ARTSA Minister Gay ESC letter 20 Feb 14

Australian Road Transport Suppliers Association Inc. 20th February 2014 The Hon. Duncan Gay, Minister for Roads and Ports, Parliament House, Sydney, NSW. PO Box 2230, Hawthorn LPO Vic 3122 Australia Phone: 03 9818 7899 Fax: 03 9818 6534 Email: [email protected] Web: http://www.artsa.com.au Dear Minister Gay, Without urgent change to truck safety levels the problem of heavy truck roll-­‐over crashes will continue for another decade. Australia is experiencing an epidemic of heavy-­‐truck roll-­‐over crashes. Electronic Stability Control on heavy trucks and trailers could significantly reduce loss-­‐of-­‐directional-­‐control incidents. I was the lead consultant to the National Transport Commission for the National Heavy Vehicle Brake Strategy1. The strategy proposed that Electronic Stability Control (ESC) be mandated on new vehicles by 2015, which is no longer practical. In fact the ADR development process for truck and trailers is stalled. Whilst dangerous goods tankers now have ESC technology routinely installed, this is being done with no lead from the ADRs. There are no national performance standards for truck and trailer ESC. Truck and Trailer Electronic Stability Control with a roll-­‐stability feature (which is called RSP) is now a proven system. It slows a vehicle when a side-­‐slide or roll-­‐over is likely to occur. This technology has been mandated on new trucks and trailers in Europe2. The US NHTSA has published a notice of proposed rulemaking3 that will mandate ESC on new motive trucks soon. Europe mandated the precursor technology ABS, on heavy trucks and trailers in 1991 and the US and Canada did so in 1997. Victorian crash data4 for Feb-­‐September 2012 shows that that about 30 % of 145 serious crashes by heavy trucks are roll-­‐over crashes. A further 12% occurred when the vehicle left the road at a bend. The 2013 National Transport Insurers safety report5 shows that more than 25% of significant claims that it pays out are due to inappropriate speed for conditions. The 2011 NTI report6 states that 7 out of 10 major payouts involve a single heavy vehicle! The truck driver will usually be blamed for these crashes however, the inherent safety of the truck is rarely questioned. Inherent truck safety depends upon regular uptake of proven technical progress. ESC should be mandated. Various Australian jurisdictions have mandated ESC in high-­‐risk situations. VicRoads requires B-­‐double log jinkers that operate on the Black Spur highway7 to have trailer ESC. This requirement have been a complete success. After a coronial inquiry into the deaths of four people, NSW coroner Forbes has recommended that a stability control system be required on all vehicles carrying DG8. The Mona Vale crash has further highlighted the issue of tanker stability. The Competent Authorities Panel, which overviews movements of dangerous goods has now decided in principal to mandate ESC on new dangerous goods trucks and tanker. However, it is grappling with the issue that there is no national performance standard. ESC is now a mature technology for the trucks and trailers. It can be retrofitted on trailers but not on motive vehicles. ESC incorporates a roll-­‐stability function with proven effectiveness for preventing truck and trailer roll-­‐overs. As a guide, when tested at 60 km/h, an additional 10 km/h safety margin is gained if prime-­‐movers have ESC with RSP. If the technology is used on trailers only, the added safety margin is about 5 km/h. If ESC with RSP is on both the truck and trailer, the safety margin increase to about 12 km/h.9 Australia lags well behind the rest of the world because the National Road Safety Strategy1 is not forcing change to the Australian Design Rules. Actual truck crash performance does not inform the ADR development process. The relevant brake rules (ADR’s 35 –truck braking and 38 – trailer braking) are currently under review11 . Rule 35 was recently amended to mandate ABS on motive vehicles from 1 July 2014. Amendments to rule 38 (trailers) has been delayed because of special pleading by the livestock haulage sector. This sector argues that ABS will be unreliable and / or inconvenient12,13. The arguments being used are the same ones that were used to stop ABS being mandated on B-­‐double tailers back in the early 1990s. The NTC retreated under pressure from the off-­‐road sector of the transport industry. This opposition also explains why ABS was never mandated on single dangerous-­‐good tankers despite being required on B-­‐double dangerous goods tankers. Sadly, the livestock haulage industry has an appalling roll-­‐over safety record17. Many of its crashes are roll-­‐overs that occur on sealed main roads and highways. ESC with RSP could greatly help this sector. The trucks most vulnerable to roll-­‐over are those that carry shifting loads with a high centre of mass. Examples are fuel-­‐haul and milk-­‐haul tankers, concrete agitators and livestock carrying crates. ESC with roll-­‐stability is a proven technology in the fuel-­‐haul and milk-­‐haul sectors. Whilst adoption in these sectors is not universal, it is common. In 2011 the National Bulk Tanker Association showed admirable leadership14 by calling upon government to mandate ESC with roll-­‐stability protection. The fuel-­‐haul industry has a long experience of ABS on trucks and trailers because it is mandated on new and in-­‐service B-­‐double DG tankers. This sector has progressed to ESC with RSP. Originally ABS was required on all B-­‐double trailers15 however, the requirement was later dropped because of conservative opposition. Consequently 2 Australia lost a pathway to advanced stability control technology. Australia now lags behind other developed countries with uptake of the next generation technology – ESC with RSP. In 2007 the National Transport Commission released the National Heavy Vehicle Brake Strategy1. This proposed that Antilock brakes be mandated on new trucks and trailers by 2011 and Electronic Stability Control by 2015. Whilst this strategy was agreed to be Federal and State authorities, the Federal Department of Infrastructure and Transport has not got around to implementing the strategy. Virtually nothing has been achieved. The off-­‐road sector of the industry has been fighting the proposals and has effectively delayed rule development. This is a failure of leadership. How can Australia be so far in front with high-­‐productivity vehicles and so far behind with adoption of fundamental safety technology ? Because our ADR amendment procedures only look at cost-­‐benefit analysis. Strategic planning and leadership are of little importance in this domain. Without intervention by state and territory governments, Australia will continue to lag twenty years behind other developed countries. (Even China mandated ABS on new heavy vehicles about 5 years ago!). The ADR revision process is not being driven by road-­‐safety considerations and there is little vision. I call upon state and territory transport ministers to announce that Electronic Stability Control with a roll-­‐stability function, will be required in their jurisdictions on new trucks, buses and trailers from 1 January 2016. Australia badly needs an introduction date to work towards. This will drive change on new heavy-­‐vehicles in the intervening time. There is a precedent for states forcing change to the Australian Design Rules. In 2008 Victorian premier Brumby announced that ESC and side-­‐curtain airbags would be required on new passenger cars. Design rule change followed soon after -­‐ ADRs 31/02 and 73/00 were developed. A similar action by state and territory transport ministers in the truck and bus sectors has the potential to reduce heavy-­‐vehicle road trauma by 30 %. Truck driving is the most dangerous occupation in Australia. We can do much better. Yours Sincerely Dr Peter Hart Chairman, Australian Road Transport Suppliers Association. [email protected] 0438 339 413 3 References: 1
National Heavy Vehicle Brake Strategy, Released by the NRTC in 2007. National Road Safety Strategy is at http://www.atcouncil.gov.au/documents/files/NRSS_2011_2020_15Aug11.pdf Tables are at: http://www.ntc.gov.au/DocView.aspx?DocumentId=01797 Table 3 & 4 follow. Only one of these proposed changes has been implemented. ADR 35/04 was signed off by Assisting Minister Thistlewaite in August 2013. It requires ABS on motive trucks by 1 July 2014. 4 5 2 Europe Mandates ESC on Heavy Trucks 6 7 8 3 USA Proposed Rule Making 4 Victorian HV truck crash analysis compiled by VTA. Based upon data supplied by Vic Police for serious crashes that occurred between 07Feb2012 and 13September 2012. 145 crashes in total. Report can be supplied upon request. 9 5 NTI Accident report 2013-­‐09-­‐16 http://www.nti.com.au/supporting/trucking/latest-­‐report.php A graph from the 2013 NTI Safety report showing principal causes of HV crashes in 461 serious incidents (> $50k payout) involving heavy vehicles. The green bars are lower than might otherwise be expected because 4% of payouts were due to the Queensland floods. 6 NTI Accident report 2011 http://www.nti.com.au/files/files/NTARC/2011MajorAccidentInvestigationReort_v
10_WS1.pdf 10 from the NTI Report 2011. Most single heavy vehicle crashes are not fatals and so do not show up in the premier crash statistics. This is one reason why they are effectively being ignored. If 70 % of heavy vehicle crashes are single-­‐vehicle crashes, the question of whether the trucks are well suited to the roads should be investigated. 7 Presentation at Freight Week Victoria, by Mr Russell Greenland, VicRoads Mr Greenland is the Manager of on road services for much of Victoria. http://www.freightweek.com.au/Portals/6/Documents/Presentations%20for%20web/
ER%201330%20Greenland.pdf 11 8 Magistrate Forbes Coronial Report is at: http://www.coroners.lawlink.nsw.gov.au/agdbasev7wr/_assets/coroners/m40160
1l3/15_bridge,makeely,jordan,david&carolan,david.pdf 12 13 9 Chairman’s Technical Column – Prime Mover Magazine, March 2013. http://www.artsa.com.au/articles/2013/2013_03.pdf 14 15 11 Regulation Impact Statement – Heavy Vehicle Braking – Phase 1. Federal Department of Infrastructure and Transport http://www.comlaw.gov.au/Details/F2013L01570/5844ef1f-­‐e853-­‐4943-­‐a0fa-­‐
a5d8c117424d 12 Minutes of the Australian Livestock and Road Transport Association, late June 2013 Based upon this submission, Assistant Minister Thistlethwaite decided to not approve the proposed amendments to ADR 38/04. 16 13 Exemptions that are proposed in response to pushback from the off-­‐road sector 14 Public declaration at the Joint NBTA & ARTSA Meeting held on 5 May 2011 at the Brisbane Truck Show. 17 15 ABS study conducted by NTC and DOTARS, 1996.
www.ntc.gov.au/filemedia/.../AntiLockBrakingSystemsHeavyVehic.doc
18 Decision making based soley on cost-­‐benefit analysis is a management approach. It overrides leadership considerations and strategic planning. This is why Australia lost the opportunity to be in front at this time. 16 Google Australia Search + Livestock Transport + roll-­‐over crashes + 2013. Further details of roll-­‐over crashes can be provided. The following page lists some recent crashes on sealed roads: 19 20