On 20 May 2018, the DVSA implemented changes to the MOT test and MOT testing manual for England, Scotland and Wales. There are different rules for Northern Ireland (https://is.gd/elebun).
The changes were made to comply with EU Directive 2014/45, more commonly known as the EU Roadworthiness Directive. In its guidance, DVSA clarifies that while the UK has decided to leave the EU; as it was still a member on 20 May, non-compliance with the directive would have led to ‘ongoing substantial fines and the fact that UK vehicles would not have been allowed to enter other EU countries’.
The changes affect all classes of vehicle (except motorcycles) and have brought new types into the scope of the test, including mobile cranes and mobile concrete batching plant. All specialised heavy vehicles constructed on or adapted from HGV chassis are now required to be tested. The operators and hirers of plant typically operate vehicle types from passenger cars, pick-ups and light vans, through to heavy trucks and low-loaders under Special Types General Order (STGO). In rural areas, agricultural tractors are becoming more popular to move plant between jobs. The Directive says: “Wheeled tractors with a maximum design speed exceeding 40 km/h are increasingly used to replace trucks in local transport activities and for commercial road haulage purposes. Their risk potential is comparable to that of trucks, and vehicles in that category, which are used mainly on public roads, should therefore be subject to roadworthiness testing.”
The 2014/45 directive
So why has the EU introduced the 2014/45 directive? One aspect of it is new roadside check standards aimed at enforcing continued roadworthiness. With an increasing reliance on technology, vehicles with malfunctioning technical systems may contribute to road crashes involving injuries or fatalities. It says that impact could be reduced if adequate improvements to the roadworthiness testing system are put in place. The drive to reduce vehicle emissions that are harmful to health has led the EU to place a much greater emphasis on a testing regime that addresses vehicles with malfunctioning emission control systems. And it and wants to clamp down on vehicle types previously not in scope.
DVSA believes that plating of vehicle weight is of benefit in the testing and enforcement process, particularly where the vehicle’s operating weight changes substantially during use. The vehicles being tested are now required to be plated, although some may be exempted on DVSA’s discretion if too difficult.
In what might be a relief to construction plant operators, heavy vehicles plated under STGO remain exempt from the MOT test. In addition, DVSA has removed some defects that previously resulted in failure (box, right).
The basic essence of the MOT is the same as before. There are some significant changes to its content (see box, below right). New defect categories have been introduced: ‘dangerous, major and minor’. For minor defects the vehicle won’t fail, but advisories will be issued. The MOT documentation has changed to reflect the new defect categories (see also https://is.gd/jekuce). If the vehicle passes with minor defects and advisories, they will show up on the certificate. This could have implications if the vehicle is subsequently stopped, or involved in a collision and the defects have not been rectified.
Industry impact
The Road Haulage Association has numerous plant hire firms in membership. Head of technical services, Malcolm Dodds (inset), reviews its impact on industry. He says: “Including any commercial vehicle based on an HGV chassis into scope – such as asphalt boxes and telegraph pole vehicles – has created problems for their operators. These were classed as plant, but because of their chassis they are now subject to test. The knock-on effect is there are around 30,000 more vehicles operating in the UK that must be tested. This is already putting additional strain on the authorised testing facilities [ATFs], which were already at full capacity.” (To cope with demand, DVSA is allowing extra time to test previously out-of-scope vehicles, up to the date of their annual inspection since May, or May 2019, whichever comes first).
Dodds also mentions revisions in the pipeline to the Guide to Maintaining Roadworthiness and Categorisation of Defects, bringing in scope tighter rules on the fitting of tyres over 10 years old.
He expands on the DVSA resourcing issues: “To manage the additional workload, in some areas DVSA is moving examiners between regions to cover requirements. There is a lack of examiners in the south and south-east, and DVSA has moved people down from Scotland and the northeast to cover the shortfalls in ATFs. They have had a recent recruiting drive for examiners, but it will be several months before they are trained and deployed.”
And there are issues with the new defect categories, Dodds adds. “The increased focus on emissions and emissions control equipment has caused the most problems. Vehicles are failing where they had passed before. And reversing light failures have posed issues.
“With the new defect categories, there are many additional ones, classed as ‘dangerous’. If the vehicle fails with one of these, an immediate prohibition will be issued. This means the vehicle must be re-inspected to get the prohibition removed. Members report they are having trouble getting an ATF slot to do this, and vehicles are being put off the road for weeks. Most ATFs require at least 30 days’ notice. To avoid problems, operators must ensure their maintenance is spot-on and drivers are doing their daily defect checks and these are rectified before the vehicle leaves the yard,” explains Dodds.
“Also, operators need to closely monitor their maintenance providers’ performance. They should check that periodic inspection and maintenance is being carried out correctly and that vehicles are being presented for the new test free of defects,” he concludes.
Considering the changes and the level of detail, plant operators need to familiarise themselves, especially if vehicles previously classed as plant now need to be plated and tested. A sound maintenance regime and forward plan is vital to remain on the road.
BOX OUT: What requires an annual MOT?
Many types of motor vehicle or trailer-based plant and equipment for engineering purposes now require an annual MOT. They include:
● Mobile cranes and breakdown vehicles
● Mobile access equipment/aerial work platforms
● Road construction vehicles (but not road rollers and other specialised equipment not based on an HGV chassis)
● Asphalt/tarmac mixers and trailers
● Electric motor vehicles registered since 1 March 2015
● Tractor units pulling exempt trailers
● Previously-exempted vehicles based on an HGV chassis intended for towing rather than load carrying weighing up to 7.37t (‘motor tractors’), between 7.37t-11.69t (‘light locomotives’) and more than 11.69t (‘heavy locomotives’)
BOX OUT: Defects that no longer cause an MOT test fail
● Brake fluid level below minimum mark
● Brake fluid warning lamp illuminated or inoperative
● Power steering fluid below the minimum mark
● Trailer electrical socket insecure
● Direction indicator flashing rate
● One of two registration plate lamps missing or inoperative
● Several audible warning defects
● Many items ‘insecure’ but not likely to become detached
BOX OUT: New items in the MOT test from 20 May 2018
● Brake fluid contamination
● Additional braking device performance
● Daytime running lamps, front fog lamps and reversing lamps
● Bumpers
● Prop shafts and all rear drive shafts
● Cab security and undertray security
● Passenger hand grips (quads and heavy trikes only)
● Cab steps and floors
● Noise suppression material
● Emission control equipment: oxygen sensor, NOx sensor, exhaust gas recirculation valve and other emission control equipment
● Engine malfunction indicator lamp
● Diesel particulate filter (DPF) tampering and fluid leaks