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Bring your heavy goods vehicle to annual test (MOT) appropriately laden

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Testing a vehicle’s braking performance is an important road safety aspect of the annual test and periodic maintenance inspections. As part of a Heavy Goods Vehicles (HGV - motor vehicles & trailers) annual test, DVSA carries out a roller brake test according to the ISO brake testing standard (21069).

Under the ISO standard, vehicles you present for test must be fully laden, apart from a few exceptions.

Why do vehicles need to be laden?

An appropriate amount of weight should be placed on the vehicle and/or trailer. This allows the Vehicle Standards Assessor to accurately carry out the test as the grip between the tyre and the rollers is at its maximum. This allows the vehicle’s wheels to keep turning for longer and avoid premature lock ups. The brake actuation pressure will also be at its most effective to determine a more meaningful assessment of the overall braking efficiency.

In most circumstances, to achieve this, vehicles must be loaded to at least 65% of their design axle weights with cargo (this doesn’t have to be the cargo you would usually carry) or loaded with ballast to achieve this. The Goods Vehicle plating and testing regulations 1988 (at regulation 8 (2) (k)) state that an examiner may refuse to accept a vehicle or trailer for test where it is not satisfactorily loaded.

Occasionally, due to the vehicle’s design this can be hard to achieve. In these cases we would accept less the 65% but no lower the 50%,

You may load the vehicle yourself or ask the Authorised Testing Facility to supply ballast for you to use. They can charge you for this service.

The load or ballast used for annual test must be safely secured on or in the vehicle. Otherwise, the test may be refused.

What if my vehicle is unladen when I bring it in for its annual test?

A small number of operators have presented vehicles for test at ATFs unladen. They have been tested as presented but the operators are taking a chance on passing with insufficient efficiency and wheel lock-ups only and may fail to meet the appropriate test standard.

To maintain road safety, vehicles presented for test must be appropriately laden for test from 1 January 2023.

After this date, a Vehicle Standards Assessor will refuse to test a vehicle which is not appropriately laden. You will lose the test fee and will need to re-present the vehicle or trailer correctly laden and pay for a new test.

You can find guidance on loading vehicles adequately for the roller brake test on GOV.UK. This also provides guidance on vehicles which may reasonably be expected to be tested without a load such as a tri-axle semi-trailer, road sweeper or concrete mixer.

Safety is crucially important

The Traffic Commissioners (TCs) and DVSA have focussed on brake testing since the 2014 Bath tipper tragedy. All the industry bodies have supported us on this. The results are showing this effort is paying off. In 2014, 3.3% of heavy goods motor vehicles failed their annual test on service brake performance. In the last quarter of 2021, that had reduced to 1.88%.

This is a great improvement but more can still be done. TCs may consider taking action where an operator's test history is unsatisfactory.

Roller brake tests should be carried out in the same week as your preventative maintenance inspections (PMIs). They should also be done to the same standard and procedure.

The same constraints on loading vehicles do not necessarily apply, given the flexibility in the Guide to Maintaining Roadworthiness on when a brake performance test can be carried out. They can also be done separately from the PMI check.

We hope this blog post has helped you understand the importance of loading your vehicles and trailers correctly for annual test.

If you have any comments, please leave them below.

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  1. Comment by Roy posted on

    Operators are allowed to downplate tractor units (or rigids) for taxation reasons. This is normally done because the loads habitually carried do not get anywhere near approaching the vehicle's permitted GVW/ GCW. A two axle trailer presented for Test or RBT at an ATF with either a 2 or 3 axle tractor which is downplated, creates a problem with the ballast loading of axles sufficiently for the RBT, and at the same time,staying within the taxation GCW. Keeping in mind that the DVSA advice is that the operator should be expecting to exceed the minimum efficiency requirements by a noticeable margin, what solution do you propose?

    • Replies to Roy>

      Comment by Julia (DVSA) posted on

      Hi Roy Under the Vehicle Excise and registration Act 1994, Schedule 2 section 22, a vehicle is exempt attending for or returning from test and this will include loading it for the purpose of test. So this should not be an issue.

      Alternatively if the operator does not want to travel to the ATF with this load then they should attend an ATF with a loading facility where the vehicle can be suitably loaded exceeding the 65% design axle weights.

  2. Comment by Tom Rankine posted on

    We maintain vehicles with varying axle configurations (mostly 6 x 4) with permanently mounted gritter bodies which i believe do not require a Mot test (as regarded as plant) however our customers request that they are Mot'd annually. Would these vehicles have to be laden for test as there is no reference to them in the brake test best practice guide?

    • Replies to Tom Rankine>

      Comment by Julia (DVSA) posted on

      Hi Tom. You are correct in thinking gritters are exempt from annual test. They can be put forward for a voluntary roadworthiness inspection which will be essentially the same inspection and standards but a different certificate given on completion. Because of the type of load it may be difficult for you to acquire a load and we cannot insist as it is a voluntary inspection. Where you can acquire a load then yes you should try to load them to 65% of the design axle weight on the drive axles.

  3. Comment by Callum King posted on

    I have questions about an ex MOD armoured patrol vehicle 3 axles and 6 wheel drive!
    First will I be required to present this laden, as it’s designed load is troops and their kit and access is relatively restricted and space to apply a load over the rear axles limited?
    Also I have the MOD procedure to RBT the vehicle but it is not possible to test the secondary brake due to its application through the drive train, the procedure states the secondary brake should be tested on an incline . How and where can I get a test that satisfies this?

    • Replies to Callum King>

      Comment by Julia (DVSA) posted on

      Hi Callum. This would be an example of a vehicle that, because of it’s design and use, would be unreasonable to expect to be loaded for test. If the vehicle's secondary brake is designated by the manufacturer as being part of the service brake split system, then it is not tested (see section 72 of inspection manual). If the secondary brake designated by the manufacturer is a part of the park brake system applied progressively, then it is tested. If the drive configuration will not allow the vehicle to be used on a roller brake tester, a decelerometer is used and, if on the secondary and park brake check this cannot be assessed using a decelerometer then the park brake is tested by applying the brake and trying to drive the vehicle against an applied brake to see if it stalls or drives off with the brake applied.

  4. Comment by Adam Dexter posted on

    Can you give clarification on STGO brake testing, trailers that have four or five axles with a special types plate for use in cat 2 can use the presented weight rule as long as the bogie weight is between 21000kg and 24000kg, but there is little to no guidance for trailers that operate in STGO cat 3.

    • Replies to Adam Dexter>

      Comment by Rob Webb (DVSA) posted on

      STGO 3 will be mostly outside of plating and testing requirements. But we will test brake performance to Design Weight where the Manufacturer’s Plate is available. If there is no Manufacturer’s Plate/Design Weights available, we’ll test to presented weight.

      • Replies to Rob Webb (DVSA)>

        Comment by Adam Dexter posted on

        Hello Rob, I appreciate that CAT 3 trailers are not Mot'd but can I have some clarification on correct test procedure to ensure best practice is observed on this category of equipment, I can simulate axle weights up to and beyond 16500kg per axle as per max allowance for STGO cat 3, but do I use the minimum pass efficiency of 45% TAW for service and 16% GVW for park for this equipment? Any advice will be gratefully received.

        • Replies to Adam Dexter>

          Comment by Rob Webb (DVSA) posted on

          These vehicles are not subject to annual test, so there is no test procedure. However, if they’re presented for a voluntary inspection this would be conducted on the same basis as an annual test (with a different test certificate issued upon completion of examination).
          We would test the brakes to the design weights where they can be established (45% of design total axle weight for service and 16% of design gross weight for park). Where the design weights can’t be established, the vehicle/trailer would be assessed against 45% and 16% of presented weight (as calculated from the total axle weights given on the Roller brake tester).

  5. Comment by Chris Cullen posted on

    We are a local Authority with a fleet of Refuse Collection Vehicles to send a vehicle for test with a load of refuse, I would suggest is not really appropriate for the tester, it is not practical to put an additional load into the body because of the set up of an RCV.

  6. Comment by Stewart Wild posted on

    Will the DVSA inspector refuse to test a RCV (refuse collection vehicle) or an ejector trailer that carries trade or domestic waste as to identify what waste is in there is near on impossible?

  7. Comment by Allan Malcolm posted on

    I think this is a very good idea, it should speed up the test and show the vehicle user wiring conditions, my doubts are with live stock vehicles where animas are the load and hopefully these vehicles loaded with livestock will be prioritised to reduce any stress on the livestock, quite sure the powers at be will have realised this already

  8. Comment by neil proud posted on

    Will this apply to 3 axle trailers.

  9. Comment by Roy posted on

    So hopefully this is an end to the ridiculous policy of it being OK to present triaxle trailers unladen but not OK to present a tandem unladen.

  10. Comment by Bill Street posted on

    Good morning,
    If brake tests can be carried out in the same ISO week elsewhere than the maintenance provider, you should really clarify what the brake test entry on the inspection should be entered as! Your own Maintenance Investigation Vehicle Report would suggest this as unsatisfactory due to an incomplete inspection or record.
    Furthermore, "passing on locks" should be ended as most maintenance providers tend to try and "fob" us transport managers off with this statement knowing other parameters on the brake test are sub standard.
    I really think as the standard setter here, more should be done to correct the absolute pass status parameters and that maintenance providers are issued guidance to this fact.
    Kind regards,

    • Replies to Bill Street>

      Comment by Rob Webb (DVSA) posted on

      This is not something that can be by-passed, as the tyre would be damaged if we continued to rotate the rollers.
      Even if the the overall efficiency has been met you are right that you should still look at the report for any braking issues such as balance, bind little or no effort etc.

  11. Comment by toney Martin posted on

    Hi, we have a fleet of RCVs, these types of vehicles would be very hard to load, we would not want to turn up to ATF full of general waste, are there
    exceptions to this rule, a 26t RCV would just make the 50% weight,
    i look forward to hearing from you

  12. Comment by Jock Anderson posted on

    I run an ATF. Any reason why tri-axle semi trailers can be tested empty? Understand how that came about in the first place, but surely there's no need now. They aren't built to carry nothing.

    • Replies to Jock Anderson>

      Comment by Rob Webb (DVSA) posted on

      The concession for tri-axle semi-trailers will continue for the foreseeable future.
      The difficulty is with obtaining an adequate load for these vehicles.

      • Replies to Rob Webb (DVSA)>

        Comment by Jock posted on

        Hi Rob, thanks for the reply. At my place, loading a tri-axle is no different to 2 or 4 axles. I get there will be exceptions, sewage tankers, cattle trailers etc but flats, boxes, curtainsides, low-loaders are all loadable. I've had VSAs, on more than one occasion, fail a loaded trailer that got 35% of TAW, 50% imbalance and no locks, only for customer to pay for new test, go thru empty, get 3000+kg and 6 locks. Pass, but we all know it's a pile of junk. That can't be right.

        • Replies to Jock>

          Comment by Rob Webb (DVSA) posted on

          Thank you for the feedback. The Department for Transport wishes the UnLaden TriAxle SemiTrailer (ULTAST) to continue for the foreseeable future.
          We are conducting trials into the ULTAST to see if it is still fit for purpose and your feedback will be considered.

      • Replies to Rob Webb (DVSA)>

        Comment by Ken Bianchi posted on

        If you are stating that there is a concession for tri-axle semi-trailers and it will continue for the foreseeable future. Why is this not outlined better in the guidance. I run a fleet of bespoke tri-axle double deck trailers with fixed floors and they would cause un an issue to load safely at an ATF. Can you confirm that tri-axle semi trailers can be tested unladen

        • Replies to Ken Bianchi>

          Comment by Rob Webb (DVSA) posted on

          The UnLaden TriAxle SemiTrailer (ULTAST) has been around for over 30 years. We’ve never required these trailers to be loaded unless the customer chooses to do so and that remains the case.
          What we’re discussing is where the vehicles are required to be laden (these are not). In those cases, we require that they come in laden or we will refuse to test them.

  13. Comment by Tom posted on

    These posts are helpful but as ever you do have a tendency to muddy the waters rather than clarify them.

    In the final few paragraphs you state a brake test must be carried out in the same week as the PMI, but then go on to say below this, with vague reference to loading, that they can be carried out separately from the PMI, how would you then refelect this on PMI paperwork, for example, as your own MIVR would categorise that report with no brake test results as an incomplete record.

    I hope the new Guide to Maintaining Roadworthiness will be released soon and offer proper clarity on this, as often your own vehicle testers do not know the content of your own published Inspection Manuals.

    Will we finally see the end of 'passing on locks'?

    There is still widespread confusion from the majority of Operators on these matters and endless debate as a result because you seem reluctant to offer crystal clear clarity.

    Please, use simple words and explain precisely what is required.

    • Replies to Tom>

      Comment by Rob Webb (DVSA) posted on

      This is not something that can be by-passed, as the tyre would be damaged if we continued to rotate the rollers.
      Even if the the overall efficiency has been met you are right that you should still look at the report for any braking issues such as balance, bind little or no effort etc.

  14. Comment by Paul Glover posted on

    Very good news
    You want to know the brakes work when loaded
    Looking for efficiency not locks

  15. Comment by Michael posted on

    I didn't andbthe test center forklift dropped the large weight all on one side blew out my tire so alway take it ladened now cost 167 pou d for tyre company and a retest

    • Replies to Michael>

      Comment by Rob Webb (DVSA) posted on

      We’re glad to hear you always present your vehicle laden now and sorry to hear that damage was caused to your vehicle.
      The ATF is responsible for loading at their site, so you will be able to claim the expense back from them if the damage was caused by their loading of the vehicle in the way you mention.

  16. Comment by mark williams posted on

    What vehicles are exempt from loading ? IE food carrying also horse boxes / livestock carrying vehicles ?

  17. Comment by Kevin Archer posted on

    A very clear explanation of the requirements needed for this very important safety measure. The improvement in brake testing failure rates is a welcome step in safety.

  18. Comment by Mike Dunlop posted on

    I think DVSA advice re brake testing is still too wishy-washy. Why not clearly state you (and the TC's) want (in order of importance)

    1. Laden RBT at every PMI
    2. If this isn't possible, a RBT every time with at least 4 per year laden
    3. If this isn't possible, 4 laden RBT per year and otherwise a decelerometer test with brake temp readings at all other PMI's

    The GTMR wording of "It is strongly advised that a calibrated roller brake tester (RBT) is used at each safety inspection" and "However, it is
    also acceptable to use an approved and calibrated decelerometer to measure overall
    brake efficiency values for vehicles without trailers" is just too weak. People read these comments as advice only and many take the decelerometer option even though it is in reality not an effective test.

    • Replies to Mike Dunlop>

      Comment by Rob Webb (DVSA) posted on

      We are clear that where the vehicle/trailer design or use it would make it impossible or difficult to load, we would accept the vehicle and test as presented. But every effort should be made to load a vehicle, as an unladen vehicle/trailer may struggle to attain the appropriate brake efficiency if the brakes do not lock sufficiently during the roller brake test.
      The alternative would be DVSA telling everyone affected they must do something that we know they’re not able to do.

  19. Comment by Ann Holman posted on

    What do we do if our lorry is for horses?

  20. Comment by Chris posted on

    In your Blog you state you carry out brake tests according to iso21069 which requires a vehicle to be fully laden yet later in the Blog and in the linked guidance you are still using 65% or no less than 50%.
    Could you make it clear as to your expectations please?

    • Replies to Chris>

      Comment by Rob Webb (DVSA) posted on

      You should aim to load the vehicle as much as possible up to 100%.
      At 65% the load sensing should be allowing full brake actuation pressure, which is why we ask for at least 65%. Up to 50% is acceptable, just not desirable.
      The more you can achieve over 65% the better it is for you brake test. You should aim to load your vehicle as much above the 65% threshold as is legally acceptable.