John Martin, RHA Policy Manager for Northern Ireland

John Martin

RHA Policy Manager for Northern Ireland.

RHA RESPONDS TO CONSULTATION ON BAN OF OLDER TYRES

The Department for Infrastructure’s consultation on Banning Tyres Aged 10 Years and Older on Heavy Goods Vehicles, Buses, Coaches and Minibuses within Northern Ireland was recently published proposing to introduce similar provisions within the region to that which the Department for Transport introduced in GB with effect from 1 February 2021 by amending the Construction & Use Regulations.

The RHA has fully considered the Department’s consultation which can be found at https:// www.infrastructure-ni.gov.uk/ consultations/consultation-bantyres-10-years-or-older-heavygoods-vehicles-buses-coachesand-minibuses and have flagged a number of points surrounding some of the commentary within the document as set out below: • The final line of the “Background and Context” section on page 4 “The proposals include measures requiring the date of manufacture marking to be visible for the purposes of inspection, and to be maintained and not tampered with.” • The final line in the “Proposal” section in page 8 “To address this the Department, is proposing to mandate the visibility of the date marking on tyres in all configurations, and to make it an offence to drive or operate a vehicle where the date markings are not visible and legible,

This means in practice that tyres will need to be fitted to the wheel-rims with the date markings facing outwards.” • The 2nd and last paragraph within the “Implementation” section on page 10 “We also propose to amend the Regulations to mandate the visibility of markings on tyres, including in a twin wheel arrangement, where

tyre date will need to be displayed on the out facing sidewalls of the arrangement; these measures are already in place in GB”. • The initial paragraph within the “Date of implementation” section on page 11 “We propose an implementation period of 3 months from the date of any legislation taking effect before any ban comes into force to allow drivers, operators and businesses time to review their fleet, stock and change any tyres if required.

Given that the rationale for this legislation is improving road safety we want to ensure that compliance with the requirement is achieved as quickly as possible.”

SUBTLE DIFFERENCE

There is a subtle difference with the Department’s proposals in Northern Ireland when compared to the actual GB legislative provisions introduced to bring these proposals into effect. The consultation documents key thrust appears to be ensure the date markings on relevant tyres is “the date marking is visible and legible” whereas within the GB legislation states, the date marking on relevant tyres is “a date marked on the tyre sidewall in accordance with ECE Regulation 30, 54, 108 or 109 is illegible”. Considering the Department are referencing and relying upon research undertaken by GB’s Transport Research Laboratory in 2018 coupled with the Department for Transport’s approach to introducing similar provisions the requirements within Northern Ireland should be exactly the same as those in GB unless the Department has additional evidence that it is relying upon but hasn’t referenced to impose more onerous requirements within the region.

ALIGNED WITH GB

The RHA has therefore suggested the Northern Ireland provisions are aligned with the approach adopted in GB. Namely:10-year age limit on tyres fitted to the front axle(s) of a bus/coach, or truck over 3500kg or on any axle with single tyre fitment on a minibus; Requirement for legibility of the date markings applying to all axles on buses/coaches including minibuses and trucks over 3500kg. In this context we suggest the Department relies on the DVSA interpretation of the word ‘legible’ as meaning not absent, defaced or removed. The interpretation does not extend to the ability to read the date marking in situ. However, a tyre may leave a depot with all markings legible and due to kerb scuffing the markings may become illegible during its journey therefore the text of the amendment should include “a without reasonable excuse” proviso. Alignment with GB policy in this matter will offer the best policy cost-benefit outcome, facilitate interoperability of vehicles, simplification of enforcement and the avoidance of unnecessary cost and environmental impact on the transport sector that is already under enormous pressure within Northern Ireland. The proposal to require the date code on the tyre sidewall to be visible, meaning that tyres would need to be fitted to the wheelrims with the date markings facing outwards is unacceptable. We strongly oppose this proposal as the benefits of the proposed measure are unquantified and unproven whilst the likely economic and environmental costs are considerable. We note that the proposed age restriction only applies to front steering axles on heavy vehicles plus any axle on a minibus where the tyres are in single fitment. In all these locations both sides of the tyre are accessible for inspection. In this context, the proposed inclusion in the legislation of a requirement for the date marking to face outwards would contribute little to improving compliance with the proposed age restriction. It is noted no age restriction is proposed in relation to the other wheels on a vehicle or combination, in this context the inclusion of a requirement for the date code to be legible is to provide an indication, amongst others, of the condition of the tyre. In most of these locations both sides of the tyre are accessible for inspection. Only in relation to twinned tyres can visibility of the date code sometimes be an issue. However, in this location the consequences of catastrophic tyre failure are greatly reduced by the presence of the adjacent wheel: in any such case it would be possible to bring the vehicle safely to a halt. Where it is not possible to confirm the legibility of a date marking (eg due to the mounting of twin tyres), other criteria can be used, eg sidewall wear or cracking, to make an informed assessment of the suitability of the tyre for continued use. On the basis of these

John Martin

RHA Policy Manager for Northern Ireland.

considerations, the proposed inclusion in legislation of a requirement for the date marking to face outwards would of itself contribute little to improving roadworthiness or road safety

INCONSISTENCIES

Consistent with its original purpose of facilitating the management of product recalls, the regulatory date marking is applied to only one sidewall. Tyres are increasingly made with directional tread patterns in order to minimise environmental impact and to accompany the growing adoption of retarders and energy conservation devices on heavy commercial vehicles. The proposal to require that the date marking should ‘face outwards’ would result in 50% of directional tyres being run in the reverse direction, leading to increased tread wear and rolling noise. The Department’s proposal is inconsistent with GB and would be highly disruptive to vehicle assembly lines wherever vehicles for Northern Ireland use were manufactured. Of greatest impact, the proposal would preclude the widespread practice of ‘turning on the rim’ and these directional tyres onto the other side of the vehicle part way through the tyre’s life so as to ensure even tread wear and maximise tyre service life. Uneven tread wear is widespread on heavy commercial vehicles, particularly on front steering axles. Aggressive sidewall wear due to kerbing is also prevalent on city buses. In both cases the only remedy is to refit the tyre on the rim part way through its life so that the inner sidewall becomes the outer sidewall. It is suggested that the cost of this proposals would be excessive and in environmental terms, the proposal would lead to approximately 8% increase in the ongoing consumption of truck and bus tyres.

SUPPORTING CANCER FUND FOR CHILDREN’S DAISY LODGE WITH PARACHUTE JUMP

McBurney Transport Group, McCulla Ireland and Palyn Transport Management Consultants recently provided sponsorship to Laura Martin and Lydia Alexander to undertake a sponsored parachute jump in aid of the Cancer fund for Children’s Daisy Lodge in Newcastle, Co. Down.

Both Laura and Lydia were pupils of the local grammar school Down High and were looking for a worthy charity to fund raise for. They completed some initial research and selected the Cancer fund for Children’s Daisy Lodge as their preferred charity and agreed to do a sponsored parachute jump with the Skydive Wild Geese in Garvagh. Laura’s father John Martin works for the RHA and was approached by the companies involved to provide sponsorship and support for this charity and he helped co-ordinate the event. They organized various school events, charity street collections, personal donations and corporate sponsorship from the three companies and raised close to £4,000 for this very worthy charity.

SAFE ENVIRONMENT

The Daisy Lodge facility is a purpose-built therapeutic centre located in Newcastle Co. Down for families across the island of Ireland affected by cancer. Designed with family’s comfort in mind, during their stay people are able to spend quality time together in a safe and supportive environment, far removed from the pressures of cancer treatment and hospital wards. John commented: “After presentation of the cheques, we were provided with an escorted tour of the facility by Cormac McMullan of the charity who gave us a fantastic insight into the facilities and care provided by this invaluable facility. “The staff are absolutely fantastic, and it was a very humbling to realise the quality and level of support this facility provides. This is an extremely invaluable facility and needs support. It takes £2.6 million to run this facility every year and they only receive 0.5% of this from Government funding, so I would encourage anyone who wishes to get involved in providing support where possible as you never know when you might need it.” Carolyn Carmichael McBurney Transport Group Operation’s Director added: “The McBurney Transport Group were delighted to provide sponsorship to Laura and Lydia in their skydiving challenge to raise money for this exceptionally worthwhile cause. Daisy Lodge is certainly an excellent and much needed facility.” And said Peter Summerton, Managing Director of McCulla Ireland: “We were pleased to be able to support this extremely worthy cause as its close to our hearts.”

Pictured L-R: John Martin RHA Policy Manager (NI), Gordon Wilson, McBurney Transport, Lydia Alexander and Laura Martin – Sky divers, and Johnny Black, McCulla Ireland Laura during the Sky dive.

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