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https://movingon.blog.gov.uk/2022/09/22/bring-your-heavy-goods-vehicle-to-annual-test-mot-appropriately-laden/

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

Posted by: , Posted on: - Categories: Vehicle testing

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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34 comments

  1. 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.

    Reply
    • 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.

      Reply
  2. 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.

    Reply
  3. 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?

    Reply
  4. 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

    Reply
  5. Comment by neil proud posted on

    Will this apply to 3 axle trailers.

    Reply
  6. 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.

    Reply
  7. 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,

    Reply
    • 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.

      Reply
  8. 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

    Reply
  9. 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.

    Reply
    • 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.

      Reply
  10. 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.

    Reply
    • 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.

      Reply
  11. Comment by Paul Glover posted on

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

    Reply
  12. 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

    Reply
    • 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.

      Reply
  13. Comment by mark williams posted on

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

    Reply
  14. 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.

    Reply
  15. 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.

    Reply
    • 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.

      Reply
  16. Comment by Ann Holman posted on

    What do we do if our lorry is for horses?

    Reply
  17. 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?

    Reply
    • 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.

      Reply

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