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 Compliance, ADR testing & you




                                 as mud

                                 I am in blood/Stepped in so far that, should I wade no more,
                                   Returning were as tedious as go o’er. Remember Macbeth?
                                    Well, that Scottish play’s nothing compared with ADRs.




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084   twowheels                                 Words by ALEC SIMPSON, photography by MICHAEL DRABIKOWSKI
 c
                  hris Drabikowski fires the yet-to-
                  be-released-in-Australia Moto
                  Morini Corsaro down the main
                  straight at Sandown Raceway.
 It’s impressive to watch, but he is not doing
 it for fun. He is recording performance data
 so he can certify that the bike complies with
 the Australian Design Rules (ADRs), and be
 approved for sale in Australia. It is a process
 that all motorcycles and scooters to be used on
 the road in Australia must go through.
     Unfortunately for the manufacturers, they
 must also meet numerous other different
 standards that exist worldwide, even within
 the same jurisdictions. In Europe, for example,
 there are three standards all with different
 levels of validation for certification: the United
 Nations Economic Commission for Europe
 (UN/ECE), the European Economic Community
 (EEC) and the European Commission (EC). So
 manufacturers have to choose which ones they
 will design their motorbikes and scooters to
 comply with. That is a decision based on the
 grisly reality of economics, and those countries
 with the largest markets are the ones whose
 rules and regulations are met. Australia is a
 small market by world standards, yet has its
 own set of design rules.
     The future lies in the ‘global harmonisation’
 of design standards, hardly exciting stuff at first
 glance, but if you are a motorcycle manufacturer      an engineer with DOTARS, describes the purpose
 or importer, it could be. Ultimately it means that    of ADRs as providing a minimum level of safety.
 anything produced anywhere in the world can               “Ideally the ADRs are about introducing
 be sold anywhere else, as it all meets the same       legislation where market forces can be
 standards for safety and performance. It’s not        demonstrated to have failed. It’s not about
 here yet, but the world’s motor vehicle regulatory    introducing regulation for its own sake.”
 bodies are trying to move that way and, as more           “ADRs are basically the standards that
 companies operate to minimum quality standards        determine the minimum requirements for the
 such as ISO9001, it is probably inevitable.           bikes and scooters,” Chris Drabikowski, once off
     It’s also a concept that Australia’s regulatory   the Moto Morini, explained. “There is more to
 body for motorcycles and scooters, the                it, most companies go to much more expense
 Department of Transport and Regional Services         to determine whether a bike complies. Litigation
 (DOTARS) has signed up for. Europe and                means companies must show they have exercised
 Australia, along with New Zealand and South           a reasonable duty of care, so it is better for them
 Africa, are adopting UN/ECE standards in a            to do something that will prevent a particular
 move towards ‘global harmonisation’.                  type of accident happening, rather than meet
     The UN/ECE standard is probably the most          minimum prescribed standards. We just test to
 stringent of all the European standards in terms      the minimum standard.”
 of the validation and verification processes              Yet when you ask how that minimum
 involved. It requires that tests take place within    standard was determined in the first place,
 certain parameters, including such things as          things can become a bit muddied. I had                                                                                                                     said Chris. “It would pass the ADR test but, as       common sense. Take the issue of the single,
 temperature range and humidity.                       wondered if it was just a power-hungry French                                                                                                              engineers, we know that it would exceed the           rectangular headlight that butchered the
     Yet by adopting a uniform, global system of       bureaucrat in a European commission making                                                                                                                 material’s endurance limit and fail from fatigue in   appearance of Ducati’s beautiful 916 when they
 standards manufacturers would only have to            arbitrary declarations, or was there some                                                                                                                  a small amount of time. In cases like this we have    were first sold in Australia in the mid-’90s.
 conduct one set of tests, and produce one set         science to it. Allan Jonas from DOTARS accepts            “If you start to trace a rules origin there   They are not concerned with the durability of      to go back to the manufacturer or importer and            “Unfortunately the Ducati 916, while
 of supporting documents for each model.               that sometimes the basis for some standards is        is usually some basis for it,” agreed Chris       items in the real world – while they determine     tell them it is unacceptable.”                        complying with the European rules, was ahead of
     It has potential advantages for Australian        difficult to decipher.                                Drabikowski. “It may have happened a long         where things like indicators and headlamps are        Chris also talked of scooters whose engines        the Australian rules...” commented Allan Jonas.
 riders in terms of product choice, as our                 “For some of the older rules, the reasoning       time ago and the basis for its instigation may    located to ensure they can be seen by other        expired at the completion of the last test run,       “The ADRs stated that if one headlight was used
 design rules change to match those of other           behind them has been lost. It can be difficult        have changed. But in Australia, to change the     road users, they don’t concern themselves          and bikes with clutch cables that rubbed on           for low beam, it had to be located on the bike’s
 industrialised countries, but could cost in terms     to compare the pre- and post-regulatory               rule you will have to have the agreement of all   with how long they will last outside of the        hot exhaust pipes. Yet even if examples like          centreline. The Ducati 916 had two headlights,
 of product support and back-up.                       environments, as design and materials have            the States, and if one person representing one    test period, or with many other aspects of the     this imply regulations are lacking, regulation        but only one headlamp operated on low beam
     Yet all this discussion about where ADRs are      changed so much... Brake regulations were             State says ‘No’, it won’t change.”                motorcycle or scooter’s design.                    is also a significant obstacle to new ideas that      and it was off the bike’s centreline. As such it
 going never seems to explain what it is that          introduced in 1935 and today’s requirements              It would be wrong to think of ADRs as              “We have had bikes with brake arrangements     change or revolutionise the way we might do           didn’t comply with the rules at that time.”
 design regulations are meant to do. Allan Jonas,      are vastly different from then.”                      consumer protection in the conventional sense.    that a six-year-old would have designed better,”   something. At times this can seem to defy                I couldn’t help but ask how he thought some




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086   twowheels
                                                                                                                                                                                                                       “The obvious one was the ADR requirement            lights comply with the regulation.
                                                                                                                                                                                                                    that the top of the chain drive be covered by a            If reading that made you feel like you were
                                                                                                                                                                                                                    chainguard running along the top from the front        about to drown in some bureaucrat’s word trap,
                                                                                                                                                                                                                    sprocket to the middle of the rear sprocket.”          imagine what it’s like trying to decipher and
                                                                                                                                                                                                                       Chris fabricated a prototype ADR-compliant          interpret the complex stuff.
                                                                                                                                                                                                                    chainguard, which was then shown to the                    At the back of Chris’s workshop is a small
                                                                                                                                                                                                                    factory. Moto Morini then designed and                 Chinese scooter an importer submitted for
                                                                                                                                                                                                                    produced a chainguard that complemented                testing eight years ago and didn’t even bother
                                                                                                                                                                                                                    the bike’s design and complied with ADRs               to collect. As it had not been designed with
                                                                                                                                                                                                                    to be fitted to all Australian bikes. Chris            any standards in mind, the cost of testing and
                                                                                                                                                                                                                    remarked that this was an extraordinary level of       modifying components until it met the ADRs
                                                                                                                                                                                                                    commitment on the part of the manufacturer,            was completely prohibitive.
                                                                                                                                                                                                                    for what is a relatively low-volume machine.               “As it hadn’t been designed with certain
                                                                                                                                                                                                                       He pointed out that many manufacturers              standards in mind then it would be an
                                                                                                                                                                                                                    would not have made the effort for such a              enormous task. It would not be impossible but
                                                                                                                                                                                                                    small market. Often it would be left to the            would probably take at least two years and
                                                                                                                                                                                                                    importer to find a local fabricator to make the        loads of money.”
                                                                                                                                                                                                                    unique component, and it would be installed                Today most manufacturers, including the
                                                                                                                                                                                                                    prior to delivery, most likely by the dealer.          Chinese, build their bikes to obtain European
                                                                                                                                                                                                                       Other idiosyncrasies include things Chris           certification, and because they build and
                                                                                                                                                                                                                                                                           design to these standards they must provide
                                                                                                                                                                                                                                                                           supporting documentation that reflects it. This
                                                                                                                                                                                                                                                                           makes it easier for engineers like Chris.
                                                                                                                                                                                                                                                                               “I then determine what I can use and what
                                                                                                                                                                                                                                                                           is irrelevant as well as what is missing that is
                                                                                                                                                                                                                                                                           required for ADR compliance. For those items
 forthcoming scooters such as the Vectrix electric    standards. This means importers can provide                                                                                                                                                                          that are missing I must contact the factory for
 scooter and Piaggio’s new three-wheeled MP3          the supporting documentation in any of the                                                                                                                                                                           more documents or drawings for evaluation or
 would fare under the current regulations.            formats and be issued with a compliance                                                                                                                                                                              complete the testing here.”
     “The only way really is to amend the ADRs to     certificate. No additional testing, interpreting or                                                                                                                                                                      Of course, this leads you to ask what sort of
 accommodate the set-up ... in Europe the MP3         re-writing is required.                                                                                                                                                                                              testing is usually done here, assuming a large
 is treated as a two-wheeled motorcycle. The             Ironically the free market is a double-edged                                                                                                                                                                      proportion of the testing has been correctly
 modified EU regulations allow it to be treated       sword as lower barriers to entry mean more                                                                                                                                                                           documented and so doesn’t need to be re-done.
 that way. So in Europe now, any set-up where         entrants, some of whom are unscrupulous,                                                                                                                                                                                 “We recommend the re-testing of bikes
 the centreline of the two wheels is less than        with poor financial backing and short-term                                                                                                                                                                           in regards to brakes, noise and speedometer
 450mm apart may be considered as one wheel.”         goals. Take a look at what’s happened in                                                                                                                                                                             accuracy and basically go over them to ensure
     Anthony Chrisis from EVO Compliance is           the unregulated off-road sector with the                                                                                                                                                                             they meet the requirements for controls and
 conducting the ADR compliance program for            Three Amigos Outdoor Gurus company in                                                                                                                                                                                lights and so on.”
 the Vectrix electric scooter. In this case the       South Australia. The SA Consumer Affairs                                                                                                                                                                                 In Australia there are three different types of
 ADRs have compliance requirements that don’t         commissioner has warned people not to deal                                                                                                                                                                           approvals and, while all the standards must be
 reflect the new technology involved.                 with these importers of non-ADR-compliant                                                                                                                                                                            met, the difference lies in the levels of evidence
     “One of the most amusing things,” he said,       Chinese motorcycles, scooters and ATVs,                                                                                                                                                                              that must be provided to support the claim of
 “is that the ADRs require a stationary noise test,   because they misrepresented consumer warranty                                                                                                                                                                        compliance. Full Volume compliance is the most
 even from an electric scooter. Vectrix hadn’t        rights [see Lowdown, tw 0707].                                                                                                                                                                                       stringent and evidence of compliance must be
 done one because they make no noise. So it              Paul has also experienced the problems that                                                                                                                                                                       given using the normal methods described in
 now has had engineers prove that it makes no         can result from products specially modified to                                                                                                                                                                       the ADRs. Calibration records must be kept for
 noise on calibrated test equipment.”                 comply with ADRs. In order to comply with the                                                                                                                                                                        all testing equipment and audits are carried
     Paul Nobbs from Stoney Creek Powersports,        Australian-specific LA scooter requirement of                                                                weeks of documentation approval and is           described as “the German factor” or things that        out to ensure compliance with regulations
 which imports TGB scooters, Sachs, SCP, MZ,          a 50km/h maximum speed, one of his scooter                                                                   done by a DOTARS representative. During          have become lost in translation, as the various        regarding testing equipment. Low Volume
 Benelli and now Moto Morini, has had a lot to        manufacturers had to source a special ignition                                                               this inspection all the submitted details are    European Union (EU) states have negotiated             compliance requires less evidence and is growing
 do with the ADR compliance process.                  (CDI) unit. A large number of warranty claims                                                                cross-checked on the bike to ensure they are     their way through various rules.                       as companies producing small runs of choppers
     “ADRs are aligned with the UN/ECE                associated with stator failures on the model                                                                 the same, including part numbers on such             On the Moto Morinis, this manifested itself        seek compliance approval. At the other end
 standards, which at this point are the least         ensued. After months of frustration it was                                                                   things as indicator lenses and mirrors. Once     in the hazard lights. In Australia you are not         of the spectrum, the Individually Constructed
 popular standard, sort of like the BetaMax           determined that the special CDI unit was the                                                                 the inspection is complete it may take another   required to have hazard lights, but if you do they     Vehicle (ICV) doesn’t require a compliance plate
 video system...                                      cause of the problems.                                                                                       three weeks for the compliance paperwork to      must meet ADR standards. The ADR for hazard            and is inspected by a local engineer.
     “When we decide to import a bike and                “It ... demonstrated how introducing variety                                                              be issued allowing the bikes to be sold.         lights is the same as the UN/ECE regulation, and           In Australia the compliance plate approval
 the manufacturer provides us with a test and         exponentially increases complexity.”                  vehicle can occur within 30 days. However, should         The Moto Morinis arrived in Chris             is written in such a way that the hazard lights        holder is not usually the manufacturer, but
 evaluation vehicle ... we are usually presented         The process of gaining ADR compliance takes        any information be missing or a ‘discussion point’     Drabikowski’s workshop with full European        must work when the ‘engine switch’ is off. ‘The        often the importer. [see Bike Tech, p138 for
 with EEC standard results. We have to say            time and produces delays getting products to          raised the clock starts from the beginning. This is    certification and he described what he is        German factor’ is that the hazard lights on the        a real life example.] This acts as a form of
 ‘Sorry, but I need ECE standard results’. This       market, which in turn costs money. In order to        why it is critical to have high quality and accurate   doing as almost a formality. Yet it will take    Moto Morini don’t work when the ignition key           protection for the importer. It doesn’t stop the
 means the manufacturer has to reassess or            minimise these delays DOTARS has a 30-day             submissions so delays are minimised.                   approximately five months to complete the        is switched off, but they do when the ‘engine          manufacturer selling bikes through someone
 translate results from one format to another.”       service commitment, which means that if all              Once the documentation is approved, a               ADR testing, evaluation and compliance issuing   kill switch’ is off and the ignition is on. As the     else, but it slows them down, as they must
     Paul points out that in New Zealand they         the required documentation is submitted in the        Single Uniform Type Inspection (SUTI) must             process because of differences between the       ‘engine kill switch’ is the device that controls the   obtain their own compliance plate approval,
 have decided to accept all three European            correct manner an inspection of the evaluation        take place. This usually occurs within three           ADRs and the ECE certification process.          starting and stopping of the engine, the hazard        even if it is the same model. In Australia the




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088   twowheels
                                                    and year of manufacture.                                are working with them to ensure that the MP3
                                                       This traceability is used particularly for recalls   will comply with ADRs.”
                                                    and in Australia the importer is responsible               Similarly, Charles Mann from Vectrix said:
                                                    for dealing with any recalls that may occur,            “DOTARS are a good group and make things
                                                    whether they have been instituted by the                very clear about what they need... We are
                                                    manufacturer or the Australian Transport Safety         very grateful that Vectrix follows some of the
                                                    Bureau (ATSB). The manufacturer’s quality               highest quality systems there are, which has
                                                    assurance system that is required as part of            helped fast track us to market. However, I will
                                                    full volume ADR compliance helps manage this            never understand why DOTARS wanted to do a
                                                    process, as Chris Drabikowski pointed out.              stationary noise test.”
                                                       “Some of the newer players wanting to bring             The utopian end result of all this regulation
                                                    in cheap Chinese scooters are surprised at the          is being able to buy any motorcycle or scooter
                                                    level of regulation. But there are much greater         manufactured in the world, comfortable
                                                    responsibilities selling vehicles – it’s not like       in the knowledge it meets all the relevant
                                                    selling bags of potatoes”                               (but yet to be determined) Global Technical
                                                       Paul Nobbs also pointed out that, while              Regulations. These will cover everything from
                                                    we are heavily regulated when it comes                  lighting standards to braking performance. In
 compliance plate approval licence is always held   to roadbikes, off-road bikes that are never             the meantime, engineers like Chris Drabikowski
 by an individual.                                  registered are not subject to any regulation at         and Anthony Chrisis will be wading through
    Then, just when you think it’s all done, you    all and, to use Chris Drabikowski’s expression,         paperwork and testing bikes to ensure our
 realise the inspection process doesn’t end with    they are being sold like bags of potatoes.              standards are complied with. tw
 the issuing of compliance plate approval. To          “There are now numerous importers selling
 ensure the manufacturer is complying with          dirtbikes from China. Some have very different          Thanks to Chris Drabikowski (CEDRA
 the processes described in the compliance          reputations from others and the dubious ones            compliance testing), Paul Nobbs (Stoney Creek
 plate approval, conformance to process             won’t do much for the standing of the industry          Powersports), Allan Jonas (DOTARS), Anthony
 inspections, known as COPs, take place. This       as a whole.”                                            Chrisis (EVO Compliance), Charles Mann
 involves representatives from DOTARS visiting         It won’t be long now and we will see our first       (Vectrix) and Simon Gloyne (Piaggio) for
 the factories where the bikes are made to          ADR-compliant Moto Morini slicing through               the time they spent helping me get my head
 conduct inspections. DOTARS officials audit the    the hills, proudly wearing its new designer             around the ADRs and where they are going,
 production records of bikes sent to Australia      chainguard. We’ll also see a Vectrix scooter sans       although in writing this I doubt if I have made
 and verify that the manufacturer has been          muffler, as of course, it is silent. Yet for all the    it any easier for anyone else to understand.
 using what they have said they would be using.     complexities involved, the importers seem pretty           For those wanting to know more the ADRs
    The VIN number on a motorcycle is the           happy with DOTARS and none consider them                can be found at <www.dotars.gov.au/roads/
 key to this traceability as it holds all the       to be faceless bureaucrats out to destroy all our       motor/design/adr_online.aspx>
 information needed to determine its origins.       fun, as Simon Gloyne from Piaggio Australia                While the UN/ECE regulations can be found
 The first three characters are the manufacturer    (and currently seeking compliance for the MP3           at <www.unece.org/trans/main/welcwp29.
 or the World Manufacturer Identifier, and then     and Gilera Fuoco three-wheelers) said: “We have         htm>
 its check numbers, plant number, serial number     a good working relationship with DOTARS and                I need to go for a ride…    -AS


090   twowheels

				
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posted:5/13/2010
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