Civilised Road Worthiness Testing

bikerepairOn Tuesday 22nd January 2013, the TRAN Committee held a Public Hearing concerning the proposals for new EU-wide  Road Worthiness Testing (RWT) also known as  Periodical Technical Inspections (PTI) for cars, powered two-wheelers (PTWs – motorcycles – scooters – mopeds) and commercial vehicles and trailers.

The European Commission representative commented that, “In a country where you apparently have very civilised motorbike riders you inspect them (the motorcycles), thus it is one more reason to actually inspect them in other member states who believe that the population of motorbikers is not so responsible and educated.”

That must mean that in Northern Ireland we are very civilised, responsible and educated motorcyclists!

The other comment that the Commission representative made which we picked up was that the proposal aims to ensure “minimum standards”. We take that to mean a level playing field throughout Europe for Member States to carry out road worthiness testing.

We should remember that any roadworthiness test and certificate issued confirms that a vehicle at the time of its test (as far as can be reasonably determined without dismantling) meets the minimum acceptable environmental and road safety standards required by law, it doesn’t mean that the vehicle is roadworthy for the life of the certificate and isn’t a substitute for regular maintenance.

Moving swiftly on, at Right To Ride what interests us is the changes there would be in the proposal, which seeks to introduce mandatory RWT for PTWs across Europe.

More importantly, how that would affect riders in those countries who already have RWT, for example, in Northern Ireland and GB we have testing known as MoT.

In concluding the TRAN meeting the rapporteur German MEP Werner Kuhn of the European People’s Party (Christian Democrats), outlined that the rapporteurs – MEPs dealing with the proposal for the European Parliament, all have different perspectives, different focuses and different priority interests.

Within those priority interests Mr Kuhn said that we need to focus on:

  • Harmonizing technical standards for inspections
  • Independent monitoring and checking bodies
  • Trained and qualified people carrying out checks
  • Implementation in all member states
  • Highest possible technical standards that can be realistically implemented
  • Proper Enforcement and mutual recognition of the results of the tests through all member states

Concerning motorcycling Mr Khun stated, “It is important that we consider mopeds and motorbikes.” adding that, “These are all matters, which I think we will tease out further down the line when we have further discussions.”

Position In Relation To The Proposal

Rather than focus specifically on all the comments from the various stakeholders, we prefer to explain our position in relation to the proposal, based on our analysis of a number of factors and not just those put forward at yesterday’s hearing.

From all the various studies that have been carried out (including our own), we see that mechanical defects are NOT a major cause of primary and secondary accidents for PTWs.

In our view, the best yardstick for determining whether there are problems with motorcycles, scooters, mopeds from a mechanical perspective is the failure rates of MoTs (aka RWT) – typically 7% per annum here in Northern Ireland.

(In Northern Ireland the government agency DVTA (Driver Vehicle Testing Agency) carries out the MoTs at designated testing centres. Interestingly, in Great Britain (England, Scotland and Wales), the failure rates are far higher – typically 21% and we can’t help thinking that this may be due to the fact that the MoT is carried out by private sector mechanics.)

The reasons for failure in Northern Ireland for motorcycles, scooters and mopeds are mainly electrical issues including lights and wiring (c.40%); c.17% for near side headlamps; brake systems at around 10%; also 10% for tyres/wheels and 5% for exhaust systems, based on data provided by the DVTA over the four year period, 2007 to 2010.

The Northern Ireland DVTA publishes failure rates for cars every month – and brakes are the most common reason for failures with an average of around 20% – 22% (i.e. double that for motorcycles).

DVTA Pass Rates & Reasons for Failure

In that respect, one could argue that there is a safety issue in terms of reasons for carrying out an MoT (RWT) for both cars and motorcycles – but we would see it as a preventative measure.

Motorcyclists And Manufacturers Representation?

We were fascinated by the arguments put forward by the FIA (Fédération Internationale de l’Automobile) representative, Laurianne Krid at the hearing (who also mentioned that the FIA represents 8 million motorcyclists!) and we think there is a lot of mileage (excuse the pun) in what she had to say regarding casualties and age of vehicle – that there does not appear to be a correlation.

She suggested that in terms of proportions of older cars and crashes, that it may be due to the fact that more young people drive older vehicles – this is quite probably true, but it is also true that there is a higher proportion of older vehicles in the parc (registered vehicles in circulation), so proportionately it stands to reason that more older cars would be involved in crashes.

FIA Region I Briefing on PTI – pdf – 2.5mb

In that respect, we would assume that this analysis could be extrapolated to PTWs.  What this suggests is that we need to look for other reasons than this to consider why we should have regular road worthiness testing.

ACEM (European Association of Motorcycle Manufacturers) put forward a very persuasive argument in favour of RWT for PTWs and by and large we are supportive of their position.

Especially with regards to the changes that IMCO Committee (Internal Market and Consumer Protection) spearheaded with the Regulation for L category vehicles – specifically relating to emissions and braking systems.

ACEM’s Presentation to Public Hearing  – pdf – 404kb

ACEM’s position on RWT – pdf – 158kb

The other aspect which Antonio Perlot of ACEM touched on at the TRAN Committee meeting, was that 59% of the PTW parc is made up of vehicles with an engine size of 125cc and under and as he pointed out, these are mainly owned by commuters or young people who are less inclined to take the same level of care that a passionate older motorcyclist might do.

Therefore we believe a regular check would be beneficial – for the reasons indicated above – regarding failures.

It is also important to ensure that the vehicle is legally roadworthy – i.e. that all parts are legal such as exhaust systems and in the case of mopeds and other restricted bikes, that they have not been tampered with.

Cost implications

We understand that there are serious cost implications for governments throughout Europe and in that respect we are supportive of the Northern Ireland Assembly’s position that the proposal should be made a Directive rather than a Regulation.

We believe that this option would allow countries to choose what suits them best, including opting out of testing PTWs, if that is what they wish.

The Northern Ireland MoT system would implode if tractors, caravans and trailers were to be tested, not least because the testing stations would struggle to accommodate these vehicles and because setting up a registration system for trailers would be far too onerous in terms of cost and implementation.

Regularity of RWT

In terms of regularity for RWT, a Directive would allow countries such as the UK to continue MoTs on a yearly basis while allowing others – typically the Nordic countries where motorcycling is seasonal thus the mileage and usage is far lower than the rest of Europe – to use the 4-2-2 system, or whatever they find appropriate to their needs and requirements.

Rights and Responsibilities

At the first TRAN Committee meeting on RWT (held in December 2012), the Commission side stepped the issue of data in terms accident causation and refers to motorcycles – (Powered Two Wheelers) as, “quite similar to a normal vehicle integrating a lot of new technologies” that would lead for consideration on the same footing as other vehicles, “in terms of regular inspections.”

The comment made by the Commission’s representative at that meeting should not be put aside or treated lightly, because this underpins a discourse that has driven rider organisations over the last 40 odd years, which is to be treated equally in the transport mix. That means accepting the same responsibilities.

From our perspective, governments need to know that the vehicle fleet on their roads has minimum standards of road worthiness and emission levels and there are only two ways of doing this – roadside checks – and regular testing.

With regards to emissions, cars are taxed in the UK based on their CO2 levels and the annual MoT ensures that those levels are monitored.

Now that the motorcycle industry will be required to do the same for motorcycles, scooters and mopeds, it seems reasonable to expect that this sector of vehicles will be afforded the same rights.


There is possibly another argument that needs addressing which is competition.

We in Europe expect and demand quality products. We expect and demand redress if these products are not to the standards that manufacturers promise.

In a global economy, products from other countries such as India, China and Russia must adhere to European standards in order to be allowed into the European markets.  Equally, the European manufacturers must provide a standard over time for our vehicles through warranties.

We as Europeans, have an opportunity to ensure that our standards are of the highest quality, but our opinion is that we, as consumers, can only achieve this by playing the game which includes accepting road worthiness testing.

Links Information

TRAN Committee Draft Report, scheduled for publication by the 7th March, with a deadline for amendments on the 22nd March.

Also scheduled but subject to change, is the Vote in TRAN Committee May 2013 – Vote in Parliament plenary July 2013

Video of the meeting still available go to 16:24:00 – Click Here

Our reporting and quotes are taken from the recording of the meeting and includes interpretation of the original speaker. We have endeavoured to report this accurately.

FIA (Fédération Internationale de l’Automobile) Region 1 –

FIA Region I Briefing on PTI – pdf – 2.5mb

ACEM (European Association of Motorcycle Manufacturers) –

ACEM’s Presentation to Public Hearing  – pdf – 404kb

ACEM’s position on RWT – pdf – 158kb

Library of the European Parliament

A page published on the Library of the European Parliament’s website, gives detailed information on the “Roadworthiness Package”.

From links to the European Commission’s presentation of the three legislative proposals contained in the Roadworthiness Package to overviews, analysis, Stake holder views, NGO views, Producers views, Statistics and EU Programmes and projects.

Library of the European Parliament –  Click Here


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  1. European Parliament – Initial appraisal of a European Commission Impact Assessment

    European Commission proposal on the ‘Roadworthiness Package’

    The European Parliament published in November 2012 a note which, ” seeks to provide an initial analysis of the strengths and weaknesses of the European Commission’s Impact Assessment (IA) accompanying the three proposals contained in its ‘Roadworthiness Package’, communicated in July 2012.

    The Parliament has highlighted issues surrounding data and motorcycles, the commissions assumption on accidents – motorcycles technical defects – is contradicted by other sources.

    In other words the justification of including motorcycles in mandatory Road Worthiness Testing (RWT) is thrown into doubt.

    “Whereas the larger part of the data used by the Commission seem to be sufficiently robust, the basic assumption that better and more frequent technical inspections would lead to fewer defects in vehicles seems not to be supported by evidence at all.

    Moreover, the further link between fewer defects in vehicles and the avoidance of accidents also seems less firmly established.

    With regard to motorcycles, the Commission’s assumption that 8% of accidents involving motorcycles are caused by technical defects is based on a single DEKRA Motorcycle Road Safety Report (2010).

    This seems to be contradicted by other OECD and European Commission statistics, indicating that such a clear relationship between motorcycle fatalities and technical testing of motorcycles might not exist.”

    Time for a rethink by the European Commission, some guidance for the TRAN Committee Rapporteurs as they represent Parliament and part justification for the European Council who have in their ammendments removed motorcycle and mopeds from the proposal.

    Initial appraisal of a European Commission Impact Assessment – Click Here – pdf – 112kb

  2. What about MEP Brian Simpson and the European Transport Safety Council (ETSC) – hey??

    The ETSC is well known for its zealous stance on Road Safety, which of course is their right and indeed reflects their aims and objectives. The Executive Director of ETSC was invited to speak at the public hearing of the TRAN Committee on January 22nd, 2013 in relation to the proposal on RWT.

    Nothing wrong with that – they were invited to speak as a Civil Society organisation.

    However what does raise an eyebrow (that would be an understatement) is the fact that the Chairman of the TRAN Committee MEP Brian Simpson – who one would assume should remain impartial and possibly declare any interest at the beginning of the meeting – with regards to organisations putting forward positions at this meeting – is the fact that Mr Simpson is on the Board of Directors of ETSC.

    The ETSC position on road worthiness testing is: Here pdf

    It seems to us that this turns relations between the ETSC lobbyists in Brussels and politicians such as Mr Simpson into a very cosy wink, wink, nudge, nudge………….. Say no more!!

  3. FEMA Reports on TRAN Committee Meeting

    In the European Parliament the responsible Transport Committee has started the discussions on the proposal for a new regulation on roadworthiness testing (RWT). Upon invitation industry stakeholders presented their views to MEPs and most lobbied in favour of strict and frequent RWT in Europe. Only the car drivers association FIA expressed doubts about the effectiveness of extended RWT.

    FEMA (Federation ofEuropean Motorcyclists Associations) was not invited to speak.

    The Federation of European Motorcyclists’ Associations (FEMA) had asked TRAN Chairmen Brian Simpson as well as Werner Kuhn, TRAN Rapporteur on RWT, to be included into the list of speakers but has not received a reply. The association of car users FIA therefore resulted as the only body representing the concerns of European citizens. All other speakers represented car and motorcycle manufacturers (ACEA and ACEM), the RWT industry (CITA and EGEA) and road transport companies (IRU). The ETSC was presented as “Civil society organization” but is in fact representing national road safety institutes as well as test centres (e.g. TÜV).

    The views of FEMA

    FEMA is disappointed that the biased positions of the testing industry are still being taken into account while the views of riders remain ignored. The prejudiced studies and data provided by CITA and its members have already been taken for granted by the European Commission. The European Parliament as the only legislative body in Europe directly representing European citizens must not make the same mistake.

    The countries of Europe are different. In Germany it is possible to race on a motorway without speed limit, riding in Sweden is only possible during several months of the year due to weather conditions. Denmark, Norway and the Netherlands have better accident statistics than Germany – even though they do not have RWT for motorcycles.

    Along with the Council FEMA calls to turn the proposed regulation into a directive and to leave the decision to the Member States on whether and how often mopeds, scooters and motorcycles are to be presented for periodic testing.

    Original Source – Read the full article at FEMA – Click Here

  4. FIA expresses concern on Periodical Technical Inspection proposals at EP hearing

    The FIA presented the users’ perspective to MEPs on a new proposal for EU-wide minimum standards for technical checks on cars, powered two-wheelers, and trailers and caravans, at a EP Transport committee hearing today (22 January 2013).

    Ms Laurianne Krid, Director of Policy for the FIA Region I office, said that while the FIA is fully supportive of efforts to improve road safety, research by member Clubs indicates that this proposal is not based on sound evidence, and will not result in the road safety benefits foreseen by the European Commission. As an introduction, she noted that in Switzerland the government is considering changing the periodicity of inspections to 7-2-2 from 4-3-2-2 without expecting any significant impact on either safety or the environment. Unlike the situation in most EU countries where testing is carried out by commercial bodies such as the German Motor Vehicle Inspection Association (DEKRA), testing is carried out by public bodies in Switzerland.

    Ms Krid said there was a need to differentiate between the primary cause of the accident and aggravating factors, in which case it has been demonstrated that technical defaults are the primary cause of less than 1% of accidents. In Germany, official road accident figures from 2010 showed that only around 0.42% of the accidents were linked to technical failures (two-thirds of these were caused by tyre failure which may not be resolved by increased PTI). “There is no sound evidence that increasing the frequency of checks will help”, said Ms Krid.

    Similarly, for powered-two wheelers and trailers, Ms Krid said that a lack of sound evidence to prove that technical defects are at the origin of accidents was the reason the FIA could not support the Commission’s proposals for these vehicle categories. She noted that these categories cover a much lower mileage in general and said that this should be taken into account.

    The FIA is calling for:

    The safety impact of PTI to be carefully weighed against other measures such as making safety technologies mandatory;

    More specific data to be collected on all vehicle categories, and specifically on newly introduced categories;

    The minimum frequency to be 4-2-2- with member states free to go beyond this requirement;

    The original form of a directive to be kept, allowing Member States flexibility to adapt to national situations.

    On mileage fraud, Ms Krid welcomed the Commission’s acknowledgement of the mileage fraud problem as a first step, but did not believe it would be sufficient to tackle the issue successfully. Here, the FIA supports technical measures to make tampering more difficult.

    Several MEPs raised concerns about increasing costs for vehicle owners, but also for authorities which would be obliged to invest in control equipment and better training for inspectors.

    Parliament’s rapporteurs on the threefold “roadworthiness package”, Mr Kuhn (EPP, DE), Mrs Sehnalova (S&D, CZ) and Mrs Savisaar (ALDE, ET) will prepare draft reports for a vote in the Transport and Tourism Committee scheduled for the end of May.

    Original Source : FIA (Fédération Internationale de l’Automobile) – Click Here

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