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Modifying Pre-ADR Vehicles
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Author:  GT mowog [ Mon Jan 31, 2011 8:25 am ]
Post subject:  Modifying Pre-ADR Vehicles

There is a common misconception that modifications to pre-ADR Vehicles are exempt from Engineering Certification. Mostly, on this forum, is has been around the fitting of after-market seats. I post this as it is important information, to avoid a potentially dangerous situation and hassles with insurers and state authorities. For anyone wishing to fit after-market or factory option seats (and carrying out any modifications), you maybe interested in this;-

http://www.rta.nsw.gov.au/registration/ ... v_2007.pdf

Of particular note, it does not give exemption to pre-ADR vehicles. Page 5 in particular talks about after market seats, like for example Cobra's.

Even (Factory) Option seats require 'Owner Certification'.

While I cannot speak for the Certifying Engineers, I think it reasonable to say that it would not be a big deal to obtain certification (for seating), however, without it the vehicle is considered un-roadworthy

I don't make these rules, so don't take them up with me.

NOTE: These are specific to NSW however, things would be similar in all states

Author:  superSeven [ Mon Jan 31, 2011 9:13 am ]
Post subject: 

For Vicroads it is a little more well defined. Anything pre-adr (1969 for seats it seems) does not require an approval certificate.

Quote:
Replacing seats
An Approval Certificate is not required for a replacement seat provided:

* the seat is offered by the manufacturer as an option and is replacing and existing seat
* the original seat mountings are used
* appropriate seat belts are fitted.

An Approval Certificate is required if:
* the replacement seat was not offered by the manufacturer as an option
* the vehicle was manufactured on or after 1 January 1969.

For more information about adding seats, see the Vehicle Standards Information No.19 - Additional or replacement seats [PDF 174KB, 2pp]


from the linked PDF for more information:
Quote:
For vehicles manufactured before 1969 the seat anchorages must be of at least equivalent strength to the original anchorages. A VASS member should be consulted if there is any doubt regarding the strength of the anchorage or any part of the seat installation.


Now under "An Approval Certificate is required if:", it does not state whether it is an AND or OR clause.

GT, there is VERY minimal information in the RTA document, do you have another link which clarifies the non-exemption of pre-ADR vehicles?

From your link:
Quote:
Owners should ensure that the seat and its anchorages comply with any applicable ADR requirements (possibly by certification from the seat manufacturer or by an engineering signatory) and the appropriate seat belts are fitted to all seating positions.
Vehicle Standards Bulletin No. 5 issued by DOTARS covers requirements for the manufacture of additional seats.


I don't see where it mentions pre-adr vehicles at all?

Author:  GT mowog [ Mon Jan 31, 2011 11:22 am ]
Post subject: 

superSeven wrote:

GT, there is VERY minimal information in the RTA document, do you have another link which clarifies the non-exemption of pre-ADR vehicles?

I don't see where it mentions pre-adr vehicles at all?


Exactly. It is a blanket requirement, covering ADR and pre-ADR vehicles. Things do seem considerably easier in Vic.

Author:  simon k [ Mon Jan 31, 2011 11:48 am ]
Post subject: 

GT mowog wrote:
Things do seem considerably easier in Vic.


as per usual... it's suck to live in NSW

Author:  GT mowog [ Mon Jan 31, 2011 3:06 pm ]
Post subject: 

GT mowog wrote:
superSeven wrote:

GT, there is VERY minimal information in the RTA document, do you have another link which clarifies the non-exemption of pre-ADR vehicles?

I don't see where it mentions pre-adr vehicles at all?


Exactly. It is a blanket requirement, covering ADR and pre-ADR vehicles. Things do seem considerably easier in Vic.


Got this email from the RTA;-

Aftermarket seat and installation require an engineers report, regardless of age or ADR's.

Regards

RTA Tech Enq

Author:  winabbey [ Mon Jan 31, 2011 3:06 pm ]
Post subject: 

simon k wrote:
as per usual... it's suck to live in NSW

... but great if you live on the border and can choose which State's regulations to use. :)

Author:  awdmoke [ Mon Jan 31, 2011 3:10 pm ]
Post subject: 

It's important to remember the current regulations only apply to mods being carried out now, not to modifications that were carried out years ago :wink:

Author:  Morris 1100 [ Mon Jan 31, 2011 3:20 pm ]
Post subject:  Re: Modifying Pre-ADR Vehicles

GT mowog wrote:
Even (Factory) Option seats require 'Owner Certification'.

I bet that is tough. You might get a really mean owner that likes to make things hard on himself. :roll:

What it means is you can fit the optional seats and there is no paperwork to be done. Quite simple. No hoops to jump through. No problems.

Author:  superSeven [ Mon Jan 31, 2011 7:07 pm ]
Post subject: 

GT mowog wrote:
GT mowog wrote:
superSeven wrote:

GT, there is VERY minimal information in the RTA document, do you have another link which clarifies the non-exemption of pre-ADR vehicles?

I don't see where it mentions pre-adr vehicles at all?


Exactly. It is a blanket requirement, covering ADR and pre-ADR vehicles. Things do seem considerably easier in Vic.


Got this email from the RTA;-

Aftermarket seat and installation require an engineers report, regardless of age or ADR's.

Regards

RTA Tech Enq



But the quote from the RTA PDF states "Applicable ADRS", there are no applicable ADRs for a pre-ADR vehicle??? Which ADR do you use? The closest by date? The latest? That just doesn't make sense. It also states "possibly by certification from the seat manufacturer or by an engineering signatory", POSSIBLY, not mandatory requirement.

I'd be interested to see his response to the above points, as his POV is in direct conflict with their documentation.

edit: could you please forward me this RTA Tech Eng's email, as I'm moving to NSW in a month and want to install WRX seats into my pre ADR mini.

Author:  GT mowog [ Mon Jan 31, 2011 8:14 pm ]
Post subject: 

superSeven wrote:

I'd be interested to see his response to the above points, as his POV is in direct conflict with their documentation.

edit: could you please forward me this RTA Tech Eng's email, as I'm moving to NSW in a month and want to install WRX seats into my pre ADR mini.


http://www.rta.nsw.gov.au/cgi-bin/index ... dback.form

I'll post the tech's return email address in the morning, I don't have it on this PC. Make your own enquiries.

Author:  superSeven [ Mon Jan 31, 2011 8:24 pm ]
Post subject: 

GT mowog wrote:

http://www.rta.nsw.gov.au/cgi-bin/index ... dback.form

I'll post the tech's return email address in the morning, I don't have it on this PC. Make your own enquiries.


done, cheers.

Author:  david rosenthal [ Mon Jan 31, 2011 10:07 pm ]
Post subject: 

when I just re-built a moke for a bloke ,the moke had NSW reg where he bought it from and a cert of inspection.
It had different seats fitted and when bugsy, the owner took it for inspection for SA reg, the "inspector" read off the usual list and asked if the bolts securing the seat were 8mm. He had no idea that 5/16" are the same size.
That car got passed with out any problems ,but the inspector had no idea.
I saw at least 10 problems with it but he never picked one.
Register them here as SA laws are fairly slack. Just tick off a few items off the ADR list and tell them you have up-graded and they are happy as long as the car is fairly "original"

Author:  GT mowog [ Tue Feb 01, 2011 3:26 am ]
Post subject: 

GT mowog wrote:
I'll post the tech's return email address in the morning, I don't have it on this PC. Make your own enquiries.


The email came back on return email address 'Technical Enquires'
This is the full email;-

GT

Aftermarket seat and installation require an engineers report, regardless of age or ADR's.

Regards

RTA Tech Enq

-----Original Message-----
From: GT mowog
Sent: Monday, 31 January 2011 12:53 PM
To: Technical Enquiries
Subject: INTERNET FEEDBACK


Date: 31/01/2011
------------------------------------------------------------------

First Name
GT

Last Name
Mowog

Email address
GT mowog

Message Type
Question

Subject
Vehicle regulations

Message
Hi, A question of fitting after-market seats. If I were to fit after-market seats, that were not manufactured by the vehicle manufacturer to a car that was manufactured prior to the ADR scheme coming in to effect (ie 1969 model), would it require engineering approval certification? Thanks.

Before printing, please consider the environment.

IMPORTANT NOTICE: This e-mail and any attachment to it are intended only to be read or used by the named addressee. It is confidential and may contain legally privileged information. No confidentiality or privilege is waived or lost by any mistaken transmission to you. The RTA is not responsible for any unauthorised alterations to this e-mail or attachment to it. Views expressed in this message are those of the individual sender, and are not necessarily the views of the RTA. If you receive this e-mail in error, please immediately delete it from your system and notify the sender. You must not disclose, copy or use any part of this e-mail if you are not the intended recipient.

Before printing, please consider the environment.

IMPORTANT NOTICE: This e-mail and any attachment to it are intended only to be read or used by the named addressee. It is confidential and may contain legally privileged information. No confidentiality or privilege is waived or lost by any mistaken transmission to you. The RTA is not responsible for any unauthorised alterations to this e-mail or attachment to it. Views expressed in this message are those of the individual sender, and are not necessarily the views of the RTA. If you receive this e-mail in error, please immediately delete it from your system and notify the sender. You must not disclose, copy or use any part of this e-mail if you are not the intended recipient.


David, I did once have most of our cars and trucks regoed in SA, not only more sensible, a LOT cheaper, ie at the time I was getting 3 cars regoed in SA for the price of 1 in NSW!

As simon says :lol:
simon k wrote:

as per usual... it's suck to live in NSW

Author:  Lillee [ Tue Feb 01, 2011 10:14 am ]
Post subject: 

FROM RTA PDF ABOVE:

Quote:
Owner certified minor modifications are generally those modifications which were optional equipment for the vehicle concerned. Owner certified modifications also include some non-standard modifications of a minor nature which do not affect the level of safety, strength or reliability of vital systems such as brakes and steering. These modifications have little or no impact upon the vehicle’s level of compliance with the Australian Design Rules.Examples of minor (owner certified) modifications are:

�� Engine changes where the capacity increase is less than 15% above the maximum size engine available for the
vehicle (providing no major structural modifications are necessary and where noise and/or exhaust emission ADRs apply, all standard equipment such as carburettors, exhaust systems, exhaust gas recirculating valves,
oxygen sensors and catalytic convertors relating to noise and emission control are retained and operate correctly).

�� The fitting of a proprietary sunroof (if the modifications are of a minor nature only).

�� Fitting a ‘package’ available as optional equipment for the vehicle (eg front disc brakes, power steering, alternative transmission and bucket or bench seats).

�� Additional lighting eg fog & driving lights.

�� Alternative wheels and tyres within the owner certified limits set by the Authority (see Vehicle Standards Information Sheet No. 9 Guidelines for alternative wheels & tyres).

�� Fitting of handling enhancing suspension components such as roll stabiliser bars and up-rated shock absorbers.

Major modifications which fall outside the category of minor (owner certified) modifications require submission of certification by an RTA recognised engineering signatory. This is usually in the form of an Engineering certificate prepared by the signatory.


Cobra seats are bucket seats and according to this is classified as a Owner Certified Modification which has "little or no impact" on ADR. In fact it says plainly that you only need engineers certificate if it does not fall into these categories.

Although they were not "optional extras" if using original Cobra subframes and attached to original seat mounting brackets with no modification to mounting points, I would argue in court that this is a "minor modification which has little or no impact on safety" and is no less safer than the original 40yr old seats mounted to same said mounting points since the seats are of the same weight, dimensions and geometry. Cannot say the same for any other seat not designed to fit on original mounting brackets.

In general: if you have to weld anything, Engineers Certificate.

Author:  GT mowog [ Tue Feb 01, 2011 12:15 pm ]
Post subject: 

Fine lillee, however for the cost of a phone call or email to the RTA or a Certifying Engineer, rather than bury your head in the sand, make the enquiry for yourself.

BTW, the Engineering Certification that I have received for After Market Seats (Cobra's in fact) was easy as and quite cheap, there shouldn't be anything to fear from it.

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