Vehicle Modifications NSW (Fuel Tanks)

Submitted: Friday, Nov 29, 2013 at 09:22
ThreadID: 105312 Views:8236 Replies:5 FollowUps:10
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Recently there was a post highlighting that a Vehicle Standards Information Bulletin (VSI 6) dated 8 November 2013 had been released.

The document is a guide to modifications requiring certification under the Vehicle Safety Compliance Certification Scheme in New South Wales, and has been updated to help vehicle owners and modifiers determine what modifications to vehicles up to and including 4.5 tonnes gross vehicle mass require certification.

I will leave individuals to review the document which I have linked below, but highlight that it is clear that when modifications to a vehicle are significant, the vehicle will require a compliance certificate issued by a person accredited as a licensed certifier on the Roads and Maritime Services (RMS) Vehicle Safety Compliance Certification Scheme (VSCCS).

Currently I am in the process of determining a suitable auxiliary fuel tank for my new Toyota 79 Series Dual Cab and there are two alternatives I am working towards deciding on.

When I checked the requirements of VSI 6 it is quite clear that the fitting or adding of an alternative fuel tank or repositioning an existing fuel tank to non-original mounting points requires certification. It is also useful to read VSB 14 as it details the requirements for the manufacture and fitting of an auxiliary tank in order for it to be compliant and certifiable.

This recent document appears to have created some confusion as to how it is applied, however my own due diligence has highlighted that certification is now required, whether that was the original intent time will tell. Given it involves fuel tanks I suspect it is certainly intended to be captured as a significant modification.

What might be of interest to many is the frequently asked questions of the VSCCS Declaration of Modification Order 2013. In part it states that the order does not introduce any new type of modification that requires certification; all certifiable modifications in VSB 14 required certification previously. This means that any vehicle subjected to a “major” modification since the late 1970s should have already been certifiable and if they were not certified, they should not have been registered. I'm not sure if that means fuel tanks were supposed to be certified previously.

But importantly, it notes, that vehicles previously modified in a manner that is considered significant under the Order will require certification if they have not already been certified. Auxiliary tanks previously fitted to vehicles, or that have had a larger capacity tank fitted, are captured under this document.

I would like to make a couple of points on my post...

Firstly, I am simply highlighting the new requirement – I neither conceived the regulations or have a view point as to whether they are applicable, at this point of time I simply intend to comply as written to ensure I have no registration and insurance issues going forward.

I prefer to do my own due diligence on this type of matter as it is me that will be in the “hot” seat if it all goes wrong given I am the registered owner of the vehicle. I recommend others do the same.

Manufacturers and fitters may well have a different view, or perhaps feel that it does not apply. When you read the documentation it is quite clear in black and white – an auxiliary tank requires certification. In fact, this is already the case in Queensland.

Why concern yourself? It is an individual’s choice how it is dealt with, but bear in mind non-compliance may have unintended consequences in the future.

Links follow.

VSB14 - Fuel Modifications

VSI 6 Vehicle Standards Information

VSCCS - FAQs

Cheers, Baz - The Landy

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Reply By: Robin Miller - Friday, Nov 29, 2013 at 10:02

Friday, Nov 29, 2013 at 10:02
Not for everybody Landy but I made a homemade Patrol tank 10 years ago which I reckon is better than some aftermarket ones I have seen and operates the way I want it to without compromise.

This is just another link in a long chain whose intention seems admirable but whose end result is increased cost and unnecessary regulation.







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Follow Up By: John and Regina M - Friday, Nov 29, 2013 at 10:14

Friday, Nov 29, 2013 at 10:14
And greater safety. Shouldn't forget that.
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Follow Up By: Robin Miller - Friday, Nov 29, 2013 at 10:23

Friday, Nov 29, 2013 at 10:23
Yes John , I was able to make my tank considerably stronger in areas I considered subject to a rock grind.
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Reply By: allein m - Friday, Nov 29, 2013 at 12:17

Friday, Nov 29, 2013 at 12:17
may be a much more simple idea is to certify at the time of manufacture

so each person has a to get the installation to done by trained technician

and like the pink slip do some random checks to make sure things are done properly

with government,s cutting back staff why create more work for the ones that are left

I can see some people just go out and do there own conversions and drive unregistered and possibly unsafe cars
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Reply By: Member -Dodger - Friday, Nov 29, 2013 at 14:23

Friday, Nov 29, 2013 at 14:23
Quoting the above,

When I checked the requirements of VSI 6 it is quite clear that the fitting or adding of an alternative fuel tank or repositioning an existing fuel tank to non-original mounting points requires certification. It is also useful to read VSB 14 as it details the requirements for the manufacture and fitting of an auxiliary tank in order for it to be compliant and certifiable.

This is and has always been the case, that is why most tanks that are installed are replacement tanks that use THE ORIGINAL mounting points.
I have had three vehicles that have had replacement tanks fitted and when I had the first one done I checked with the RTA, at the time and was told as long as it uses original mounting points and has been manufactured by a reputable manufacturer and has been tested as required all is in order.
I used to have a handle on life, but it broke.

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Follow Up By: The Landy - Friday, Nov 29, 2013 at 15:23

Friday, Nov 29, 2013 at 15:23
Yes, that is my precise reading of it also.

VSB 14 also indicates that a replacement tank of more than 125% of the original capacity uses the original mountings, their strength must be checked and shown to be adequate by a Signatory - as to the extent to which that has been enforced I'm not sure...

Cheers, Baz - The Landy
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Reply By: olcoolone - Friday, Nov 29, 2013 at 14:52

Friday, Nov 29, 2013 at 14:52
I think you're worrying about nothing, the tank manufactures would seek approval and engineering for their designs.

Much the same as certified GVM upgrades not needing an engineering inspection on every vehicle.
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Follow Up By: The Landy - Friday, Nov 29, 2013 at 15:25

Friday, Nov 29, 2013 at 15:25
I’m not too worried on the fuel tank issue, but simply highlighting the requirements in VSI6 as it may have implications for others.

I am looking at another tank that will be in addition to the one already on the vehicle. This will require certification, and my reading of VSB14 is that a tank more than 125% of the original capacity also requires certification even if mounted in the original mounting points.

I’m happy to be wrong as it will most likely save me $500 in engineer’s fees, so if you can point me to something that indicates my reading of the documents is incorrect that would be most helpful.

On GVM upgrades, you are half right and half wrong…and I say that politely!

GVM upgrade prior to the initial registration does not require an engineer sign-off providing the installed upgrade is an approved GVM kit installed by an accredited fitter authorised by the Secondary Manufacturer.

In NSW, a post registration GVM upgrade requires an engineering certification for every vehicle.

Cheers, Baz – The Landy
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Follow Up By: olcoolone - Saturday, Nov 30, 2013 at 08:47

Saturday, Nov 30, 2013 at 08:47
This is a typical mass hysteria reaction by people who don't understand the the new requirements and who are thinking this is the end of man kind and the world.

What they are trying to achieve is to put an end to shonky businesses and DIYers with very little knowledge or experience doing below standard work and fitting gear that is non compliant that could pose a risk.

You will find reputable companies will spend the money making their gear compliant and safe. They will also offer a blanket engineering compliance.

The stuff we see fitted incorrectly that comes into our workshop by incompetent businesses and the DIYer is at time shocking and scary.

There are general engineering practices that should be followed but to someone unskilled in this they would not have a clue and do understand why some thing is done the way it has..... Everyone is an expert until something goes wrong.

All this law will do is bring everything into line and a safe common standard.

So stop scarring the kids and the unknown and stop spreading incorrect information until all is know.
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Follow Up By: The Landy - Saturday, Nov 30, 2013 at 10:20

Saturday, Nov 30, 2013 at 10:20
Hi

I think you are quite right about the intent, and I'm sure the reputable manufacturer's will welcome it.

The guidelines are quite clear and that is all I have posted, nothing incorrect about it. But as I indicated from the outset it is up to individuals to determine how they interpret and respond to them.

I have spoken with the Roads and Maritime technical section and they confirm that my understanding is correct and as outlined in the bulletins and if I add an additional fuel tank it will require a certification from a signatory.

I guess all I can do is deal with the facts and information I'm presented with.

I've taken the opportunity to post this in the forum so people are aware of it and leave it at that...

Cheers, Baz - The Landy








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Follow Up By: olcoolone - Saturday, Nov 30, 2013 at 21:00

Saturday, Nov 30, 2013 at 21:00
There is nothing wrong with mentioning it, I am we'll assure reputable aftermarket businesses would be three steps ahead of the general public and would have it all under control.

Most products are tried and proven and are designed by someone with engineering knowledge and experience.

It can only bd good for the public and 4x4 industry.
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Follow Up By: Member - Bucky - Sunday, Dec 01, 2013 at 12:04

Sunday, Dec 01, 2013 at 12:04
My understanding is that all vehicle modification gear, made in Oz, company's must have it engineered, and passed, then it's safe to install, and no further certification is necessary.
But I have been wrong before, but only once.

Cheers Bucky
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Follow Up By: olcoolone - Monday, Dec 02, 2013 at 18:12

Monday, Dec 02, 2013 at 18:12
Not everything has to be certified, bullbars when fitted to SRS equip vehicles must comply and originally they would of been certified.

Most what there are talking about is already covered under the old act and have to be engineered...... RE brake upgrades, engine conversions, some suspension mods and tyre/rim specs.

Most places who supply upgrades also supply the relevant paperwork for compliance.

It's just mass hysteria and no different to when vehicle stability control and suspension upgrades were in the news.

Nothing is going to be any differant and the world will still be here.
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Follow Up By: The Landy - Tuesday, Dec 03, 2013 at 08:35

Tuesday, Dec 03, 2013 at 08:35
Ocoolone

As I said from the outset, and highlighted a couple of times, the intent of this post was to inform (interested) people that there had been clarification to existing rules. In fact, there are no new rules, they have simply been put into plain speak the requirements under the regulations, something that should be welcomed.

My interest has been in fuel tanks, hence the reference to them specifically…

You may well be right that it will be “business as usual” despite certification by an engineer being required for changes to fuel tanks.


In reality no-one is checking vehicles under 4,500kg on a systemic basis, and at least not like heavy vehicles. That means modifications to vehicles that have not been certified will most likely only ever come to the attention of the authorities if there is a serious accident.


Now most people don’t think this will ever happen to them, so I get it that they might not bother complying. But $200 for an engineering certificate is cheap insurance to ensure there are no unintended consequences in the future. From my perspective, I have spent a lot of money setting this vehicle to my requirements and I won’t rely on anyone when it comes to modifications that affect ADRs. For two reasons, firstly my experience points too many being blissfully unaware of the requirements, and secondly, many have a vested interest in selling me a product…


But here is the thing, it appears there are a lot of people that are not even aware there are compliance requirements that need to be met, and in fact the post by “Buckey” highlights this. In this post “Buckey” is of the view that the manufacturer is the person who has obtained compliance. That is only half correct, the manufacturer should by complying with the ADRs, but it is still the registered owner’s responsibility to ensure it is fitted correctly and certified by an engineer.


And I don’t think “Buckey” is alone on this, there are many out there who are blissfully unaware of the actual requirements…


But let’s be clear – the “she’ll be apples approach” is clearly the path that many take, just do so in full knowledge that there are regulations that should be complied with, whether an individual elects to is entirely up to them…


I can’t add to this, but hopefully there will be those who appreciate at least being presented with the facts, and if one person is now more enlightened than from my perspective it has been worthwhile – that is what this forum is all about, being informed and an exchange of ideas!

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Reply By: The Landy - Sunday, Dec 01, 2013 at 17:04

Sunday, Dec 01, 2013 at 17:04
Hi Bucky

The process is along those lines, however, for example a fuel tank may be made to comply with ADRs, however when you fit it to a vehicle it is your responsibility to ensure it complies with registration requirements, and that may mean an engineer's certification.

And this is the trap with after market products and modifications, it isn't the responsibility of the manufacturer to ensure you comply with the requirements for registration of the vehicle it is yours...they are simply selling it to you.

If you change something on or to your vehicle, the first question you should ask is whether a certification is required...

Cheers, Baz - The Landy
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