GCM and GVM Upgrades NSW | Vehicle, aircraft and boat
GCM and GVM Upgrades NSW
Phone: +61 2 8859 6768
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18.01.2022 We are usually pretty quiet on Facebook but very busy in the shop. Here are some pics.
11.01.2022 UPDATE There has been some confusion in the industry in relation to the regulation of gross combination mass (GCM) upgrades. Lovells has been working at an ind...ustry level to seek to clarify this confusion and will continue to do so. In the meantime, Lovells wishes to confirm its understanding of the regulatory position as it stands at the time of writing this statement. Pre-registration GCM upgrades A vehicle’s GCM is first nominated by the original manufacturer (OEM). There are various organisations, known in the industry as ‘second stage manufacturers’ (SSMs), that are frequently engaged to upgrade vehicle capacity, prior to first registration. Some SSMs, like Lovells, update the GCM to reflect the change in capacity as a result of the upgrade. Lovells believes that when there has been an upgrade to vehicle capacity pre-registration, it is important for any change to the vehicle’s GCM that has resulted from the upgrade to be noted. Lovells believes this is important for numerous reasons, including for accuracy and safety. Lovells understands that an updated GCM may be specified by a manufacturer and believes it is good practice for manufacturers to do so. Who is a manufacturer? The term manufacturer has a clear definition in the Australian Design Rules (ADRs), in clause 3 of Vehicle Standard (Australian Design Rule - Definitions and Vehicle Categories) 2005. The ADRs say that a manufacturer of a vehicle is the person who accepts responsibility for compliance with the ADRs in relation to that vehicle and is issued a compliance plate approval certificate for that vehicle. The ADRs do not differentiate between OEMs and SSMs. Based on the definition in the ADRs, Lovells will be considered to be a manufacturer of a vehicle if it accepts responsibility for compliance with the ADRs in relation to that vehicle and is issued a compliance plate approval certificate for that vehicle. Lovells accepts this responsibility as part of its GCM upgrade packages. Has there been a recent change to the law regulating pre-registration GCM upgrades? There has been no recent change to the law regulating pre-registration vehicle upgrades. Lovells understands that the longstanding position for many years has been that while the Federal Department does not assess, endorse or approve GCM upgrades, it equally does not restrict or prohibit GCM upgrades. Lovells understands this longstanding position has not changed. Importantly, this means that: Vehicles that Lovells has previously modified are legal in all States and Territories. Lovells is permitted to plate vehicles with gross vehicle mass (GVM) upgrades and towing capacity upgrades under the approved RVD (as stated in Lovells SSM approvals and as noted on current RVDs). Lovells is permitted to modify GVM/GCM/towing capacity or variants of these modifications in all States and Territories prior to first registration. What is the position regarding post-registration upgrades? When a manufacturer modifies a vehicle that has already been registered, this modification is governed by the various State and Territory authorities and their individual Type Approvals or Modification Codes. Put simply, these upgrades are governed by State and Territory law. Whether a particular type of modification is available post-registration, therefore depends on the position in the State or Territory in question. Some of the States and Territories have recently changed their position in relation to post-registration upgrades. GCM upgrades post-registration Lovells understands that the current position in relation to GCM upgrades in each State and Territory is as follows: NSW, SA and VIC recognise a revised GCM specified by a SSM if endorsed by the inspecting engineering signatory. The signatory must be an endorsed engineer who has access to our Evidence Packages. Endorsed engineers’ contact details are available upon request Tasmania recognises a revised GCM specified by a SSM. Queensland no longer recognises a revised GCM above the GCM nominated by the OEM. However, on 22 January 2020, Queensland TMR released a statement to the industry that TMR is exploring options for the issue of a new code that deals with GCM increases. TMR is working closely with Industry on this task, and in particular the Australian Automotive Aftermarket Association (AAAA). Whilst TMR’s priority remains on road safety and national consistency, it is optimistic that a technically sound and separate code-based solution for GCM re-rating can be developed. WA, ACT and NT no longer recognises a revised GCM above the GCM nominated by the OEM. Towing upgrades post-registration Lovells understands that the current position in relation to towing upgrades in each State and Territory is as follows: NSW, SA and VIC recognise a revised towing capacity upgrade if endorsed by the inspecting engineering signatory. The signatory must be an endorsed engineer who has access to our Evidence Packages. Endorsed Signatories contact details are available upon request. Queensland recognises a revised Towing Capacity Upgrade based on LS11/LS15/LX1 Modification Codes under the VSA (Vehicle Standards Approval System). Tasmania, WA and NT no longer allow Towing Capacity over OEM nominated capacity. GVM upgrades post-registration Lovells understands that GVM upgrades can still be plated in all States and Territories. How does Lovells ensure that any GCM it nominates is accurate? Not every SSM can or does nominate a revised GCM. Lovells does nominate revised GCM capacity figures as a SSM. Lovells is committed to going above and beyond and believes it is the only SSM that has a full complement of test data and evidence packages to satisfy the recently-released GCM and Towing Upgrade Technical Working Group test regime. This comprehensive proposed test regime developed by the AAAA, exceeds OEM requirements, and includes the following tests: 1. ADR35/05 Testing- Dynamic Braking performance, handbrake performance and gradient starts. 2. ADR88 ESC Performance Testing- Sine with Dwell. 3. Uprated Axle Assembly Testing- FEA (Finite Element Analysis), lab testing, material testing and CAD modelling. 4. SAE J2807 GCM Verification- Driveline and Power train thermal testing. 5. SAE J2807 Dynamic Stability testing as a combination. Utilising Lovells test trailer built to SAE standards. This is the only SAE test trailer in the country at present and features include, adjustable draw bar/axle position, adjustable centre of gravity, adjustable moment of inertia, load cells on all components, yaw sensors and data acquisition systems, adjustable aerodynamics and frontal area, adjustable weight distribution with rail slides and interchangeable suspension types. 6. SAE J266 Understeer testing as a combination. 7. VSB6 GCM verification calculations- Startability and Gradability. 8. Combination Vehicle and Trailer Braking test based on ADR35. 9. Towing Upgrade Chassis testing and ADR-62/02 testing. 10. Towing Upgrade Hitch receiver load testing and durability/cyclic frequency evidence by an independent DIRDC endorsed Test Facility. 11. ADR62/02 Evidence- Mechanical Connections between vehicles. 12. Laboratory Report ADR-62/02 - 1200lb Weight Distribution System. 13. Dynamic Strength Test Report - Lovells 5T Haul Ace All Terrain Hitch. 14. Laboratory Report ADR-62/02 - Static Test AS4177.1 -1200lb Weight Distribution System. 15. Laboratory Report ADR-62/02 - Static Strength Test. 16. Component Registration 47868 Lovells 5T Haul Ace All Terrain Hitch. 17. Component Registration 48275 Lovells 1200lb Weight Distribution System. 18. Component Registration 48274 Lovells Tow Bar/Drop Shank. Summary Lovells is committed to ensuring that it adheres to the best quality and standards when it comes to vehicle GCM revision. Lovells has been working with the AAAA as part of the GCM and Towing Upgrade Technical Working Group to make sure everyone in the industry meets these high standards. Now that the AAAA GCM and Towing Upgrade Technical Working Group has been wrapped up and released to the industry prior to Christmas, the findings will be presented to State and Territory regulators in May 2020.
01.01.2022 Just a few of the upgrades we have done lately. Call us for yours, taking 2021 bookings now. Stock is taking longer to get so if you are planning an upgrade let us know now so we can put your name on a stock order kit due end of January.
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