Frequently Asked Questions about Vehicle Standards (current and future).
Future Standards FAQ
I am told that swivel seats and talking taximeter will be required in future, is this true?
No.
Wheelchair Accessible FAQ
Can converted vans (goods vehicle N1) be licensed as a wheelchair accessible taxi or hackney?
New wheelchair accessible taxi and wheelchair accessible hackney standards require passenger car (M1) levels of compliance. A converted van (goods vehicle N1) will still be acceptable provided that the finished converted vehicle has proof of compliance to passenger vehicle (M1) safety standards. The main areas are seats and seat belt installations that require formal test reports.
Is it true that new wheelchair accessible taxis and hackneys have to be under 9 years of age?
No, here is no age limit applied to wheelchair accessible vehicles. That age limit is only applicable to standard taxis and hackneys when changing vehicle from June 8th 2010 and on renewal in 2011.
What is “Type Approval” and who is responsible for this?
Type Approval is a process for ensuring that vehicles seeking registration meet certain safety, environmental and legislative engineering standards. In Ireland type approval is the responsibility of NSAI.
If you are a vehicle convertor then you should review the information on the RSA website very carefully indeed as it will affect you.
Why does Type Approval affect me as a wheelchair service provider or vehicle convertor?
The Commission for Taxi Regulation has sought to ensure that the wheelchair accessible vehicle licensing requirements “line up” wherever possible with the changes likely to occur under this new regime of entry into service regulations (Type Approval).
Type Approval has relevance because it will apply, starting on an optional basis from April 2009 (but mandatory as we understand it from April 2012), to almost all road vehicles including those converted from goods vehicles to carry passengers and vehicles converted or adapted to transport persons seated in their wheelchairs.
This same legislation brings with it, for the first time, a defined category of “wheelchair accessible vehicle” and this requires certification to passenger car (M1) levels. The European intent is quite obvious and sensible and it is that vehicles carrying passengers should meet passenger car levels of safety and environmental legislation. A goods vehicle does not necessarily meet those same standards.
The Commission for Taxi Regulation has respected these forthcoming changes and as part of its licensing requirements has adopted the passenger car standards approach as published in the National Vehicle Standards document towards the end of 2007. The final finished vehicle in converted accessible form must comply with passenger car standards and not just goods vehicle standards. A converted goods vehicle may be accepted provided that it holds final certification to passenger car (M1) standards. The decision as to whether to start the conversion from a goods vehicle (e.g. panel van) or from a passenger vehicle (e.g. Combi 9 seater) is probably more of an economic decision than a technical one and will also depend on any possible assistance offered by the vehicle manufacturer.
What are the important differences between a Goods Vehicle (N1) and a Passenger Vehicle (M1)?
A goods vehicle has at least four wheels and is designed and constructed for the carriage of goods, there are various categories defined by maximum gross vehicle weight and category N1 is limited to a maximum gross weight of 3500kg.
A passenger vehicle has at least four wheels and is designed and constructed for the carriage of passengers; there are various categories defined by the number of passenger seats and vehicle maximum weight. Category M1 is limited to no more than 8 passengers. The modern driving licence for cars (class B driving licence entitlement) is limited to vehicles with a maximum design vehicle weight of 3500kg.
These vehicle categories are European definitions and relate to the Type Approval requirements that must be met if a vehicle is to be registered and entered into service, i.e. to be allowed on the road. They are definitions relating to the engineering standards and certification governing the safety, environmental and legislative aspects of vehicle design and manufacture.
They do not necessarily align with national definitions set for example by the Revenue Commissioners that relate solely to taxation matters, e.g. the “commercial” vehicle as defined for the purposes only of VRT etc.
On paper there are potentially 61 separate areas of approval for passenger cars and around 12 for goods vehicles. It is therefore obvious that there are some considerable differences between the two approval regimes. However when the vehicle is available from the manufacturer in both passenger and goods vehicle form, e.g. panel van and Combi, then it is likely that a large number of approvals will be shared between the two versions. However you would need to check this out for each particular vehicle. One example of differences may be the interior and exterior projection requirements designed to ensure there are no sharp edges inside the vehicle upon which passengers may injure themselves.
Seat belt and anchorages are obvious safety items; my vehicle was a van and converted with “crash tested seats” and has an Engineer’s Report. Why are you making this more complicated than it needs to be?
Type Approval sets out standards to be met in respect of seat belts and their anchorages. An Engineer’s Report is not sufficient proof; some test certification is required. The real world usefulness of seat belts is unarguable. The current Type Approval requirements for seats, belts and anchorages are known to be very representative of real crash scenarios and must be fully considered as perhaps the most important aspect of any vehicle conversion or adaptation.
It is important to note that the Type Approval system currently applies to vehicles seeking registration; it is a road vehicle requirement that is going to happen independently of any public service vehicle licensing requirements. It will affect vehicle convertors and coachbuilders regardless of the end use of their vehicle: no Type Approval = no registration = NO SALE.
But my seats are “crash tested” and so must be safe?
There are two other categories of passenger vehicle, M2 and M3 (basically minibus and coaches/buses respectively). This is important because sometimes seats are sold as “crash tested” and usually this refers to seats with integral seat belts and it is the belts and their seat belt anchorages (on the seat) that have been crash tested. The complete assembly has not always been tested in the vehcile and it is this performance that matters.
There are three different crash test requirements for the three different passenger vehicle categories. The M1 crash test is the most severe, 20g deceleration. The M2 is less at 10g and M3 only 6.6g. [1g acceleration or deceleration is that experienced purely due to gravity, as in jumping off a wall. 20g is stopping 20 times quicker than that from around 48km/h, ,i.e. very severely.]
So a minibus seat (tested only as required in a minibus to M2 standards) is unlikely to pass the more rigorous “car” (M1) test. Certainly in regard to any vehicle certification to M1 levels, this would not be granted to a vehicle for which the seats only had accompanying documentation for their fitment in M2 vehicles or M2 crash test results.
The above is really only half of the full picture. Even if the seats and their associated seat belts and anchorages have in fact been tested to the required M1 standards, the “in-vehicle” performance can then only be as good as the seats’ connection to the vehicle floor. Worse still the seat belt anchorage test load is applied directly to the seat frame via the bolted attachment at the strap or buckle end. When this test load is applied to the seat assembly installed in the vehicle, this will usually be some distance from the floor which gives rise to a considerable bending moment being applied to the vehicle floor. In addition to the seat belt anchorage test loads the vehicle floor must also withstand a 20g deceleration of the seat mass itself. Consequently and especially for seats where all of the belt anchorages are attached to the seat or its mounting frame the loads involved at the vehicle floor are very high indeed.
By way of example the seat belt anchorage test load (M1) is around 2700kg force per seat so this requires the floor structure for a row of three seats (bench style) to withstand around 9 tonnes of force in the forward direction for forward facing seats. If the belt anchorages are assumed to be around 350mm from the floor and the fore/aft bolt spacing of the mounting legs into the floor is around 175mm then the seat assembly becomes a great big lever applying twice the ultimate seat belt loads into the floor, i.e. potentially 18 tonnes across the width of the vehicle. If said seat has 3 pairs of mounting bolts then each attachment still has to react 3 tonnes! Of course this huge load into the floor structure can be greatly reduced if some of the seat belt anchorages attach directly into the body structure, partly as a result of less overall load points and partly due to less leverage effect.
Consequently if moving seats or considering relocating the existing seat belt anchorages from body to seat, very careful and detailed thought is needed as to the likely loads involved. If, for example, the standard three seat bench unit has the outer seats with the outboard lower anchorage on the wheelarch and the outboard upper anchorage on the roof (cant) rail then the only seatbelt anchorage loads being applied to the floor are the centre seat belt anchorage forces (100%) and a percentage of the two outboard seat belt’s inner anchorage loads. In addition there is greatly reduced bending moment on the floor.
For rear facing seats these are tested in the rearwards direction but only to the M3 load case, i.e. the 6.6g deceleration or around 0.9 tonnes. However the popular configuration of a row of three tip down seats behind the driver will still give rise to large loads to be reacted at the vehicle floor and “B” pillar area. Consideration should also be given to the (forward) inertia forces arising from these tip down seats in a forward collision scenario.
My wheelchair accessible vehicle has wheelchair and occupant restraints to the old requirements; the new requirements stipulate actual tests. Why? What will be the purpose of the Assessor's Report in future?
The Commission has suggested a number of methods to ensure that these vital safety features are fully assessed. In a similar manner to the above example there are requirements for both the actual belts/straps (including their end fittings) and also for their anchorages into the vehicle structure. The vast majority of wheelchair tie downs will be certified to ISO 10452. The vehicle anchorage points for wheelchair and wheelchair occupant restraints may be tested as outlined in the National Vehicle Standards document, i.e. either the successful resistance of the forces as prescribed in the seat belt anchorage Type Approval Directive 76/115 as amended or the static pull test described in Appendix 6.
As the above anchorage tests are fundamentally destructive in nature the tests relate to specific vehicle types and specific anchorage designs and are “read over” to the finished vehicle by conformity statements from the vehicle convertor that the finished vehicle installation is the same as that for which test certificates are presented. The Assessor's Report will include checks that the vehicle and documentary evidence are, in fact, all in agreement. Please be aware that the ultimate acceptance of a vehicle may be delayed if there is any doubt as to the overall integrity of the conversion. It is the individual vehicle presented that is being considered and any accompanying documentary evidence (test certificates, installation instructions etc.) must relate relevantly to the presented vehicle. For example, seats that are on higher mounting pedestals than those on the test certificate would normally not be accepted. Usually the testing authority (overseeing the physical seat belt tests) will require the “worst case” situation to be initially tested; however this can often be awkward to define and so the final test certification may be quite restrictive on permitted seat types or locations.
It is the Commission’s view that the Assessor’s Report, in respect of the suitability requirements, would form an Information Folder and check that the certification and documentary evidence do in fact relate to the finished vehicle presented for the suitability inspection.
The supplier/firm of the conversion and/or restraint products has always guaranteed that they are “approved”. Does this mean I have nothing to worry about?
You do need to consider very carefully the validity of any supplier test certification and whether it remains relevant to your particular finished installation in any one vehicle. In the overall scheme of things the seat belt anchorage tests are not that expensive and testing the vehicle in its “as finished” specification is really the best possible way to ensure compliance with these fundamental safety requirements.
As will be understood by those who attended the RSA Type Approval seminars it is clear that greater emphasis will be placed on engineering and test led certification for any vehicle seeking first registration in the future. The idea of an “Information Folder” was mentioned and that this would gather together all of the relevant certificates and approvals in one file.
It is strongly recommended that you investigate what is required and check with suppliers as to what information/certification/test results/approvals they may hold. Compare them with the standards listed in the National Vehicle Standards document.
As may be understood the EC Type Approval system is a system for, and recognised across, European Member States only. American, Canadian and Japanese vehicle safety approvals are not automatically equivalent. With specific regard to seats, head restraints, seat belts and wheelchair restraints and wheelchair occupant seat belts you are advised to check with suppliers as to exactly what certification they hold and to ensure that they meet, or are equivalent to, the required European or International standards. The same applies to windows where the glass must be marked with the required approvals and not be too heavily tinted.
Why and how does the vehicle Type Approval system work, what about component parts like wheelchair tracking?
As a good example of how Type Approval works, and the usefulness of certification, we can look at the “flooring system” that some convertors use. A floor system usually comprises some tracking rails and some structural infill panels. They are designed to allow for a range of seating positions and wheelchair positions. The manufacturer of the floor system will perform a pull test (or maybe a dynamic “crash” test) with an example setup of seats, seatbelts and wheelchair restraints in a “worst case” condition (agreed with an independent test laboratory and authorised Government Type Approval engineer). As the fitment into the vehicle is critical this test result will be vehicle and installation specific. The test results may be limited to certain seat types, heights or configurations only.
The floor system supplier would then appoint “approved installers” who are trained and considered suitably skilled at fitting that floor system into that specific vehicle in strict accordance with their instructions. The overall result of this is that the floor system when installed correctly into the same basic vehicle and with similar seating installations will be most likely to meet the (test proven) Type Approval seatbelt anchorage loads.
Thus there is a traceable path of certification from finished vehicle to original tests: the flooring system supplier supplies a copy of the original strength tests, the vehicle convertor supplies copies of his installer certification and a letter stating that he has installed the system in vehicle VIN number XYZ and that it was installed in line with the floor system manufacturer recommendations. The purpose of the Assessor’s Report is an experienced engineering assessment that the above statements are true.
What are the potential problems?
Note that in the example above it all falls apart if, for example, the floor system is used in a different vehicle variant not covered by the original test certification, if the finished vehicle installation has more seats or they are outside of the floor system manufacturer’s recommended positions, if the original tests were to M2 levels and the finished vehicle seeks M1 compliance etc.
Note also that this does not guarantee that the overall installation is Type Approved for any other legislative requirement, e.g. interior projections.
It should also be understood that, for example, the performance of single line of tracking depends massively on how and where it is bolted down. It will support very different loads if bolted to a rigid slab than when bolted to a thin steel monocoque vehicle shell, where the failure mode will usually be the opening of the upper slot sides due to inadequate vertical bending stiffness of the outer flanges. The rigid slab will add localised support that does not usually exist on the vehicle floor and this hopefully shows why adequate reinforcements are needed to achieve the desired “in-vehicle” results.
Ultimately the “in-vehicle” installation is only as good as the component parts and the correct assembly/combination of those parts. “Mixing and matching” outside of the original specifications or certifications is foolhardy.
Some vehicles already passed as suitable are being failed because of the tip down seats, why?
Figure 2 on Page 30 of the National Vehicle Standards attempts to clarify the interpretation of the measurement of the wheelchair space. Please note that ALL of this document relates to future requirements, none are currently law. However in this specific regard the future intent is clear and it has been agreed with SGS that the interpretation of the current dimensions should be in line with the future intent.
To be clear the diagram shows dimensions that are consistent with the existing suitability legislation and clarifies the allowed-for intrusion of any tip down seat into the defined wheelchair space. The intrusion allowance dimensions results from wheelchair measurements and do not reflect any particular vehicle. The dimensions are measured parallel to the vehicle floor as shown in side view and along the vehicle axis front to rear in plan view. Interpreting the minimum length requirement of 1200mm and the maximum tip down intrusion of 200mm means that a measuring stick of 1000mm (one metre) should be able to be placed, parallel to the floor and along the front/rear axis of the vehicle between the front edge of the (forward facing) seat squab and the underside of the tip down seats. The “200mm maximum” dimension is the maximum allowed intrusion of the tip down seats into the 1200mm minimum wheelchair fore/aft dimensions.
Limousine FAQ
Is there an age limit for limousines?
No, the only age-related requirement for limousines is that for vehicle is under 30 years of age the engine must be at least 1900cc capacity.
The Commission will discuss with the limousine industry the concept, as suggested by their submissions, of creating in the future some sub categories, one of which (corporate chauffeur business) may be naturally suited to an age requirement. This is not suggested for the “ceremonial, classic or wedding style historic” type vehicle.
What about side facing seats?
EC Directive 2005/39/EC applies. As we interpret this it prohibits the registration of any new car with side facing seats after 20th October 2007. The Revenue Commissioners are responsible for the registration of all cars. This is not an SPSV licensing matter but a road vehicle matter.
Prospective purchasers of vehicles with side facing seats not registered in Ireland should ensure that they ascertain for themselves that they will be able to register them, the Revenue Commissioners deal with the first registration of motor vehicles. They should also assure themselves that the vehicles are likely to meet the suitability requirements if intending them to be licensed as SPSVs.
Those considering the import of a stretched limousine are advised to fully understand the requiremnts of the Entry into Service Regulations, please also see the RSA website..
Safety Equipment FAQ (applicable for all from 01/01/2009)
Can the Commission direct me to a shop where I can get the safety equipment?
The Commission is not able to endorse, recommend or promote any particular brand but all safety equipment items are usually available from large supermarket chains, car dealerships and pharmacies. The Commission has produced a flyer which helps you identify the correct safety equipment. This can be downloaded here. Please check your equipment specification is correct before purchasing.
How many fire extinguishers are needed and what is the specification?
A single 2kg extinguisher is required from 1st January 2009 (along with the other safety equipment outlined in the National Vehicle Standards document), more than one 2kg extinguisher would also be acceptable.The 2kg dry powder unit must be suitable for the inflammability classes A, B and C suitable for fighting a fire in the engine or passenger compartment from organic solids, flammable liquids or flammable gases and be compliant with IS EN3-7 2004 or direct equivalent standard.
With regard to the “newness” of IS EN3-7 2004 the common equivalent acceptable standard is BS or EN 3: 1996.
Two separate 1kg extinguishers are not acceptable.
The fire extinguisher must be mounted in the luggage area safely and securely. This means in a manner so as to prevent it rolling around the boot or coming loose in an accident. Common methods for achieving this would be to screw the mounting bracket into place in a convenient location or for it to be strapped into place securely, e.g. in a similar manner to how some spare wheels are secured.
Annual certification is not required but the extinguisher shall be in serviceable condition as recommended by the manufacturer and any gauge or date information shall be respected. Thus a corroded extinguisher, or one with the gauge reading in the red or past any “service by date” etc. will not pass.
What standard should I look for when buying a high visibility vest?
All SPSV drivers shall carry a high visibility safety vest which is to be used at the scene of an accident and for enhanced night time visibility. The high visibility safety vest shall be approved to ANSI/ISEA 107 1999 or 2004 or to BS EN 471 or CEN 471, 1994 or 2003 and marked accordingly.
This identification is usually sewn into the label either at the collar or at the side seam with the washing instructions.
Someone said I need to have a torch in my car: is this true?
Yes, all SPSV drivers shall carry a working handheld torch and store it safely within the vehicle. It may be used to highlight step edges or other hazards.
What standard should I look for on the warning triangle?
A reflective advance warning triangle shall be carried within the vehicle. It shall be safely and securely installed within the vehicle in such a way that the warning triangle can present no danger to the occupants in the event of a collision. The advance warning triangle shall be approved to ECE Regulation 27 and marked accordingly. The approval mark will start with the “E” and having a number of the form “27Rxxxxx”.
I cannot understand the First Aid Kit as shown on Page 28 of the National Vehicle Standards document, please can you explain this better?
There are 2 acceptable First Aid kits, EITHER the DIN 13164 OR the HSA Travel kit.
DIN 13164 kit contents, popular automotive vehicle first aid kit, often found as standard in German cars.
1 roll of self-adhesive plaster DIN 13 019-A, size 5m roll x 2.5cm width (adhesive tape)
8 pieces of self-adhesive bandage, size 10cm x 6cm, DIN 13 019 (first aid dressings/large plasters)
1 large sterile first-aid packet DIN 13 151-G (standard first aid dressing, large, 10cm x 12cm)
3 medium sterile first-aid packets DIN 13 151-M (standard first aid dressing, medium 8cm x 10cm)
1 large sterile dressing for burns DIN 13 152-A (burn dressing 60cm x 80cm)
2 small sterile dressings for burns DIN 13 152-BR (burn dressing 40cm x 60cm)
3 large elastic gauze bandages DIN 61 631-MB-8, 8cm x 4m (conforming bandage)
2 small elastic gauze bandages DIN 61 631-MB-6, 6cm x 4m (conforming bandage)
6 sterile gauze wound compresses 10cm x 10cm (non adherent wound dressings)
2 triangular bandages DIN 13 168-D (96cm x 96cm x 135cm)
1 pair of scissors DIN 58 279-A 145
1 insulating emergency foil blanket gold/silver 160cm x 210cm
4 disposable vinyl gloves, large
1 first-aid brochure six languages
1 table of contents
Note: Items marked “sterile” generally have an expiry date that should be observed.
OR
Irish Health & Safety Authority General First Aid Applications 2007 Recommended Contents for First-Aid Travel Kit (contents should be kept up to date).
20 Adhesive Plasters
2 Sterile Eye Pads (No. 16) (bandage attached)
2 Individually Wrapped Triangular Bandages
6 Safety Pins
1 Individually Wrapped Sterile Unmedicated Wound Dressings Medium (No. 8) (10 x 8cms)
1 Individually Wrapped Sterile Unmedicated Wound Dressings Large (No. 9) (13 x 9cms)
1 Individually Wrapped Sterile Unmedicated Wound Dressings Extra Large (No. 3) (28 x 17.5 cm)
10 Individually Wrapped Disinfectant Wipes
1 Paramedic Shears
3 Pairs of Examination Gloves
2 x 20mls Sterile water where there is no clear running water **
1 Pocket Face Mask
1 Water Based Burns Dressing Small (10 x 10 cm) ***
1 Water Based Burns Dressing Large ***
1 Crepe Bandage (7cm)
** Note 2: Where mains tap water is not readily available for eye irrigation, sterile water or sterile normal saline (0.9%) in sealed disposable containers should be provided. Each container should hold at least 20ml and should be discarded once the seal is broken. Eye bath/eye cups/refillable containers should not be used for eye irrigation due to the risk of cross infection. The container should be CE marked.
*** Note 3: Where mains tap water is not readily available for cooling burnt area.
The easiest guaranteed inspection pass method is a kit to the specification of EITHER DIN 13164 sealed in original wrap OR the HSA Recommended Travel Kit. If obviously still sealed and unopened there should be no need to carry out any further checks to boxed kits marked as meeting the above standards.