively to but not in contact with one another) ; a fluid brake (when the forces are generated by the action of a fluid situated between two parts of the vehicle moving relatively to one another) ; or an engine brake (when the forces are derived from a controlled increase in the braking action of the engine transmitted to the wheels). 

1.7. "Different types of braking devices" 

"Different types of braking devices" means equipment which differs in such essential respects as: 1.7.1. components having different characteristics, 

1.7.2. a component made of materials having different characteristics or a component different in shape or size, 

1.7.3. a different assembly of the components. 



1.8. "Braking system component" 

"Braking system component" means one of the individual parts which, when assembled, constitute the braking device. 

1.9. "Continuous braking" 

"Continuous braking" means the braking of combinations of vehicles through an installation having the following characteristics: 1.9.1. a single control which the driver actuates progressively, by a single movement, from his driving seat, 

1.9.2. the energy used for braking the vehicles constituting the combination of vehicles is supplied from the same source (which may be the muscular energy of the driver), 

1.9.3. the braking installation ensures simultaneous or suitably phased braking of each of the constituent vehicles of the combination, whatever their relative positions. 



1.10. "Semi-continuous braking" 

"Semi-continuous braking" means the braking of combinations of vehicles through an installation having the following characteristics: 1.10.1. a single control which the driver can actuate progressively, by a single movement, from his driving seat, 

1.10.2. the energy used for braking the vehicles constituting the combination of vehicles is supplied from two different sources (one of which may be the muscular energy of the driver), 

1.10.3. the braking installation ensures simultaneous or suitably phased braking of each of the constituent vehicles of the combination, whatever their relative positions. 



1.11. "Automatic braking" 

"Automatic braking" means braking of the trailer or trailers occurring automatically in the event of separation of components of the combination of coupled vehicles, including such separation through coupling breakage, without the effectiveness of the remainder of the combination being affected. 

1.12. "Inertia or "overrun" braking" 

"Inertia braking" means braking by utilising the forces generated by the trailer's moving up on the drawing vehicle. 

1.13. "Laden vehicle" 

"Laden vehicle" means, except where otherwise stated, a vehicle laden to its "maximum weight". 

1.14. "Maximum weight" 

"Maximum weight" means the maximum weight stated by the vehicle manufacturer to be technically permissible (this weight may be higher than the "permissible maximum weight"). 



2. CONSTRUCTION AND FITTING REQUIREMENTS 2.1. General 2.1.1. Braking device 2.1.1.1. The braking device must be so designed, constructed and fitted as to enable the vehicle in normal use, despite the vibration to which it may be subjected, to comply with the undermentioned requirements. 

2.1.1.2. In particular, the braking device must be so designed, constructed and fitted as to be able to resist the corrosion and ageing phenomena to which it is exposed. 



2.1.2. Functions of the braking device 

The braking device defined in item 1.2 must fulfil the following conditions: 2.1.2.1. Service braking 

The service braking must enable the driver to control the movement of the vehicle and to halt it safely, speedily and effectively, whatever its speed and load, on any up or down gradient. It must be possible to graduate this braking action. The driver must be able to achieve this braking action from his driving seat without removing his hands from the steering control. 

2.1.2.2. Secondary braking 

The secondary braking must make it possible to halt the vehicle within a reasonable distance in the event of the failure of the service braking. It must be possible to graduate this braking action. The driver must be able to obtain this braking action from his driving seat while keeping at least one hand on the steering control. For the purposes of these requirements, it is assumed that not more than one failure of the service braking can occur at one time. 

2.1.2.3. Parking braking 

The parking braking must enable the vehicle to be held stationary on an up or down gradient even in the absence of the driver, the working parts being then held in the locked position by a purely mechanical device. The driver must be able to achieve this braking action from his driving seat, subject, in the case of a trailer, to the requirements of item 2.2.2.10. 





2.2. Characteristics of braking devices 2.2.1. Vehicles of categories M and N 2.2.1.1. The set of braking devices with which a vehicle is equipped must satisfy the requirements laid down for the service, secondary and parking brake 

2.2.1.2. The devices providing service, secondary and parking braking may have common components, provided that they fulfil the following conditions: 2.2.1.2.1. there must be at least two controls, independent of each other and readily accessible to the driver from the driving seat ; this requirement must be met even when the driver is wearing a safety belt; 

2.2.1.2.2. the control of the service braking device must be independent of the control of the parking braking device; 

2.2.1.2.3. where the service and secondary braking devices have the same control, the effectiveness of the linkage between that control and the various components of the transmission systems must not be liable to diminish after a certain period of use; 

2.2.1.2.4. where the service and secondary braking devices have the same control, the parking braking device must be so designed that it can be actuated when the vehicle is in motion; 

2.2.1.2.5. in the event of a breakage of any component other than the brakes (as defined in item 1.6) or the components specified in item 2.2.1.2.7, or of any other failure of the service braking device (malfunction, partial or total exhaustion of an energy reserve), the secondary braking device or that part of the service braking device which is not affected by the failure must be able to bring the vehicle to a halt in the conditions prescribed for secondary braking; 

2.2.1.2.6. in particular, where the secondary braking device and the service braking device have a common control and common transmission; 2.2.1.2.6.1. where the service braking is actuated by the muscular energy of the driver assisted by one or more energy reserves, the secondary braking must, in the event of failure of that assistance, be capable of being ensured by the muscular energy of the driver assisted by the energy reserves, if any, which are unaffected by the failure, the force applied to the control not exceeding the prescribed maxima; 

2.2.1.2.6.2. where the force for the service braking and transmission depend exclusively on the use of an energy reserve controlled by the driver, there must be at least two completely independent energy reserves, each provided with its own independent transmission ; each of them may act on the brakes of only two or more wheels so selected as to be capable of ensuring by themselves the prescribed degree of secondary braking without endangering the stability of the vehicle during braking ; in addition, each of these energy reserves must be fitted with a warning device as defined in item 2.2.1.13; 



2.2.1.2.7. for the purposes of item 2.2.1.2.5, certain parts, such as the pedal and its bearing, the master cylinder and its piston or pistons (hydraulic systems), the control valve (pneumatic systems), the linkage between the pedal and the master cylinder or the control valve, the brake cylinders and their pistons (hydraulic and/or pneumatic systems), and the lever-and-cam assemblies of brakes, shall not be regarded as liable to breakage if they are amply dimensioned, are readily accessible for maintenance, and exhibit safety features at least equal to those prescribed for other essential components (such as the steering linkage) of the vehicle. Where the failure of any such part would make it impossible to brake the vehicle with a performance at least equal to that prescribed for the secondary braking, that part must be made of metal or of a material with equivalent characteristics and must not be subject to significant distortion in the normal operation of the braking devices. 



2.2.1.3. Where there are separate controls for the service and secondary braking devices, simultaneous actuation of the two controls must not render both the service and secondary braking devices inoperative, either when both braking devices are in good working order or when one of them is faulty. 

2.2.1.4. In the event of failure in a part of the transmission of the service brake, the following conditions must be met: 2.2.1.4.1. a sufficient number of wheels must still be braked by actuation of the service braking device control, whatever the vehicle load; 

2.2.1.4.2. these wheels must be so selected that the residual performance of the service braking device is equal to not less than × % of the performance prescribed for the category to which the vehicle belongs, the force applied to the control not exceeding 70 kg: >PIC FILE= "T0038194"> 

2.2.1.4.3. however, the above requirements shall not apply to drawing vehicles for semi-trailers when the transmission of the service braking device of the semi-trailer is independent of that of the drawing vehicle. 



2.2.1.5. Where use is made of energy other than the muscular energy of the driver, there need not be more than one source of such other energy (hydraulic pump, air compressor, etc.), but the means by which the device constituting that source is driven must be completely reliable. In the event of failure in any part of the transmission of a vehicle's braking devices, the supply to the part not affected by the failure must continue to be ensured where this is required for the purpose of halting the vehicle with the degree of effectiveness prescribed for secondary braking. This condition must be met by means of devices which can be easily actuated when the vehicle is stationary, or by automatic means. 

2.2.1.6. The requirements of items 2.2.1.2, 2.2.1.4 and 2.2.1.5 must be met without the use of any automatic device of a kind such that its ineffectiveness might pass unnoticed because the parts which are normally in an "at rest" position are actuated only in the event of failure of the braking device. 

2.2.1.7. The service braking device must act on all the wheels on the vehicle. 

2.2.1.8. The action of the service braking device must be appropriately distributed among the axles. 

2.2.1.9. The action of the service braking device must be distributed between the wheels of the same axle symmetrically in relation to the longitudinal median plane of the vehicle. 

2.2.1.10. The service braking device and the parking braking device must act on braking surfaces permanently connected to the wheels through components of adequate strength. It must not be possible to disconnect a braking surface from the wheels ; however, in the case of the servicing device and secondary braking device, such disconnection of the braking surfaces shall be permitted provided that it is only momentary, for instance during a change of gear, and that both the service braking and the secondary braking continue to operate with the prescribed degree of effectiveness. In addition, any such disconnection shall be permitted in the case of the parking braking device, provided that it is controlled exclusively by the driver from his driving seat by a system which cannot be actuated by a leak1. 

2.2.1.11. Wear on the brakes must be easily compensated by means of a system of manual or automatic adjustment. In addition, the control and the components of the transmission and of the brakes must possess a reserve of travel such that, when the brakes become heated or when the brake linings have reached a certain degree of wear, effective braking is ensured without an immediate adjustment being necessary. 

2.2.1.12. In hydraulic braking devices: 2.2.1.12.1. the filling ports of the fluid reservoirs must be readily accessible ; in addition, the containers of reserve fluid must be so made that the level of the reserve fluid can be easily checked without the containers having to be opened. Where this last condition is not fulfilled, a warning light must indicate to the driver when the reserve fluid falls to a level liable to cause a failure of the braking device. The driver must be able to check easily whether the light is functioning properly; 

2.2.1.12.2. the failure of a part of the hydraulic transmission must be indicated to the driver by a device embodying a red warning signal which lights up as soon as the control is actuated. The light must be visible even in daylight, and the driver must be able to check easily whether the light is in order. Any failure of a component of the device must not cause total loss of effectiveness of the braking device. 



2.2.1.13. Every vehicle fitted with a brake actuated from an energy reservoir must, where the prescribed braking performance is impossible without the use of stored energy, be fitted with a warning device, in addition to a pressure gauge where fitted, giving an optical or acoustical signal when the energy, in any part of the installation preceding the control valve, falls to 65 % or less of its normal value. This device must be directly and permanently connected to the circuit. 

2.2.1.14. Without prejudice to the requirements of item 2.1.2.3, where the use of an auxiliary energy source is essential for the operation of a braking device, the energy reserve must be such as to ensure that, should the engine stop, the braking performance remains sufficient to bring the vehicle to a halt in the prescribed conditions. In addition, if the muscular energy applied by the driver to the parking braking device is reinforced by some aid, the actuation of the parking braking must be ensured in the event of failure of that aid, if necessary by using a reserve of energy independent of that normally supplying such aid. This reserve of energy may be that intended for the service braking. The expression "actuation" also covers the action of releasing. 1 This item must be interpreted in the following way : The performance of the service and secondary braking devices must remain within the limits prescribed in the Directive, even during momentary disconnection. 

2.2.1.15. In the case of a motor vehicle to which the coupling of a trailer equipped with a brake controlled by the driver of the drawing vehicle is authorised, the service braking device of the drawing vehicle must be fitted with a device so designed that if the trailer braking device should fail, or the air supply pipe (or such other type of connection as may be adopted) between the drawing vehicle and trailer should break, it will still be possible to brake the drawing vehicle with the effectiveness prescribed for the secondary braking ; it is accordingly prescribed, in particular, that this device be fitted to the drawing vehicle1. 

2.2.1.16. The auxiliary equipment must draw its energy only in such a way that its operation, even in the event of damage to the energy source, cannot cause the reserves of energy feeding the braking devices to fall below the level indicated in item 2.2.1.13. 

2.2.1.17. In the case of a braking device operated by compressed air, the pneumatic link with the trailer must be of the type with two or more pipes. 

2.2.1.18. Where the trailer belongs to category O3 or O4, the service braking device must be of a continuous or semi-continuous type. 

2.2.1.19. In the case of a vehicle authorised to draw a category O3 or O4 trailer, the braking devices must satisfy the following conditions: 2.2.1.19.1. when the secondary braking device of the drawing vehicle is actuated, there must also be a graduated braking action on the trailer; 

2.2.1.19.2. should the main braking device of the drawing vehicle fail, and if this device is made up of at least two independent sections, the section or sections not affected by this failure must be able partially or fully to actuate the trailer brakes. It must be possible to graduate this braking action; 

2.2.1.19.3. in the case of a break or leak in one of the air supply pipes (or in such other type of connection as may be adopted), it must nevertheless be possible for the driver to fully or partially actuate the trailer brakes, by means either of the service braking control or of the secondary braking control or of a separate control, unless the break or leak automatically causes the trailer to be braked. 



2.2.1.20. Except in the case of "urban buses", vehicles used for the carriage of passengers comprising more than eight seats in addition to the driver's seat, and having a maximum weight exceeding 10 metric tons, must satisfy the Type II A test described in item 1.5 of Annex II and not the Type II test described in item 1.4 of that Annex. 



2.2.2. Vehicles of category O 2.2.2.1. Trailers of category O1 need not be fitted with a service braking device ; however, if trailers of this category are equipped with a service braking device this must comply with the same requirements as those of category O2. 

2.2.2.2. Every trailer of category O2 must be fitted with a service braking device either of the continuous or semi-continuous type or of the inertia (overrun) type. The latter type shall be authorised only for trailers other than semi-trailers. 

2.2.2.3. Every trailer of category O3 or O4 must be fitted with a service braking device of the continuous or semi-continuous type. 

2.2.2.4. The service braking device must act on all the wheels of the trailer. 

2.2.2.5. The action of the service braking device must be suitably distributed among the axles. 

2.2.2.6. The action of every braking device must be distributed between the wheels of each axle symmetrically in relation to the longitudinal median plane of the vehicle. 

2.2.2.7. The braking surfaces required to attain the prescribed degree of effectiveness must be in constant contact with the wheels, either rigidly or through components not liable to failure. 1 This point is to be interpreted in the following way : It is essential, in all cases, that the service braking device should be fitted with a device (for instance a limiting valve) ensuring that the vehicle can still be braked by the service brake, but with a performance equal to that of the secondary brake. 

2.2.2.8. Wear on the brakes must be easily compensated by a system of manual or automatic adjustment. In addition, the control and the components of the transmission and of the brakes must possess a reserve of travel such that, when the brakes become heated or when the brake linings have reached a certain degree of wear, braking is ensured without immediate adjustment being necessary. 

2.2.2.9. The braking devices must be such that the trailer is stopped automatically if the coupling breaks while the trailer is in motion. However, this requirement shall not apply to single-axled trailers with a maximum weight not exceeding 1 75 metric tons provided that the trailers are fitted, in addition to the main coupling, with a secondary coupling (chain, cable, etc.) which, in the event of breakage of the main coupling, can stop the drawbar from touching the ground and provide some residual steering action on the trailer. 

2.2.2.10. On every trailer which is required to be fitted with a service braking device, parking braking must be ensured even when the trailer is separated from the drawing vehicle. It must be possible for a person standing on the ground to actuate the parking braking device ; however, in the case of a trailer used for the carriage of passengers, it must be possible to actuate this brake from inside the trailer. The expression "actuate" also covers the action of releasing. 

2.2.2.11. Where a trailer is fitted with a device enabling compressed-air actuation of the braking device to be cut out, the first-mentioned device must be so designed and constructed that it is positively restored to the "at rest" position not later than on the resumption of the supply of compressed air to the trailer. 









ANNEX II BRAKING TESTS AND PERFORMANCE OF BRAKING DEVICES 

1. BRAKING TESTS 1.1. General 1.1.1. The performance prescribed for braking devices shall be based on the stopping distance. The performance of a braking device shall be determined either by measuring the stopping distance in relation to the initial speed or by measuring the reaction time of the device and the mean deceleration in normal operation as prescribed in Annex III. 

1.1.2. The stopping distance shall be the distance covered by the vehicle from the moment when the driver begins to actuate the control of the device until the moment when the vehicle stops ; the initial speed shall be the speed at the moment when the driver begins to actuate the control of the device. In the formulae given below, for the measurement of braking performance, 

v = initial speed in km/h 

s = stopping distance in metres. 

1.1.3. For the type approval of any vehicle, the braking performance shall be measured during road tests conducted in the following conditions: 1.1.3.1. the vehicle's condition as regards weight must be as prescribed for each type of test and be specified in the test report; 

1.1.3.2. the test must be carried out at the speeds prescribed for each type of test. Where a vehicle is so constructed that its maximum speed is lower than that prescribed for a test, the test must be performed at the maximum speed of the vehicle; 

1.1.3.3. during the tests the force applied to the brake control in order to obtain the prescribed performance must not exceed the maximum laid down for the test vehicle's category; 

1.1.3.4. the road must have a surface affording good adhesion; 

1.1.3.5. the tests must be performed when there is no wind liable to affect the results; 

1.1.3.6. at the start of the tests the tyres must be cold and at the pressure prescribed for the load actually borne by the wheels when the vehicle is stationary; 

1.1.3.7. the prescribed performance must be obtained without locking of the wheels, without deviation of the vehicle from its course, and without abnormal vibration. 



1.1.4. Behaviour of the vehicle during braking 1.1.4.1. In braking tests, and in particular in those at high speed, the general behaviour of the vehicle during braking must be checked. 





1.2. Type O test (ordinary performance test with brakes cold) 1.2.1. General 1.2.1.1. The brakes must be cold. A brake is deemed to be cold when the temperature measured on the disc or on the outside of the drum is below 100 °C. 

1.2.1.2. The test must be conducted in the following conditions: 1.2.1.2.1. the vehicle must be laden, the distribution of its weight among the axles being that stated by the maker. Where provision is made for several arrangements of the load on the axles the distribution of the maximum weight among the axles must be such that the load on each axle is proportional to the maximum permissible load for each axle; 

1.2.1.2.2. in the case of a motor vehicle, every test must be repeated on the unladen vehicle carrying only the driver and possibly one person - preferably sitting on the front seat - responsible for noting the results of the test; 

1.2.1.2.3. the limits prescribed for minimum performance, both for tests with the vehicle unladen and for tests with the vehicle laden, shall be those laid down hereunder for each category of vehicle; 

1.2.1.2.4. the road must be level. 





1.2.2. Type O test with engine disconnected 1.2.2.1. The test must be carried out at the speed prescribed for the category to which the vehicle belongs, the figures prescribed in this connection being subject to a certain margin of tolerance. The minimum performance prescribed for each category must be attained. 



1.2.3. Type O test with engine connected 1.2.3.1. Apart from the tests prescribed in item 1.2.2, additional tests shall be carried out at various speeds with the engine connected, the lowest being equal to 30 % of the maximum speed of the vehicle and the highest being equal to 80 % of that speed. The performance figures measured and the behaviour of the vehicle shall be recorded in the test report. 





1.3. Type I test (fade test) 1.3.1. With repeated braking 1.3.1.1. The service brakes of vehicles in categories M1, M2, M3, N1, N2 and N3 shall be tested by successively applying and releasing the brakes a number of times, the vehicle being laden, in accordance with the conditions shown in the following table: >PIC FILE= "T0038195"> 

1.3.1.2. >PIC FILE= "T0038196"> 

1.3.1.3. In these tests, the force applied to the control must be so adjusted as to attain a mean deceleration of 3 m/sec2 at the first application of the brakes. This force must remain constant throughout the succeeding brake applications. 

1.3.1.4. During brake applications the highest gear ratio (excluding overdrive, etc.) must be continuously engaged. 

1.3.1.5. For regaining speed after braking, the gearbox must be used in such a way as to attain the speed v1 in the shortest possible time (maximum acceleration allowed by the engine and gearbox). 



1.3.2. With continuous braking 1.3.2.1. The service brakes of trailers of categories O3 and O4 shall be tested in such a manner that, the vehicle being laden, the energy input to the brakes is equivalent to that recorded in the same period of time with a laden vehicle driven at a steady speed of 40 km/h on a 7 % down gradient for a distance of 1 77 km. 

1.3.2.2. The test may be carried out on a level road, the trailer being drawn by a motor vehicle ; during the test, the force applied to the control must be adjusted so as to keep the resistance of the trailer constant (7 % of the weight of the trailer). If the power available for hauling is insufficient, the test can be conducted at a lower speed but over a greater distance, as shown in the following table: >PIC FILE= "T0038197"> 



1.3.3. Residual performance 1.3.3.1. At the end of the Type I test (test described in item 1.3.1. or test described in item 1.3.2 of this Annex) the residual performance of the service braking device shall be measured under the same conditions as for the Type O test with the engine disconnected (the temperature conditions may be different) ; this residual performance must not be less than 80 % of that prescribed for the category in question nor less than 60 % of the figure recorded in the Type O test with the engine disconnected. 





1.4. Type II test (downhill behaviour test) 1.4.1. Laden vehicles shall be tested in such a manner that the energy input is equivalent to that recorded in the same period of time with a laden vehicle driven at an average speed of 30 km/h on a 6 % down gradient for a distance of 6 km, with the appropriate gear engaged (if the vehicle is a motor vehicle) and the retarder, if the vehicle is fitted with one, being used. The gear engaged must be such that the rpm of the engine does not exceed the maximum value prescribed by the manufacturer. 

1.4.2. For vehicles in which the energy is absorbed by the braking action of the engine alone, a tolerance of ± 5 km/h on the average speed shall be permitted, and the gear enabling the speed to be stabilised at the value closest to 30 km/h on the 6 % down gradient shall be engaged. If the performance of the braking action of the engine alone is determined by a measurement of deceleration, it shall be sufficient if the mean deceleration measured is at least 0 75 m/sec2. 

1.4.3. At the end of the test, the residual performance of the service braking device shall be measured in the same conditions as for the Type O test with the engine disconnected (the temperature conditions, of course, are different) ; this residual performance must not be less than 75 % of that prescribed for the Type O test with the engine disconnected. 



1.5. Type IIA test (test for vehicles, other than "urban buses", used for the carriage of passengers comprising more than eight seats in addition to the driver's seat and having a maximum weight exceeding 10 metric tons) 1.5.1. Laden vehicles shall be tested in such a manner that the energy input is equivalent to that recorded in the same period of time with a laden vehicle driven at an average speed of 30 km/h on a 7 % down gradient for a distance of 6 km. During the test, the service, secondary and parking braking devices must not be engaged. The gear engaged must be such that the rpm of the engine does not exceed the maximum value prescribed by the manufacturer. 

1.5.2. For vehicles in which the energy is absorbed by the braking action of the engine alone, a tolerance of ± 5 km/h on the average speed shall be permitted and the gear enabling the speed to be stabilised at the value closest to 30 km/h on a 7 % down gradient shall be engaged. If the performance of the braking action of the engine alone is determined by a measurement of deceleration, it shall be sufficient if the mean deceleration measured is at least 0 76 m/sec2. 





2. PERFORMANCE OF BRAKING DEVICES 2.1. Vehicles of categories M and N 2.1.1. Service braking devices 2.1.1.1. Provisions relating to tests 2.1.1.1.1. The service brakes of vehicles of categories M1, M2, M3, N1, N2 and N3 shall be tested under the conditions shown in the following table: >PIC FILE= "T0038198"> 





2.1.2. Secondary braking devices 2.1.2.1. The secondary braking, even if the device which actuates it is also used for other braking functions, must give a stopping distance not exceeding the first term plus twice the second term of the binomial expression giving the service-braking stopping distance for the category in question. 

2.1.2.2. If the secondary braking control is a manual control, the prescribed performance must be obtained by applying to the control a force not exceeding 40 kgf in the case of category M1 vehicles and 60 kgf in the case of other vehicles, and the control must be so placed that it can be easily and quickly grasped by the driver. 

2.1.2.3. If the secondary braking control is a foot control, the prescribed performance must be obtained by applying to the control a force not exceeding 50 kgf in the case of category M1 vehicles and 70 kgf in the case of other vehicles, and the control must be so placed that it can be easily and quickly actuated by the driver. 

2.1.2.4. The performance of the secondary braking device shall be checked by the Type O test. 



2.1.3. Parking braking devices 2.1.3.1. The parking braking device must, even if it is combined with one of the other braking devices, be capable of holding a laden vehicle stationary on an 18 % up or down gradient. 

2.1.3.2. On vehicles to which the coupling of a trailer is authorised, the parking braking device of the drawing vehicle must be capable of holding the combination of vehicles stationary on a 12 % gradient. 

2.1.3.3. If the control is a manual control, the force applied to it must not exceed 40 kgf in the case of category M1 vehicles and 60 kgf in the case of all other vehicles. 

2.1.3.4. If it is a foot control, the force exerted on the control must not exceed 50 kgf in the case of category M1 vehicles and 70 kgf in the case of all other vehicles. 

2.1.3.5. A parking braking device which has to be actuated several times before attaining the prescribed performance is admissible. 





2.2. Vehicles of category O 2.2.1. Service braking devices 2.2.1.1. Requirement relating to tests of category O1 vehicles. 2.2.1.1.1. Where the provision of a service braking device is mandatory, the performance of the device must meet the requirements laid down for category O2. 



2.2.1.2. Requirements relating to tests of category O2 vehicles. 2.2.1.2.1. Where the service braking device of the trailer is of the continuous or semi-continuous type, the sum of the forces exerted at the periphery of the braked wheels must be equal to not less than 45 % of the maximum weight borne by the wheels when the vehicle is stationary. Where the trailer is fitted with a compressed air brake, the check must be made with a pressure not exceeding 6 75 bars in the brake cylinders1. 

2.2.1.2.2. Where the braking device is of the inertia type, it must comply with the conditions laid down in Annex VIII. 

2.2.1.2.3. In addition, these vehicles must be subjected to the Type I test. 

2.2.1.2.4. In the Type I test of a semi-trailer, the weight braked by its axles must be that corresponding to the load on the axle or axles of the semi-trailer when the latter is carrying its maximum load. 



2.2.1.3. Requirements relating to tests of category O3 vehicles. 

The same requirements apply as apply to category O2 ; in addition, these vehicles must undergo the Type I test. 

2.2.1.4. Requirements relating to tests of category O4 vehicles. 2.2.1.4.1. The same requirements apply as apply to category O2 ; in addition, these vehicles must be subjected to the Type I and Type II tests. 

2.2.1.4.2. In the Type I and Type II tests of a semi-trailer, the weight braked by its axles must be that corresponding to the load on the axle or axles of the semi-trailer when the latter is carrying its maximum load. 





2.2.2. Parking braking devices 2.2.2.1. The parking brake with which the trailer or semi-trailer is fitted must be capable of holding the laden trailer or semi-trailer stationary, when separated from the drawing vehicle, on an 18 % up or down gradient. The force applied to the control must not exceed 60 kgf. 





2.3. Reaction time 

Where a vehicle is fitted with a service braking device which is totally or partially dependent on a source of energy other than the muscular effort of the driver, the following requirements must be satisfied: 1 The pressures specified here and in the following Annexes are relative pressures measured in bars. 2.3.1. in an emergency manoeuvre, the time elapsing between the moment when the control begins to be actuated and the moment when the braking force on the least favourably placed axle reaches the level corresponding to the prescribed performance must not exceed 0 76 seconds; 

2.3.2. the requirements of Annex III shall apply to compressed air devices with double pipes. 







ANNEX III METHOD OF MEASURING THE REACTION TIME FOR VEHICLES FITTED WITH COMPRESSED AIR BRAKING DEVICES WITH DOUBLE PIPES 

1. GENERAL REQUIREMENTS 1.1. The reaction time for the braking device shall be determined with the vehicle stationary, the pressure being measured at the opening of the least efficient brake cylinder. 

1.2. During the tests, the stroke of the brake cylinders of the individual axles must be that corresponding to the most closely adjusted brakes. 

1.3. The following tests shall apply to standard road trains for which the maximum pressure in the feed pipe varies between 6 75 and 8 70 bars and the maximum pressure in the control pipe is between 6 70 and 7 75 bars. 

1.4. Pressures differing from those specified in item 1 73 may be used for components designed for other pressure maxima levels at the coupling heads. In such cases, this must be noted in the test report ; a plate indicating clearly the operating pressure maxima and minima must be fixed to the vehicle. 



2. MOTOR VEHICLES 2.1. At the start of each test, the pressure in the reservoirs must be equal to the minimum pressure at which the governor starts feeding the installation again. In installations not fitted with a governor (e.g. pressure limited compressor) the pressure in the reservoir at the start of each test must be equal to 90 % of the pressure stated by the manufacturer, as defined in item 1.2.2.1 of Annex IV, to be used for tests prescribed in this Annex. 

2.2. Reaction times in terms of actuation time (tf) shall be obtained by a series of actuations to the fullest extent, starting from the shortest possible up to a time of about 0 74 seconds. The values measured must be given on a diagram. 

2.3. Reaction times corresponding to an actuation time of 0 72 seconds shall be determinant for the test. This reaction time can be obtained from the diagram by interpolation. 

2.4. In the case of the actuation time of 0 72 seconds, the time elapsing between the beginning of actuation of the control pedal and the moment when the pressure in the brake cylinder reaches 75 % of its asymptotic value must not exceed 0 76 seconds. 

The value thus noted may be rounded to the nearest tenth of a second. 

2.5. In the case of motor vehicles having a brake coupling for trailers, it is advisable, as an exception to the requirements of item 1.1, not to measure the reaction time at the braking cylinder, but at the extremity of a pipe with a length of about 2 75 metres and an internal diameter of 13 mm which shall be joined to the brake coupling (coupling head) of the motor vehicle. 

2.6. The time which elapses between the start of the activation of the control pedal and the moment when the pressure measured at the coupling head of the control pipe reaches × % of its asymptotic value must not exceed the values listed in the table below: >PIC FILE= "T0038199"> 



3. TRAILERS (including semi-trailers) 3.1. The reaction times for trailers shall be measured without a drawing vehicle. To simulate the drawing vehicle it is necessary to provide a simulator to which the coupling heads of the control pipe and of the feed pipe of the trailer are to be connected. 

3.2. The pressure in the feed pipe must be 6 75 bars. The pressure in the reservoir or reservoirs of the trailer must be that corresponding to a pressure of 6 75 bars in the feed pipe. 

3.3. The simulator must have the following features: 3.3.1. it must have a thirty litre reservoir filled to a pressure of 6 75 bars; 

3.3.2. it must be adjusted in such a way that if a tube with a length of 2 75 metres and an internal diameter of 13 mm is joined to it, the time taken for the pressure to increase from 10 % to 75 %, i.e. from 0 765 bars to 4 79 bars, would be 0 72 seconds. Between these two values, the pressure must increase in an approximately linear way. The sketch in the Appendix to this Annex gives an example of the correct use of the simulator. 



3.4. The time elapsing between the moment when the pressure produced in the control pipe by the simulator reached 10 % of the asymptotic pressure and the moment when the pressure in the brake cylinder of the trailer reaches 75 % of its asymptotic value must not exceed 0 74 seconds. 





>PIC FILE= "T0038200"> 


ANNEX IV ENERGY RESERVOIRS AND SOURCES OF ENERGY FOR COMPRESSED AIR BRAKES 

1. CAPACITY OF RESERVOIRS 1.1. General requirements 1.1.1. Vehicles on which the operation of the braking devices depends on the use of compressed air must be fitted with reservoirs of a capacity meeting the requirements of items 1.2 and 1.3 below. 

1.1.2. Nevertheless, the capacity of reservoirs shall not be laid down where the braking system is such that in the absence of any energy reserve it is possible to achieve a braking performance at least equal to that prescribed for the secondary braking. 

1.1.3. When verifying compliance with the requirements of items 1.2 and 1.3 the brakes must be adjusted as closely as possible. 



1.2. Motor vehicles 1.2.1. The reservoirs of brakes of motor vehicles must be such that after eight full-stroke actuations of the service braking control it is still possible to achieve the performance prescribed for secondary braking. 

1.2.2. During the test, the following requirements are to be satisfied: 1.2.2.1. The initial pressure in the reservoirs must be that indicated by the manufacturer. This pressure must be such as to enable the prescribed performance for the service braking to be achieved; 

1.2.2.2. The reservoir or reservoirs must not be replenished ; in addition, the reservoir or reservoirs of auxiliary equipment must be isolated; 

1.2.2.3. In the case of motor vehicles to which the coupling of a trailer or semi-trailer is authorised, the feed line must be blocked off and a reservoir of 0 75 litre capacity must be connected to the control line. The pressure in this reservoir must be exhausted before each actuation of the brakes. After the test referred to in item 1.2.1 the pressure in the control line must not be less than one half of the pressure obtained at the first brake application. 





1.3. Trailers (including semi-trailers) 1.3.1. Reservoirs fitted to trailers must be such that after eight full-stroke actuations of the drawing vehicle's service braking device, the pressure supplied to the operating parts using it is not less than one half of the pressure obtained at the first brake application. 

1.3.2. During the test, the following requirements are to be satisfied: 1.3.2.1. The pressure in the reservoirs at the beginning of the test must be equal to the maximum specified by the manufacturers; 

1.3.2.2. The feed line must be blocked off ; in addition, the auxiliary equipment reservoirs must be isolated; 

1.3.2.3. There must be no significant replenishment of the reservoir during the test; 

1.3.2.4. For each application of the brakes, the pressure in the control pipe must correspond to the maximum specified by the manufacturer. 







2. CAPACITY OF ENERGY SOURCES 2.1. General provisions 

Compressors must satisfy the requirements laid down in the following items: 

2.2. Definitions 2.2.1. P1 is the pressure corresponding to 65 % of the pressure p2 defined in item 2.2.2 

2.2.2. p2 is the value specified by the manufacturer and referred to in item 1.2.2.1 

2.2.3. T1 is the time required for the relative pressure to rise from O to p1 ; T2 is the time required for the relative pressure to rise from O to p2. 



2.3. Conditions of measurement 2.3.1. In all cases the rpm speed of the compressor shall be that obtained when the engine is running at the speed corresponding to its maximum power or at the speed allowed by the control valve. 

2.3.2. The auxiliary equipment reservoirs shall be isolated during the tests for determining the periods T1 and T2. 

2.3.3. On motor vehicles constructed to draw trailers, the trailer shall be represented by a reservoir whose maximum relative pressure p (expressed in bars) is that which can be supplied through the feed circuit of the drawing vehicle and whose volume V (expressed in litres) is given by the formula p 7 V = 20 R (R being the permissible maximum load, expressed in metric tons, on the axles of the trailer or semi-trailer). 



2.4. Interpretation of results 2.4.1. The time T1 for the least efficient reservoir must not exceed: - three minutes in the case of vehicles to which the coupling of a trailer or semi-trailer is not authorised; 

- six minutes in the case of vehicles to which the coupling of a trailer or semi-trailer is authorised. 



2.4.2. The time T2 for the least efficient reservoir must not exceed: - six minutes in the case of vehicles to which the coupling of a trailer or semi-trailer is not authorised; 

- nine minutes in the case of vehicles to which the coupling of a trailer or semi-trailer is authorised. 





2.5. Additional test 2.5.1. When the vehicle is equipped with an auxiliary equipment reservoir or reservoirs with a total capacity exceeding 20 % of the total capacity of the brake reservoirs, an additional test must be carried out during the course of which there must be no interference with the functioning of the valves controlling the filling of the auxiliary equipment reservoir(s). A check must be made during the course of this test that the period T3 required to bring about a rise in the pressure in the brake reservoirs from O to p2 is less than: - eight minutes in the case of vehicles to which the coupling of a trailer or semi-trailer is not authorised; 

- eleven minutes in the case of vehicles to which the coupling of a trailer or semi-trailer is authorised. 









ANNEX V SPRING BRAKES 

1. DEFINITION 

"Spring brakes" are braking devices for which the energy required for braking is supplied by one or more springs acting as an energy accumulator. 

2. GENERAL REQUIREMENTS 2.1. A spring brake shall not be used as a service brake. 

2.2. A small variation in any of the pressure limits which may occur in the brake compression chamber feed circuit must not cause a significant variation in the braking force. 

2.3. The feed circuit to the spring compression chamber must include an energy reserve which does not supply any other device or equipment. This provision shall not apply if the springs can be maintained in the compressed state by using two or more independent systems. 

2.4. The device must be so designed that it is possible to apply and release the brakes at least three times starting with an initial pressure in the spring compression chamber equal to the maximum design pressure. This requirement must be met when the brakes are adjusted as closely as possible. 

2.5. The pressure in the compression chamber beyond which the springs begin to actuate the brakes, the latter being adjusted as closely as possible, must not be greater than 80 % of the minimum level (pm) of the normal available pressure. 

2.6. When the pressure in the compression chamber falls to the level at which the brake parts begin to move, an optical or audible warning device must be actuated. Provided this requirement is met, the warning device may be that specified in item 2.2.1.13 of Annex I. 

2.7. On motor vehicles fitted with spring brakes and authorised to draw trailers with continuous or semi-continuous brakes, automatic application of the spring brakes must cause the trailer brakes to be applied. 



3. RELEASE SYSTEM 3.1. Spring brakes must be so designed that, in the event of failure, it is possible to release them without using their normal control. This may be achieved by the use of an auxiliary device (pneumatic, mechanical, etc.). 

3.2. If the operation of the auxiliary device referred to in item 3.1 requires the use of a tool or spanner, the tool or spanner must be kept on the vehicle. 





ANNEX VI PARKING BRAKING BY MECHANICAL LOCKING OF THE BRAKE CYLINDERS (lock actuators) 

1. DEFINITION 

"Mechanical locking of the brake cylinders" means a device for ensuring parking braking by mechanical wedging of the brake piston rod. 

Mechanical locking occurs when the locking chamber is emptied of compressed air ; the mechanical locking device shall be designed in such a way that it can be released when the locking chamber is again subjected to pressure. 

2. SPECIAL PROVISIONS 2.1. When the pressure in the locking chamber approaches the level corresponding to mechanical locking, an optical or audible warning system must be actuated. 

2.2. In the case of brake actuators fitted with a mechanical locking device, the brake actuator must be capable of being actuated by either of two energy reserves. 

2.3. The locked brake cylinder may only be released if it is certain that the brake can be operated again after such release. 

2.4. In the event of a failure of the source of energy supplying the locking chamber, an auxiliary unlocking device (mechanical or pneumatic, for instance) using, for example, the air in one of the tyres of the vehicle, must be provided. 





ANNEX VII CASES IN WHICH TYPE I AND/OR II (OR II A) TESTS DO NOT HAVE TO BE CARRIED OUT ON A VEHICLE SUBMITTED FOR TYPE APPROVAL 

1. Type I and/or II (or II A) tests do not have to be carried out on a vehicle submitted for type approval in the following three cases: 1.1. where the vehicle in question is a motor vehicle, a trailer or a semi-trailer which, in respect of tyres, braking energy absorbed by each axle and method of fitting of tyres and brakes, is identical, as far as braking is concerned, to a motor vehicle, a trailer, or a semi-trailer which: 1.1.1. has passed a Type I and/or II (or II A) test; 

1.1.2. has been type approved, with regard to braking energy absorbed, for axle weights greater than or equal to those of the vehicle submitted for type approval. 



1.2. where the vehicle in question is a motor vehicle, a trailer or a semi-trailer of which the axle or axles, in respect of tyres, braking energy absorbed by each axle and method of fitting of tyres and brakes, is or are identical, as far as braking is concerned, to an axle or axles which has or have individually passed a Type I and/or II test for axle weights greater than or equal to those of the vehicle submitted for type approval, provided that the braking energy absorbed by each axle does not exceed the energy absorbed by that axle during the reference test or tests carried out separately on that axle. 

1.3. where the vehicle submitted for type approval is fitted with a retarder, other than an engine brake, identical to a retarder which has already been tested under the following conditions: 1.3.1. in a test carried out on a gradient of at least 6 % (Type II test) or of at least 7 % (Type II A test), this retarder has, on its own, stabilised the speed of a vehicle with a maximum weight at the time of testing at least equal to the maximum weight of the vehicle submitted for type approval; 

1.3.2. in the above test, a check must be made as to whether the speed of rotation of the revolving parts of the retarder is such that, when the vehicle submitted for type approval is travelling at a speed of 30 km/h, the retarding torque is at least equal to the retarding torque in the test mentioned in item 1.3.1. 





2. The term "identical" as used in items 1.1, 1.2 and 1.3 means identical as regards the geometrical and mechanical characteristics of the vehicle parts mentioned in those items, and also as regards the characteristics of the materials from which these parts are made. 

3. When advantage is taken of the above provisions, the type approval communication in respect of braking (Annex IX) must contain the following particulars: 3.1. where item 1.1 is applicable, the type of the approval number of the vehicle on which the Type I and/or II (or II A) test serving as a reference test has been carried out (item 14.7.1 of Annex IX); 

3.2. where item 1.2 is applicable, the table in item 14.7.2 of the model item of the communication in Annex IV must be completed; 

3.3. where item 1.3 is applicable, the table in item 14.7.3 of the model of the communication in Annex IX must be completed. 



4. When a person applying for type approval in a Member State refers to a type approval granted in another Member State, that person must produce the documents relating to such approval. 



ANNEX VIII CONDITIONS GOVERNING THE TESTING OF VEHICLES EQUIPPED WITH INERTIA (OVERRUN) BRAKES 

1. GENERAL PROVISIONS 1.1. The inertia (overrun) braking device of a trailer comprises the control device, the transmission and the brakes proper, hereinafter called "brakes". 

1.2. The control device is the combination of components comprising the coupling head. 

1.3. The transmission is the combination of components comprised between the coupling head and the first part of the brake. 

1.4. The "brake" is the part in which the forces opposing the movement of the vehicle develop. The first part of the brake is either the lever actuating the brake cam or similar parts (mechanical-transmission inertia brake) or the brake cylinder (hydraulic-transmission inertia brake). 

1.5. Braking devices in which accumulated energy (for instance, electric, pneumatic or hydraulic) is transmitted to the trailer by the drawing vehicle and is only controlled by the force at the coupling shall not be deemed to be inertia braking devices within the meaning of this Directive. 

1.6. Two axles with a wheelbase of less than one metre (tandem axle) shall, for the purposes of this Annex, also be deemed to be one axle. 

1.7. Tests 1.7.1. Determination of the main characteristics of the brake. 

1.7.2. Determination of the main characteristics of the control device and testing as to whether that device conforms with the provisions of this Directive. 

1.7.3. Testing on the vehicle - the compatibility of the control device and the brake 

- the transmission. 







2. SYMBOLS AND DEFINITIONS 2.1. Units used >PIC FILE= "T0038201"> 

2.2. Symbols valid for all types of brakes (see diagram in Appendix 1, p. 771) 2.2.1. GA : "total weight" of the trailer declared to be technically permissible by the manufacturer; 

2.2.2. G'A : "total weight" of the trailer which, according to the manufacturer's declaration, can be braked by the control device; 

2.2.3. GB : "total weight" of the trailer which can be braked by the joint operation of all the trailer brakes 

GB = n 7 GBo 

2.2.4. GBo : Fraction of the permissible "total weight" which, according to the manufacturer's declaration, can be braked by one brake; 

2.2.5. B* : braking force required; 

2.2.6. B : required braking force taking account of rolling resistance; 

2.2.7. D* : permitted thrust on coupling; 

2.2.8. D : load on the coupling; 

2.2.9. P' : control device output force; 

2.2.10. K : supplementary force of control device by convention ; this is defined as the force D corresponding to the point of intersection of the × axes of the extrapolated curve expressing P'in terms of D, measured with the control system in the mid-travel position (see graph in Appendix 1, p. 772); 

2.2.11. KA : threshold force of control device-this is the maximum force on the coupling head which can be applied for a short period of time without producing any output force on the control device. By convention, KA is defined as the force measured when force begins to be exerted on the coupling head at a speed of from 10 to 15 mm/s, the control device transmission being uncoupled; 

2.2.12. D1 : this is the maximum force applied to the coupling head when it is forced rearward at a speed of s mm/s ± 10 %, the transmission being uncoupled; 

2.2.13. D2 : this is the maximum force applied to the coupling head when this is pulled forward at a speed of s mm/s ± 10 % from its rearmost position, the transmission being uncoupled; 

2.2.14. >PIC FILE= "T0038202"> 

2.2.15. >PIC FILE= "T0038203"> 

2.2.16. >PIC FILE= "T0038204"> 

2.2.17. s : travel of control (expressed in millimetres); 

2.2.18. s' : effective travel of control (expressed in millimetres) fixed in accordance with the requirements of item 9.4.1; 

2.2.1


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## gaspode (May 9, 2005)

OK Keith, I think that's plenty to read through for now. Thread will now be locked. At this rate Nuke will need to buy some more drives for storage! Please don't start a new thread on the same subject unless there is something *NEW* to add.


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