FIA Region I Briefing on Periodical Technical Inspections
SAFETY
ENVIRONMENT CONSUMER PROTECTION
Executive Summary On 13 July 2012, the European Commission published its ‘Roadworthiness Package’ which includes proposals introducing new minimum standards for periodical technical inspections (PTI), with the aim of improving road safety, reducing emissions, and addressing mileage fraud. Powered-Two wheelers (i.e. motorcycles and moped) and trailers (caravans) would, for the first time, also be subject to regular PTI. The FIA and its Clubs unconditionally support ambitious European road safety objectives in their daily activity. The proposal indeed contains some positive elements, such as the idea to set up minimum requirements for the contents and testing methods. However, we would like to stress that the challenges faced by the different EU member states in terms of safety are quite varied and call for tailor-made measures to be adequately addressed. Road safety measures that can be very effective in some member states, may turn out to be costly and ineffective in others. Moreover, any additional measure leading to increased consumer costs should always be based on sound evidence. Most recent FIA research indicates that the proposal would mostly likely not result in the road safety benefits foreseen by the European Commission. Concerns in particular are raised with regard to the Commission’s methodology (e.g. insufficient pool of vehicles tested), and finds that the expected impact varies significantly from member state to member state (e.g. in the Netherlands, it has been demonstrated that the cost of PTI can be ten times higher than the expected road safety returns). We cannot back the Commission proposal in its current form and call for a better analysis of the safety benefits before placing additional costs on the consumer without securing sufficient safety return on the investment. The safety impact of increased PTI checks should be carefully weighed against other measures, such as making safety technologies mandatory, before reaching conclusions. As EU member states are faced with a variety of challenges, it is important to leave Member States leverage to apply additional measures as they see fit. The original legal form of a directive was more in line with the general subsidiarity and proportionality principles and a minimum frequency of 4-2-2 would leave member states enough flexibility to adapt to their national context.
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Legislative Background The Roadworthiness Package is composed of the following pieces of legislation: • Proposal for a Regulation of the European Parliament and the Council on periodic roadworthiness tests for motor vehicles and their trailers (COM (2012) 380 final) • Proposal for a Directive of the European Parliament and the Council amending Council Directive 1999/37/EC on registration documents for vehicles (COM (2012) 381 final) • Proposal for a Regulation of the European Parliament and the Council on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union The Proposal for a Regulation of the European Parliament and the Council on periodic roadworthiness tests (COM (2012) 380 final) sets the minimum frequency of testing to 4-2-1-1- for motor vehicles and poweredtwo wheelers alike. Additional requirements apply to cars with a mileage of more than 160,000 km. Member States would remain free to maintain a more regular frequency if they wish, and to impose additional checks after an accident with serious damage, after alterations to safety or environmental components, or after the change of registration holder. According to the European Commission, increased PTI frequency is deemed to lead to fewer accidents and lower emissions. The impact assessment is based on the assumption that 6% of car accidents are primarily caused by technical defects. This figure is based on a very small statistical population of approximately 50 car and 8 motorcycle accidents per year which are caused by technical failure. It is strictly focussed on the age of the vehicle and takes no account of additional factors, such as the age of the driver or the due date of the next PTI. The Commission also sets minimum requirements to be fulfilled for testing equipment, indications on the level of training of inspectors, and a common set of rules to assess deficiencies. Legislators furthermore propose to record the vehicle’s mileage during each PTI. Two years after the entry into force of the directive, the Commission is due to carry out a study on the feasibility, costs and benefits of setting-up a European electronic vehicle information platform to exchange data. In the final provisions, the Member States are encouraged to “take all necessary measures to ensure that the manipulation or tampering of an odometer is regarded as an offence and is punishable by effective, proportionate, dissuasive and non-discriminatory penalties”.
FIA Region I Position Increased frequency of PTI for passenger cars The European Commission’s efforts to improve the safety of European roads is welcomed, but measures that have a cost for consumers should be weighed against other options such as mandatory technologies (seat belt reminders, ABS for motorcycles, AEBS, etc.). Here attention is drawn to a number of concerns in the figures used to substantiate the proposed Regulation’s effects on safety, in particular with regard to the proposed frequency of inspections to 4-2-1-1 and on the proposal to change the legal form of the text. The official road accident statistics for 2010 show 354,919 passenger car accidents in Germany involving personal injuries. In only 1,508 of the passenger cars involved did a technical defect cause the accident. In other words, only 0.42 % of the passenger car accidents involving personal injuries were caused by a technical defect. Of this number, 946 cars showed tyre failure as the cause of the accident. It stands to reason that here the cause of the accident has even less to do with the age of the vehicle, since tyres are replaced relatively frequently and tyre failure due to previous damage (e.g. from parking against kerbstones, low tyre pressure) must be assessed independently of the vehicle itself. The value of between 7 and 8% of accidents caused by technical failure presented by the German Motor Vehicle Inspection Association (DEKRA) is based on its internal accident statistics drawing on 5,019 cars and 700
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motorcycle accidents from 2002 to 2009. The DEKRA findings, based on 50 cars and 8 motorcycles accidents, are actually “over-representative”, since they only take into accounts accidents for which technical experts were called in. In practice, technical experts are called in only for the most serious accidents or for accidents caused by some obvious technical failure. What is more, in the accidents cited by DEKRA there is no information about the age of the drivers or the due date of the next roadworthiness inspection, which could have clarified the figures further.
Source: ADAC
An examination by FIA Clubs of 15,000 accident-cases found no direct link between the number of accidents and the frequency of PTI (source: ADAC). Indeed, the following graph shows that vehicles are not more likely to be part of an accident in the second year after PTI. Neither the cars (0-7 years), nor the older cars (> 7 years) show an increased involvement in accidents in the second year after PTI.
Time since last PTI in months Furthermore, given the proposal’s focus on increasing the frequency of PTI for older cars, FIA Clubs believe any reliable analysis of the technical risk represented by older vehicles should not only be based on the vehicle’s age but also take additional risk factors into account. An automatic correlation between a higher risk for older vehicles and technical failure can be misleading. There is no study positively proving that older cars present a higher accident risk. Since the causes of accidents may include human as well as technical factors, reviewing the drivers’ age as a contributing factor in such accidents is absolutely necessary. We welcome the possibility for member states to require additional roadworthiness in instances where vehicles could represent a threat to safety, for example after an accident with serious damage to the vehicle’s main safety related elements. Consumers should not be unduly burdened with the extra costs of an increased frequency of PTI, and we recommend a minimum standard for inspection frequency of 4-2-2-2-… to remain the status quo. This would not impose an unnecessary additional burden on motorists.
Emissions On the justification of increased frequency of PTI on the basis of reducing emissions resulting from technical defects, it should be remembered that for cars less than 12 years old, technical defects are now indicated by dashboard warning lights (the Mal Indication Lamp – MIL). These lights indicate to motorists the existence of a system failure without needing a PTI check. In more serious cases, the indicator light flashes and sets the vehicle to an emergency mode with a limited speed. This provides the motorist with the opportunity to reach a garage once the problem has been indicated.
Region I
Inclusion of L-class vehicles1 The proposal calls for L-class vehicles such as mopeds and motorcycles to also be subject to a PTI frequency of 4-2-1-1-….for the first time across Europe. Motorbikes on average have a much lower mileage per year than passenger cars (5,000 km compared to 15,000 km). They represent an important alternative means of transportation in a range of EU countries. While it is indeed important to improve the safety of this vulnerable category of road users, we call on the Commission to provide more up-to-date evidence to justify the proposed level of frequency and the associated increased costs for the consumer. In the Netherlands, the ANWB has estimated that the financial cost of implementation and execution of this measure is disproportional in relation to the benefits in terms of road safety. The setting up of independent investigations to obtain data on trends in this class is required.
Inclusion of O1 and O2-class vehicles (Trailers and Caravans)2 Trailers (and Caravans) are included within the scope of inspection for the first time also. Here again, research by the FIA calls into serious doubt whether the costs to the consumer of an increased frequency of inspection will bring a proportional improvement in roadworthiness and safety. While trailers have an enviable safety record compared to some other categories of vehicle, when problems do occur these are very often the result of ‘use’ issues (e.g. overloading, excessive speed, etc.) rather than roadworthiness issues. The cost/benefit case for including them within the scope of roadworthiness testing is therefore not clear. Here again, the setting up of independent investigations to obtain data on trends in this class is required.
Mileage Fraud The proposal includes a provision for mileage to be recorded during each PTI, which may in the future allow for the exchange of data between Members States (systems such as the Belgian CAR-PASS database of mileage registration have shown positive results at a national level). This development is welcomed as a first step towards addressing the problem, however most vehicles are tampered with before their first PTI. In order to tackle the problem effectively, only vehicle manufacturers can significantly raise technical barriers against mileage fraud. We welcome the recognition of the mileage fraud problem by the European Commission, and the recommendation to Member States to make odometer tampering an offence punishable by effective penalties in all Member States. In the long-term, only a technical solution can tackle the problem effectively.
Fédération Internationale de l’Automobile (FIA) Region I FIA Region I represents 106 Touring and Motoring Clubs in Europe, the Middle East and Africa from its Brussels office, which total more than 36 million members. The FIA represents the interest of these members as motorists, public transport users, pedestrians and tourists. The FIA’s primary goal is to secure a mobility that is safe, affordable, sustainable and efficient. With these aims in mind the work focuses on Road Safety, Consumer Protection, Environmental Protection, and the promotion of Sustainable Motoring. See more at www.fiaregion1.com.
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1
The Dutch Club ANWB is opposed to the introduction of mandatory PTI for motorcycles, caravans and trailers.
2
See (1)
Brussels, December 2012