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Topic: New trailer law.
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29/2/2008 at 12:36am
Location: Cornwall Outfit: Autotrail Scout
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OK, Rex, taking your points:
- Yet you at least strongly imply that the secondary coupling must prevent separation in the event of the towball failing.
answer
Yes this is also correct There is no other reason for a second coupling. Should the first coupling fail the second coupling as to keep the trailer attached until brought to a stop.
Response
The law requires all unbraked trailers manufactured after 1996 be fitted with a secondary coupling that prevents the drawbar from touching the ground and provides some residual steering in the event of separation of the main coupling. DfT have kindly provided a publication that explains the intent (which is what a court will consider). You can read it here but the salient bit says:
"Brakes
Braking requirements are prescribed in Regulations 15 and 16 of The Road Vehicles (Construction & Use) Regulations 1986 as amended and essentially require a trailer with a maximum design laden weight of more 750 kg to be braked and allow an inertia (overrun) type braking system to be used up to a maximum permissible laden weight of 3500kg. In use it is not permitted to use an unbraked trailer the laden weight of which exceeds 50% of the kerbside weight of the towing vehicle. For trailers up to 1500kg laden weight it is permitted to use a secondary coupling, which in the event of separation (NOT failure) of the main coupling will retain the trailer attached to the towing vehicle, prevent the nose of the trailer from touching the ground and provide some residual steering of the trailer. Above 1500 kg laden weight the trailer must be fitted with a device to stop the trailer automatically in the event of separation (NOT failure) of the main coupling and this is normally achieved by a breakaway cable attached to the parking brake mechanism - the trailer becomes detached from the towing vehicle." (my emphasis).
You say there is no other reason for a second coupling other than to ensure safety in the event of failure. Yet the law implies, and DfT explictly states, that the reason why a secondary coupling is required has nothing to do with failure of the main coupling. Instead, it is to do with the separation that might occur (e.g.) should you fail to hitch up properly, or use a 50mm hitch head with a 2" towball.
- I believe that you are misrepresenting the law when you say that using a chain doesn't comply.
answer.
The word comply is not appropriate as the law dose not stipulate what to use, The ministry of transport did not recommend the chain over ball at they deemed this unsafe.
Response
It was Mat, not me, that used the word comply. While the law doesn't state how it is to be achieved it is very clear on what is to be achieved. If the Ministry deemed all installations of coupling chain over ball to be unsafe without sight of every example, they are exceeding their authority and this is another example of the sort of thing that prompted me to make my first post in this thread.
The man from the Ministry does not know, and cannot know, the exact circumstances of every example of this type of secondary coupling that is or ever will be and so cannot say for sure that every example does not comply.
- AFAICT the law is clear enough in the case of those small trailers that come with a chain already fitted. The manufacturer must make his goods fit for their intended purpose, which means that the secondary coupling must meet the requirements of SI 1996/3033 etc. The user, who is not an expert in the matter, is entitled to rely on the implied fitness for that purpose
answer.
The ministry do not lay down what is fit or unfit to be fitted to a trailer that comes under currant regulations.
so were dose the manufacturer get his information from.
Response
The manufacturer gets his information from the law, or from standards created to ensure compliance with the law. The law places many constraints on how products must be designed. For example, electrical and mechanical goods must comply with the appropriate safety legislation, and the design of trailers is constrained by the Construction and Use Regulations.
So the manufacturer has a set of criteria that his product must meet to be lawfully used for the purpose for which he sells that product. For example, for trailers intended to be towed by class M1 vehicles, the trailer must be no wider than 2.3m, no longer than 7.0m excluding the drawbar, and must have lights that conform to the C&U regs. If the trailer doesn't meet these requirements it is unfit for purpose as defined by the Sale of Goods Act and may not lawfully be sold to consumers for that purpose.
One of the criteria that an unbraked trailer produced after 1996 must meet is that it must be fitted with a secondary coupling that in the event of separation of the main coupling prevents the drawbar from touching the ground and provides some residual steering. If the manufacture fits a secondary coupling (which Erde et al. do) then it must meet this requirement. If it does not, the trailer is unfit for purpose and may not be sold to consumers. So there is an implied fitness for purpose upon which the purchaser is entitled to rely as evidence that the coupling complies with the law.
Now, you might think that I'm nitpicking here and that I have a "bee in my bonnet". However, it is important that we separate legal requirements from common-sense good practice and particularly so in the mind of those responsible for enforcing the law. If they get it wrong it can seriously ruin your day.
IIRC last year there was a "crackdown" on dodgy trailers in Devon and the VOSA man stated on the local TV news that looping your breakaway cable around the base of the towball and clipping it back to itself was illegal because it wouldn't apply the brakes if the towball failed. However, that is incorrect. The requirement is to apply the brakes in the event of decoupling (not failure) and a snug-fitting breakaway clipped to itself does that and so fully complies. Although he didn't say he'd detained any outfits, the man from the ministry did say that was one of the most common illegalities among the outfits they'd checked - and they certainly were detaining outfits for something.
So, lets imagine that you're setting out for a fortnight's holiday with your camping trailer in tow. It's a brand-new trailer just like that Erde in the HA video and the manufacturer is satisfied that it fully complies with the law. Then some officious so-and-so who half-understands the subject deems your trailer to be illegal because the secondary coupling would jump off if the towball flange bolts parted. He tells you that you can't continue with it until it is modified to his satisfaction and you must either modify it there and then or pay to have your trailer removed by a recovery truck. Through no fault of your own, you're stuck with a ruined holiday at the very least, and all because some officious misinterpreted the law.
Geoff
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29/2/2008 at 4:41am
Location: None Entered Outfit: Vango Icarus 500
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geoff
freedom to express is a good thing but, yawn, you are now starting to bore and irritate..
please go and find another topic to highjack and vent off on.
you have sadly clouded our intent on this one.
it is nothing personal but common sense and best practice is what we are trying to get across, to promote a safe travel to your holiday destination.
my input on his topic is now done
mat
------------- Vango Icarus 500
Modified Erde 122 Trailer
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29/2/2008 at 9:07am
Location: Cornwall Outfit: Autotrail Scout
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Mat, you made an incorrect claim from a position of authority (as a traffic officer) that all "chain over ball" secondary couplings are illegal. Incorrect and misleading statements from those in authority can be seriously detrimental and IMO such disinformation from "on high" needs to be nipped in the bud.
For example, your posts might convince someone that the factory-fitted and fully legal arrangements on their trailer are unlawful, which might prompt them to bodge things to create something untested and that is actually illegal but looks good to their inexpert eyes. Worse, the bodge might damage the main coupling, making failure of both couplings more likely. That claim could also prevent people from buying or continuing to use a perfectly good trailer and consequently put people who can't fit all they need in the car off camping.
Because you said it is your understanding as a traffic officer that all "chain over ball" arrangements are illegal, there is a strong possibility that this misunderstanding is prevalent in your organisation. This wouldn't be the first time such misunderstanding has taken root, and that needs to be addressed to lessen the chances of outfits being wrongly taken off the road etc. at checkpoints.
FWIW, If you hadn't started your first post in this thread with "as a traffic officer my understanding is" I'd have probably only made one post - to direct people to the law and to the DfT page on the subject. AFAICT, the manufacturer of Rex's trailer has designed their secondary coupling to be used with an anchor plate, and Rex seems to have misinterpreted that to mean that all secondary couplings must (by law) use an anchor plate. Thus I can excuse Rex's opening and subsequent posts. He doesn't claim to be an expert on the subject. However, you are writing from a position of authority and that makes a huge difference.
Geoff
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29/2/2008 at 2:25pm
Location: Cornwall Outfit: Autotrail Scout
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Hi again, Rex.
You're a QA engineer. Fine, we should be on the same wavelength. I'm sure that you'd agree that no one person can fully understand every ISO or BS standard currently in force (there are over 27,000). I'm sure that you're also aware that BS5750/ISO900x have a holistic approach and do not deal directly with how to manufacture a trailer! So helping a company through ISO9000 doesn't make you an expert even in what that company produces.
You say, "how can anyone lay down a standard for the length of a second coupling that fits over a ball." Perhaps BS AU 267:1988 (Code of practice for breakaway cables and secondary couplings) has something to say on that. As a QA engineer, I'm sure that you won't be surprised that there are standards to support manufacture of most products subject to EEC Directives (71/320/EEC and 91/422/EEC in this case).
So, if an ISO9000 company produced a trailer with a secondary coupling to the standard I've referred to above and documented in the instructions how that coupling was to be used, I guess that you'd be happy to use it as directed - even if the instructions told you to loop the chain over the towball.
In the end, bear in mind that current trailer models sold in the UK use this type of secondary coupling (e.g. the Erde 158 shown in the HA video) AFAICT, Erde trailers are German-made, subject to TUV approval, and must comply with same EU directives as UK trailers. The chances are that it fully complies with law no matter how wrong it might instinctively appear.
Geoff
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29/2/2008 at 3:38pm
Location: None Entered Outfit: Kampa Filey 6 Air
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Ok for the lay man,
This is what I have done, bought a new trailer for this camping year, an Erde193 this comes with the hitch chain which goes over the tow ball, I have also fitted a secondary hitch bracket to the back of my towball plate through one of the fixing bolts, new bolt fitted, and bought a short steel secondary cable.
So in summary the best of both worlds, for about £5.00
Victor
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