Vehicle Standard (Australian Design Rule 13/00 – Installation of Lighting and Light Signalling Devices on other than L-Group Vehicles) 2005 Amendment 3

Vehicle Standard (Australian Design Rule 13/0013/00 – Installation of Lighting and Light Signalling Devices on other than L-Group Vehicles) 2005 Amendment 3

Made under section 7 of the Motor Vehicle Standards Act 1989

Explanatory Statement

Issued by the authority of the Minister of Infrastructure, Transport, Regional Development and Local Government

June 2009

CONTENTS

1. legislative context................................................

2. content and effect of ADR 13/00 and amendments

2.1. Overview of the ADR.............................................

2.2. Changes to the ADR..............................................

3. best practice regulation............................................

3.1. Business Cost Calculator...........................................

3.2. General Consultation Arrangements..................................

3.3. Specific Consultation Arrangements for this Vehicle Standard.............

3.4. Regulation Impact Statement........................................

Attachment A...........................................................

1. legislative context

Vehicle Standard (Australian Design Rule 13/00 – Installation of Lighting and Light Signalling Devices on other than L-Group Vehicles) 2005 is made under the Motor Vehicle Standards Act 1989 (the Act).  The Act enables the Australian Government to establish nationally uniform standards for road vehicles when they are first supplied to the market in Australia.  The Act applies to such vehicles whether they are manufactured in Australia or are imported as new or second hand vehicles.

The making of the vehicle standards necessary for the Act's effective operation is provided for in section 7 which empowers the Minister to "determine vehicle standards for road vehicles or vehicle components".

Australian Design Rule (ADR) 13/00 was originally determined in Determination of Motor Vehicle Standards - Order No 1 of 1989 along with ten subsequent determinations before it was remade in 2005 to meet the requirements of the Legislative Instruments Act 2003.  It has since been amended in two subsequent determinations.

2.                       content and effect of ADR 13/00 and amendments

2.1.                 Overview of the ADR

ADR 13/00 provides requirements for the layout and installation of vehicle lighting systems for four wheeled road vehicles and trailers.  This includes requirements for the number and mode of installation of lamps for direction indicators, position, stop, reversing, parking and retroreflectors for all road vehicles (other than two and three wheeled motor vehicles) and main-beam/dipped-beam headlamps, fog, driving, hazard warning signals, daytime running and corning lamps for four wheeled motor vehicles.

Its technical content is based on internationally accepted United Nations Economic Commission for Europe (UNECE) standards.  ADR 13 works in conjunction with several other ADRs including; ADR 46 Headlamps, ADR 51 Filament Lamps, ADR 77 Gas Discharge Headlamps and ADR 78 Gas Discharge Light Sources.

2.2.                 Changes to the ADR

The proposed changes to the ADR makes provisions for the optional fitment of Adaptive Front lighting Systems (AFS), emergency stop signals and conspicuity marking to road vehicles.  These new provisions are being incorporated into the ADR by the adoption of the latest revision of UNECE Regulation (R) 48 in Appendix A, which includes the 03 and 04 series of amendments.

The ADR is being amended to remove the current interim requirements for optional fitment of Light Emitting Diode Headlamps in Appendix B as these requirements are now incorporated in the latest revision of UNECE R 48 which is being adopted in Appendix A.

The ADR is being amended to make reversing lamps optional on trailers.  Previous amendments to the ADR to incorporate earlier revisions of the UNECE regulations mandated that certain types of trailers be fitted with reversing lamps.  This was an oversight.

The ADR is also being amended to set practical requirements for stop lamps, rear position lamps, rear direction indicators and retroreflectors requirements for small TA (very light) category trailers (either single or two wheeled) having a width of not more than 980 mm.  Current requirements for these trailers inhibit their use.

The amendments also include the removal of a redundant clause for the repeal of standards, the rationalisation of the term “rule” and “standard” in various clauses and the correction of the term “paragraph” and “clause” when referencing the ADR and Appendix A.

3.                       best practice regulation

3.1.                 Business Cost Calculator

The substantive amendments in this package all act to increase choice.

The provisions for fitment of AFS, emergency stop signals, and conspicuity markings are optional only and can be taken up as a matter of choice by manufacturers and consumers.

Without these provisions, manufacturers supplying to the world markets would not be able to supply their product to the Australian market.  The effect that this would have on the Australian market is to limit the choice of vehicle models for consumers and deny consumers the safety and efficiency benefits that the features provide.

The amendments in respect of lighting on small TA trailers will facilitate their practical operation.

3.2.                 General Consultation Arrangements

It has been longstanding practice to consult widely on proposed new or amended vehicle standards.  For many years there has been active collaboration between the Federal and the State/Territory Governments, as well as consultation with industry and consumer groups.  Much of the consultation takes place within institutional arrangements established for this purpose.  The analysis and documentation prepared in a particular case, and the bodies consulted, depend on the degree of impact the new or amended standard is expected to have on industry or road users.

Depending on the nature of the proposed changes, consultation could involve the Technical Liaison Group (TLG), Transport Agencies Chief Executives (TACE), and the Australian Transport Council (ATC).

• TLG consists of representatives of government (Australian and State/Territory), the manufacturing and operational arms of the industry (including organisations such as the Federal Chamber of Automotive Industries and the Australian Trucking Association) and of representative organisations of consumers and road users (particularly through the Australian Automobile Association).
• TACE consists of the chief executives of Australian and State/Territory departments of transport and road vehicle administrations.
• ATC consists of the Australian, State/Territory and New Zealand Ministers with responsibility for transport issues.

The Department of Infrastructure, Transport, Regional Development and Local Government process editorial changes and changes to correct errors without reference to other agencies.  This approach is only used where the amendments do not vary the intent of the vehicle standard.

Proposals that are regarded as significant need to be supported by a Regulation Impact Statement meeting the requirements of the Office of Best Practice Regulation as published in Best Practice Regulation Handbook and the Council of Australian Governments Principles and Guidelines for National Standard Setting and Regulatory Action for Ministerial Councils and Standard-Setting Bodies. 

3.3.                 Specific Consultation Arrangements for this Vehicle Standard

The proposed minor amendments were discussed within the TLG at its 25 July 2007 and 22 May 2008 meetings, where the proposal to amend ADR 13 as outlined was agreed to by all members.

As the amendments are minor in nature, and do not raise the stringency of the ADR, TLG members agreed that further consultation was not necessary through the public comment process.  The state and territory representatives were also confident that they represented the views of their jurisdictions and that there was no need for further consultation through the Transport Agency Chief Executives (TACE) or the Australian Transport Council (ATC).

3.4.                 Regulation Impact Statement

A RIS has been prepared and is included at Appendix A. Since the decision is made by the Minister for Infrastructure, Transport, Regional Development and Local Government without reference to the ATC, it conforms to the requirements established by the Office of Best Practice Regulation (OBPR) in relation to regulatory proposals where the decision maker is the Australian Government’s Cabinet, the Prime Minister, minister, statutory authority, board or other regulator.  The OBPR reference number is 10331.

APPENDIX A

REGULATION IMPACT STATEMENT FOR

MINOR AMENDMENTS TO AUSTRALIAN DESIGN RULE 13/00

Regulation Impact Statement for

Minor Amendments to Australian Design Rule 13/00

June 2009

OBPR Ref No. 10331

Prepared by: Vehicle Safety Standards

Department of Infrastructure, Transport, Regional Development and Local Government

CONTENTS

1. Introduction

2. Background

2.1. The Problem

2.2. New Provisions and Amendments

2.2.1. LED Headlamps

2.2.2. Adaptive Front-lighting Systems (AFS)

2.2.3. Emergency Stop Signal

2.2.4. Conspicuity Markings

2.2.5. Reversing Lamps

2.2.6. Small TA Category Trailer Lighting Provisions

2.3. International Standards

3. Objectives

4. Options

4.1. Option 1: Take No Action

4.2. Option 2: Adopt the Proposed Minor Amendments

4.3. Option 3: Delete the ADR

4.4. Option 4: Non-regulatory Option

5. Analysis

5.1. Option 1: Take No Action

5.2. Option 2: Adopt the Proposed Minor Amendments

6. Impacts

6.1. Cost to business

6.2. Benefits

7. Consultation

8. Conclusions and Recommendations

9. Implementation and Review

10. References

APPENDIX 1

1.                    Introduction

The Australian Government provides protection for new vehicle consumers through the Motor Vehicle Standards Act 1989 (C’th) (MVSA). 

The MVSA provides mandatory vehicle safety, emission and anti-theft standards which apply when new vehicles are supplied to the Australian market.  These are national standards and are known as the Australian Design Rules (ADRs).

Australian Design Rule 13/00 – Installation of Lighting and Light Signalling Devices on other than L-Group Vehicles, provides requirements for the layout and installation of vehicle lighting systems for four wheeled road vehicles and trailers.  This standard is harmonised with United Nations – Economic Commission for Europe (UNECE) Regulation 48/02.

Industry has proposed a minor amendment to ADR 13/00 to allow UNECE R 48/03 and R 48/04 as alternative standards to permit Adaptive Front Lighting Systems (AFS) and emergency stop signal systems in road vehicles and by making this minor amendment it will facilitate the updating of Appendix A of ADR 13 with the latest revision of UNECE R 48 to remove the current temporary provisions for Light Emitting Diode (LED) headlamps.

This Regulation Impact Statement (RIS) examines the case for government intervention.

2.                      Background

2.1.                 The Problem

Currently, the ADR for vehicle lighting equipment does not have provisions for AFS or emergency stop signal systems as the development of this technology has outpaced the current ADR and manufacturers are prevented from implementing these features as either options or standard equipment on vehicles.  The 03 and 04 series of UNECE R48 has provision for AFS and emergency stop signal systems.  The inclusion of 03 and 04 series of UNECE R 48 as alternative standards in the ADR will remedy this deficiency.

ADR 13/00 has a temporary provision in Appendix B for LED headlamps in road vehicles.  This temporary measure was necessary at a time when the vehicle industry had developed LED headlamp technology and the UNECE standard for LED headlamps had not been ratified.  The temporary measure was to be replaced with the ratified UNECE standard when it became available.  The updating of Appendix A in the ADR with the latest revision level of the UNECE R 48 and the acceptance of the 03 and 04 series of UNECE R 48 as alternative standards will replace this temporary measure.

If the above amendments are not made to cater for the new provisions, manufacturers supplying to the world market would not be able supply their product to the Australian market.  The effect that this would have on the Australian market is to limit the choice of vehicle models for consumers and deny consumers the safety and efficiency benefits that the features provide.

A previous revision to ADR 13/00 incorporated a version of UNECE R 48 that mandated the fitting of reversing lamps to certain types of trailers.  The mandating of this requirement was an oversight and as there is no evidence to suggest that the presence of reversing lamps on trailers is a safety issue, to continue to impose this mandatory requirement cannot be justified.

Small single wheeled TA category trailers that are towed behind motor cycles, have demonstrated a deficiency in the current standard that deals with the position requirements for stop lamps, rear position lamps, direction indicators and retroreflectors.  Currently, some state and territory transport authorities permit these vehicles providing that they comply with some of the ADR 19/02 - motor cycle lighting provisions.  As there is no justification to prohibit the use of small single wheeled trailers on the basis of a lack of compliance with ADR 13/00 lighting requirements, it is proposed to adopt the relevant provisions in ADR 19/02 - motor cycle lighting to apply to small single wheeled trailers.  Furthermore, so as not to exclude two wheeled small trailers from utilising the same provisions, it is proposed to apply these provisions to small narrow TA Category trailers.

2.2.                 New Provisions and Amendments

The acceptance of 03 and 04 series of UNECE R48 regulation as alternative standards and making the amendments to ADR 13 will provide requirements for the following:

2.2.1.           LED Headlamps

The provisions for LED headlamps are similar to those for filament lamps or high-energy gas discharge light sources.  The performance of LED headlamps is comparable with headlamps equipped with these other light sources while providing improved reliability and the potential for greater efficiency, leading to improved road safety and reduced motoring costs for consumers.  The provision for LED headlamps is optional on vehicles.

2.2.2.           Adaptive Front-lighting Systems (AFS)

AFS can provide various modes of front-lighting illumination, for example the ability to alter high beam and or low beam lighting patterns to accommodate for various road geometries as the vehicle is steered into corners. The provision for AFS will be optional on vehicles.

2.2.3.           Emergency Stop Signal

The emergency stop signal is a flashing signal to indicate to other road users to the rear that the lead vehicle is braking rapidly due to an emergency situation.  The signal will be given by the simultaneous flashing operation of all of the stop or direction lamps.  The provision for the emergency stop signal capability will be optional on vehicles.

2.2.4.           Conspicuity Markings

Conspicuity markings are intended to increase the visibility of a vehicle, when viewed from the side or rear.  These markings are not self illuminating as they reflect the light from other light sources, typically the headlamps of another vehicle.  The UNECE regulation amendment containing provisions for these markings mandates them for certain types of goods vehicles and trailers.  However, the requirements for heavy vehicle contour markings in Australia are controlled by a code of practice.  The amendment to ADR 13 will make the UNECE R 48 provisions for conspicuity markings optional for all vehicles, other than for those passenger vehicles for which conspicuity markings are prohibited in UNECE R 48.

2.2.5.           Reversing Lamps

Reversing lamps are used to illuminate the road to the rear of the vehicle and to warn other road-users that the vehicle is reversing or about to reverse.  The current regulation requires that reversing lamps are fitted to all motor vehicles and all light, medium and heavy trailers (Categories TB, TD & TC).  Reversing lamps can be fitted to very light trailers (TA Category) as an option.  The amendments to the ADR seek to make the fitment of reversing lamps optional on all trailers.

2.2.6.           Small TA Category Trailer Lighting Provisions

Small single wheeled trailers that are towed behind motor cycles are designed for the transport of stowage in addition to or as an alternative for panniers on motor cycles.  The size of the single wheeled trailer is generally no wider than the motor cycle. 

This narrow bodied trailer falls outside of the ADR 13 vehicle lighting requirements.  So that this type of trailer can fit into the current certification system requirements, it is proposed make the relevant provisions of ADR 19/02 - motor cycle lighting applicable to small single wheeled TA category trailers in ADR 13.

Consideration has been give to include small two wheeled TA category trailers in the same requirements.  However, so as to ensure that the relevant ADR 19/02 lamp provisions only apply to small TA category trailers with a similar width to motor cycles, a maximum trailer width of 980 mm has been proposed.  This dimension is also based on the ADR 19/02 minimum separation dimension of 180 mm between lamps and the ADR 13/00 maximum dimension of 400 mm from the extreme outer edge of the trailer to the stop or direction-indicator lamp (400 x 2 = 800 + 180 = 980 mm). 

The amendments to the ADR seek to make the relevant provisions of ADR 19/02 – motor cycle lighting applicable to small all TA category trailers having an overall width no more than 980 mm.

2.3.                 International Standards

ADR 13 is based on the international standard UNECE R 48 as adopted by the UNECE.

During 2008, UNECE R 48 was progressively amended to include provisions for LED headlamps, AFS, emergency stop signals and conspicuity markings.  The standard has become available during this period and can be included in ADR 13.  The proposed amendments to ADR 13 will make it possible for these features to be fitted to vehicles that are supplied to the Australian market.

3.                      Objectives

The first objective of the identified proposal is to ensure that the ADR provisions are effective, appropriate for Australian conditions and technically current so that consumers are not denied the safety and efficiency benefits that new technology features provide.

The second objective is to ensure that the ADR provisions are not a technical barrier to trade and that vehicle manufacturers who supply product to the world market are able to supply the same product into the Australian market.

The third objective is to ensure that the ADR provisions do not create the need for special consideration by the state and territory transport authorities when processing the registration of small TA category trailers for use on public roads.

4.                      Options

4.1.                 Option 1: Take No Action

Under this option, vehicles would be required to continue to comply with the current ADR 13/00 requirements.

This option would not enable the ADR to be effective, appropriate for Australian conditions and technically current, as Appendix A in ADR 13 would not be updated with the latest revision level of the UNECE R 48 technical specification and this would potentially exclude new technology such as AFS or emergency stop signal systems from being fitted to vehicles for supply to the Australian market.  It would also mean that the temporary measures for LED headlamps would remain in place without a method for amendment.  Reversing lamps on some trailer categories would remain mandatory even though there is no evidence to suggest that the presence of reversing lamps on trailers is a safety issue.  Some small trailers would continue to require special consideration of the lighting provisions by the state and territory transport authorities.

This option would not permit the updating of the ADR provisions which could result in the ADR being a technical barrier to trade as vehicle manufacturers who supply product to the world market would not be able to supply the same product into the Australian market.

4.2.                 Option 2: Adopt the Proposed Minor Amendments

This option would ensure that the ADR remains effective, appropriate for Australian conditions and technically current, as it will replace the temporary measures for LED headlamps in the ADR with the removal of Appendix B and the updating of Appendix A with the latest revision level of the UNECE R 48 technical specification.  The acceptance of 03 and 04 series of UNECE R48 as alternative standards also includes requirements for LED headlamps and will ensure that vehicles complying with these standards will be accepted into the Australian market.  The updated Appendix A also includes provisions for AFS and emergency stop signal systems.  This amendment will ensure that vehicles fitted with these features can then comply with these provisions and be accepted into the Australian market.

Reversing lamp provisions for trailers will be made optional which corrects an oversight in the previous amendments to ADR 13 that mandated this provision.

Manufacturers of small TA category trailers having an overall width of not more than 980 mm will be permitted to use some of ADR 19/02 – motor cycle lighting requirements to demonstrate compliance with ADR 13.

The introduction of the latest revision level of UNECE R 48, in Appendix A of ADR 13, requires the mandatory application of conspicuity markings for certain vehicles.  The proposed amendment of ADR 13 will make this provision optional for all vehicles, other than for those vehicles which conspicuity markings are prohibited.  This will ensure that the current Australian arrangements that utilise a code of practice for heavy vehicle conspicuity markings can remain an option for vehicle manufacturers.

It is important to note that the proposed amendments do not constitute a barrier as vehicle manufacturers who supply product to the world market are able to supply the same product into the Australian market.

4.3.                 Option 3: Delete the ADR

Under this option, vehicles would no longer be required to continue to comply with ADR 13/00 requirements.

The ADRs are subject to a full review every ten years. This ensures that they remain relevant, cost effective and do not become a barrier to the importation of safer vehicles and vehicle components. The next full review for this ADR will be due in 2011.   The broader issue of whether to retain or delete the entire ADR, or any of the requirements therein, has already been considered and rejected as part of the full review of the vehicle lighting package.  Therefore, this option has not been considered any further in the RIS.

4.4.                 Option 4: Non-regulatory Option

Under this option, non-regulatory options such as suasion (publicity, social pressure etc), pure market approaches (property rights) and economic approaches (taxes, charges, fees, or subsidies) would be considered that would have the same effect as the proposal for this minor amendment.  As with Option 3, non-regulatory options have already been considered and rejected as part of the full review.  Therefore, this option has not been considered any further in the RIS.

5.                      Analysis

5.1.                 Option 1: Take No Action

This option involves maintaining the lighting related ADRs as is and not allow for the use of AFS, emergency stop signals or conspicuity markings.  This would be disadvantageous to industry as it would prevent manufacturers from supplying vehicles equipped with these lighting systems to the Australian market.  This would deny consumers the safety and efficiency benefits of this technology.  As vehicles equipped with these lighting systems are currently available in Europe, not making provisions in the ADR for this new technology is an unacceptable option.

The mandating of reversing lamps for trailers and not making provisions for rear lighting requirements for small trailers would result in continuing to impose a regulation on manufacturers that cannot be justified from a safety standpoint and continue to place unnecessary regulatory provisions at a state and territory level.

5.2.                 Option 2: Adopt the Proposed Minor Amendments

Under this option, vehicles fitted with the new technology such as LED headlamps, AFS or emergency stop signal systems would need to comply with the ADR before supply to the Australian market.  Making the amendment to the ADR would realise the safety and efficiencies from this technology for the consumer and other road users.  Consumers would also benefit from a greater selection of vehicle models being supplied to the Australian market.

The reversing lamps provisions would be made optional on all trailers which corrects an oversight in a previous amendment to the ADR that mandated this provision.

Small TA category trailers having an overall width of not more than 980 mm will be permitted to use relevant provisions of ADR 19/02 – motor cycle lighting to demonstrate compliance with ADR 13, this will reduce the current regulatory practices by the state and territory transport authorities for this vehicle type to be used on the roads saving time and reducing the cost of providing registration services for these trailers.

The amendment that makes conspicuity markings optional on all vehicles, other than for those vehicles which conspicuity markings are prohibited, will eliminate a potential conflict with the current arrangements for heavy vehicle contour markings that are controlled by a code of practice.

This option would meet all of the objectives set out above.

6.                      Impacts

6.1.                 Cost to business

The current new vehicle certification system administered by the Department imposes several costs on industry.  Before a new vehicle can be issued an identification plate (allowing it to be supplied to the market) test evidence must be provided to show that the vehicle meets all relevant ADRs.  Primarily this evidence consists of summaries of tests preformed on various components or the whole vehicle.  Many of these tests are destructive (not an issue for these new provisions) and require specialist training, equipment and facilities.

Option 1, taking no action, would preserve the status quo and not impose any additional cost on vehicle manufacturers.

Option 2, adopt the proposed minor amendments, would not dramatically change the compliance cost for lighting systems on vehicles for a majority of vehicle manufacturers as the compliance process will have already been carried out for other international markets.  The requirements set out in the new provisions for conspicuity markings and emergency stop signals are very basic and because of this the cost of compliance to vehicle manufacturers would be low.  Though the requirements for Adaptive Front-lighting Systems are slightly more complex than those of conventional headlamps, it is expected that the cost of testing to any of these new provisions will not greatly exceed the costs related to testing existing lamps and that there will be negligible changes to record keeping, enforcement and procedural costs.

The new standard for AFS, emergency stop signals and conspicuity markings would impose a small education cost on some business as they will have to familiarise themselves with the new requirements.  This cost would be optional however, as the new ADR will not mandate the use of LED headlamps, AFS, emergency stop signals and conspicuity markings.

There is no cost to business associated with making the fitment of reversing lamps on trailers optional.  Those manufacturers that were fitting reversing lamps to trailers can continue to do so without alteration or save the cost of fitting the lamps if they choose not to fit them. 

Amending the rear lighting requirements to accommodate very small trailers provides greater selection of options for the trailer manufacturer and would reduce design costs by permitting readily available motor cycle lighting systems.

6.2.                 Benefits

Option 2, adopt the proposed minor amendments, would provide an improvement in safety for those vehicles fitted with AFS, emergency stop signal systems for other road users.

The introduction of a standard containing the new provisions will allow the import and local manufacture of road vehicles equipped with AFS, emergency stop signals, conspicuity markings and related components.  The use of an international standard will allow local manufacturers to supply to both the Australian and international markets and offer new markets to existing vehicle lighting manufacturers.

Removing the requirement for the mandatory fitment of reversing lamps to certain categories of trailers will not prohibit the import and local manufacture of trailers complying with the current international requirements.

The World Trade Organisation’s Technical Barriers to Trade Agreement tries to ensure that regulations, standards, testing and certification procedures do not create unnecessary obstacles to trade.  This proposal is in keeping with this principle.

7.                      Consultation

Development of the Australian Design Rules (ADRs) under the Motor Vehicle Standards Act 1989 (C’th) (MVSA) is the responsibility of the Vehicle Safety Standards Branch of the Department of Infrastructure, Transport, Regional Development and Local Government.  It is carried out in consultation with representatives of the Australian Government, state and territory governments, manufacturing and operating industries, road user groups and experts in the field of road safety.

The Department undertakes public consultation on significant proposals. Under Part 2, section 8 of the MVSA the Minister may consult with state and territory agencies responsible for road safety, organizations and persons involved in the road vehicle industry and organizations representing road vehicle users before determining a design rule.

The Technical Liaison Group (TLG) is the consultative committee for advising on ADR developments and includes members for the Australian, state and territory governments, the vehicle manufacturing and operating industries and consumer groups.  The full membership of TLG is shown at Appendix 1.

The proposed minor amendments were discussed within the TLG at its 25 July 2007 and 22 May 2008 meetings, where the proposal to amend ADR 13 as outlined was agreed to by all members.

As the amendments are minor in nature, and do not raise the stringency of the ADR, TLG members agreed that further consultation was not necessary through the public comment process.  The state and territory representatives were also confident that they represented the views of their jurisdictions and that there was no need for further consultation through the Transport Agency Chief Executives (TACE) or the Australian Transport Council (ATC).

8.                      Conclusions and Recommendations

Option 2, adopt the proposed minor amendments, is regarded as the most effective solution in terms of achieving the outcomes suggested previously.  Under this option the ADR will be amended to accommodate the latest revision of the relevant UNECE regulation.  Additionally the amendments will be implemented such that vehicles compliant with the regulation prior to the amendment being made will continue to comply after the fact without the need for minor and inconsequential non-compliant approvals.

Option 1, taking no action, does not meet any of the objectives previously outlined and continues to perpetuate the inadequacies of the current ADR.  As such it not regarded as a viable solution.

The TLG agreed that Option 2, adopt the proposed minor amendments, is the preferred option.  As industry and regulatory agencies are fully supportive of the minor amendments and that there are no disadvantages to consumers, this option is recommended.

9.                      Implementation and Review

The amendments to the relevant ADRs would be determined by the Minister for Infrastructure, Transport, Regional Development and Local Government under section 7 of the Motor Vehicle Standards Act 1989.  The determination process generally takes approximately 28 days.

10.                 References

Australian Design Rules are available from http://www.Infrastructure.gov.au/roads/motor/design/adr_online.aspx

• Vehicle Standard (Australian Design Rule 13/00 – Installation of Lighting and Light Signalling Devices on other than L-Group Vehicles) 2005
• Vehicle Standard (Australian Design Rule 19/02 - Installation of Lighting and Light Signalling Devices on L-Group Vehicles) 2005

UNECE regulation documents are available from http://www.unece.org/trans/main/wp29/wp29regs.html

• UNIFORM PROVISIONS CONCERNING THE APPROVAL OF VEHICLES WITH REGARD TO THE INSTALLATION OF LIGHTING AND LIGHT SIGNALLING DEVICES. Regulation No. 48

APPENDIX 1

Membership of the Technical Liaison Group (TLG)