My assessment of the ICV Rego process in NSW

[Baz]

I had this assessment prepared for inclusion in the next issue of Custom Kitcar Magazine, but unfortunately that publication is no longer in circulation. I have decided to circulate it on this Forum for general information and hope that a few of the issues I have highlighted will help kit builders in the future and also inspire Kit Manufacturers to make available and include to the client, far more applicable build / test data on their product when they sell a kit.

After what I’ve been through in the past 2 years, I feel that I am more than qualified to comment on such things.

BACKGROUND
I purchased my kit comprising the body, chassis, steering system and roll bars from the Replica Car Company (R.M.C.) in Perth, W.A. in October 2007. The build took about 2 years and the registration process about the same.

My first and most important piece of advice is select your kit manufacturer very carefully. The problem which I found is that by the time I reached the Registration Phase and was tasked by the R.T.A. to supply technical data concerning some of the components which I purchased from my kit manufacturer (R.M.C.), the management and employees from that Company had changed. They were not the same people who I dealt with 2 years earlier. The current staff could not supply the necessary information about how a particular part was initially constructed, what the grade of metal the part was constructed from and whether it had been heated or welded in the manufacturing process, as they weren’t employed by that Company when the parts were manufactured and sold.

STEERING SYSTEM
This applied particularly to my steering setup which was purchased from R.M.C. in 2007. That system included a VC Commodore Steering Rack and an Intermediate Steering Shaft which joined the Steering Rack to the Mitsubishi Sigma Steering Column.

At the request of the R.T.A., I emailed R.M.C. requesting specific information on how the Steering Rack was shortened from its original length. The current staff at R.M.C. could not supply that information as they were not with the Company when the product was sold to me in 2007.

I later emailed them again, requesting information for the R.T.A. on the specifics of the Intermediate Steering Shaft. They responded with incorrect information, stating that the shaft was from a donor VC Commodore. This was totally incorrect as the shaft fitted to my vehicle was individually fabricated from a steel rod. This incorrect information by R.M.C. was subsequently passed onto the R.T.A. causing embarrassment as well as wasting valuable time and money. As a result, I then had to have that shaft scientifically analyzed for strength and durability by virtue of Section 3.4.5. of the National Code of Practice for Light Vehicle Modifications (NCOPLVM) which relate to the ‘General Requirements’ for ‘Steering Modifications ‘.

Section 3.4.5.2. States:-

It is recommended that steering modifications be carried out by selecting production components which do not require cutting, heating, bending or welding.

Where such operations cannot be avoided, the operations employed must be determined and controlled so that the final properties can be predicted and verified on an individual component basis by a NATA approved materials laboratory, using Australia Standard AS 1554, 1985 Part 1 as a reference. The following post process testing by the laboratory is a minimum for such components:

(a) welded parts must have the weld material identified, a hardness test traversing across the weld area including the heat affected zone, an x-ray inspection and a Statement of weld integrity.

(b) Heated parts must be stress relieved, heat treated to the laboratory’s specifications and crack detected by a process as least as accurate as Magnafluxing.

(c) Parts which have been cold worked (where permitted) must be checked to ensure that the cold working is not excessive, stress relieved if required and inspected by a process at least as accurate as Magnafluxing.

What this means that any part which has been individually manufactured and has not been sourced from an ADR approved donor vehicle must be subject to extensive testing by the manufacturer who MUST provide documented evidence to the licensing authorities that the subject part can withstand all the forces that it may experience when fitted to the vehicle.

On the positive side of the ledger were the two Steering Shaft universals which secured the shaft to the column and rack. These were identified as being sourced from a donor vehicle (1976 Triumph 2000) and were therefore classified as ADR compliant.

KIT MANUFACTURERS
The majority of Kit Manufacturers supply information such as Torsion and Beam Test results for the chassis, Side Door Intrusion data, Torso, ELR, Outboard, Inboard and External Lap Seat Belt Anchorage data and Door Hinge data. Unfortunately the original data supplied to me by R.M.C. was issued for a prototype model and not issued in respect of each individual vehicle sold. It is imperative to satisfy the authorities that the information supplied to customers in relation to Torsion and Beam testing relate to the vehicle which they have purchased and not be in a generic form from a prototype test vehicle/chassis.

These data reports should be prepared by the Kit Manufacturer and contain endorsements listing the owner’s name, the date the tests were conducted and the chassis reference number which should also be stamped into the chassis in a conspicuous position. The required data for the Torsion and Beam test performed on my particular chassis was eventually located and supplied from an Engineers Office employed by RMC in 2007 and located in Adelaide.

The RTA now requires Signatory Engineers to provide evidence that the steering, front and rear suspension, seats and seat mounts, seat belts and anchorages, side impact protection and brakes meet the NCOPLVM and will take all forces that the vehicle can experience as well as being Australian Design Rule (ADR) compliant.

It should also be mandatory for Kit Manufacturers to supply Steering Rack mounting load and strength data and Seat and Seat Belt Anchor Pull Test data. Similarly, they should also be required to supply adequate data and structural calculations on side impact implications.

These tests could be performed on a prototype generic chassis/jig identical to that being purchased by the customer and provided to the customer at the time of sale. This would negate the prospect of the owner being advised by the registering authority at the time of his initial inspection for registration, that the data initially supplied by the manufacturer was deficient in detail.

All Kit Manufacturers should have a signed Memorandum of Understanding (MOU) with each Licensing / Registration Authority in each State of Australia. This M.O.U. would clearly outline the data / calculations that each Kit Manufacturer should supply to a client in order to satisfy the requirements of that particular Licensing / Registration Authority in each State.

The benefit here for both the Kit Manufacturer and the client are obvious. It is far easier to do these tests on a bare chassis in the manufacturing phase than being confronted with the prospect of stripping a completed car back to the bare chassis to satisfy the request of an RTA Inspector. Tests would only need to be repeated when there were changes to a chassis design by the manufacturers. This would also require a re-negotiation of the applicable M.O.U.

The RTA acknowledges the difficulties in assessing a vehicle to ADR 3 and ADR 5 (Seat and Seat Belt Mountings). These difficulties would be completely removed if Kit Manufacturers conducted and documented the tests outlined in the previous paragraphs.

This would also negate the current requirement for Signatory Engineers to provide an assessment of the installation, accompanied by detailed calculations that take full cognizance of the condition of the attachment points and the host vehicle as a whole. This assessment of these tests should also indicate that the components will be capable of withstanding the forces specified in the ADR’s.

Kit manufacturers should be supplying all this test data to the customer when an I.C.V. is originally purchased from them. At the present time, the N.S.W. customer has to track down and chase up all the engineering data required by the registering authorities.

SIGNATORY ENGINEERS
My next piece of advice is to select a competent Engineer. Don’t just rely on what you have heard from other people. Ask the Engineer to nominate a few of his past customers, get in touch with them and be guided on what they say before making your mind up to employ that person as the Signatory Engineer for your project.

The Engineering Signatory who certifies a modification to a motor vehicle must – where structural modifications have been carried out (including steering conversions) or a vehicle is individually constructed, ensure, by appropriate engineering analysis or tests, that the vehicle is structurally sound and is able to be safely controlled by the driver. (Road holding and Handling tests are not prescribed by the RTA, but it is recommended that such tests be conducted and should include heavy braking and cornering tests to the extremes that could be encountered on the road.)

A TRUE CHASSIS ENSURES A TRUE BUILD
I selected R.M.C. because it had a substantial chassis and above average side impact protection. The first activity after receiving delivery of the chassis and body was to remove the body from the chassis and have the chassis laser measured. This ensured that the chassis was square and true. A couple of minor adjustments were conducted which if ignored, would have caused major headaches further along in the build.

CONCLUSION
My dream for the last 48 years has finally arrived and I love it. I must admit that it has not been as a pleasant experience that I thought it might be. I have been put through an unacceptable and unnecessary number of hoops. Many barriers and disappointments have been placed before me in the process, but I have also benefited by the support and knowledge of the members of the Australian Cobra Club and Ozclubbies Forums. You guys know who you are and I would like to thank you publicly for all your help and support. Thanks also to Robert Jacobs who has professionally documented my build through this great magazine over the past 3 years and I'm really sorry to see it finally fold.

Thanks all for your help and support and I sincerely hope that this article will help others in attaining a speedy process of building their dream. I also hope that the initiatives that I have suggested will be adopted by Kit Builders and Licensing / Registration authorities throughout this great Country as I definately know that they read this Forum. (Hi to Tony and Hernan)


Baz.

[Gav]

Unfortunatly Baz, in the time between when you purchased the car and when you where getting it ready for rego, the goal posts where temporarily pulled down and then moved.

Perhaps as someone who now has jumped through the hoops, you could collate all your information so future ICV builders in NSW can benefit from your experiences?

[suthol]

An excellent and thoughtful post Baz, it's good to see you finally enjoying your retirement gift.

Hopefully Nemo's rego isn't too far away and we can hit the streets together, big thunder would probably have to tolerate the company of a few 4 pot screamers though

[Zedn]

Great post Baz, will be helpful to new builders.

I question the commercial viability or need for kit manufacturers to conduct all the destructive testing. I dont feel this would improve the safety of the vehicles and the cost of this testing would take many kits sold to recover. To complete all testing would likely cost the manufacturer $50-$100k by the time you include cost of building several chassis and components for testing.

FEA can provide results that are accurate enough for the risk to be managed with a factor of safety.

How many high rise buildings are built and demolished to check if they will fall down in the event of wind loading or eathquake? These contain much more occupants than a car

[Rob. Smith]

Nice Job Baz,
I've an RMC and my engineer (now retired due to the ridiculous RTA changes ) was very familiar with all the RMC chassis 'versions' from single rail to double rail. He was happy with my chassis (double rail) as well as being very conversant with the 'Original' staff at the RTA in Sydney. At that particular time (2002) my engineer was talking of these crazy changes and that the old school management of the RTA would disappear and bad changes would occur with no improvement to the engineering process.
He was right. This particular engineer took a great interest in my project as he does with others. He is genuinely interested as it is his hobby as well as a job. A lot of engineers are just doing a job. There is talk of a total reconfigure of the RTA itself and this may help or hinder the ICV industry. Interesting times ahead for NSW

[stephen low]

A thoughful piece Baz.

With an RMC clone in the G-Force I would concur with the apparent observation that there doesn't appear to be too much documentation being kept by some manufacturers on a chassis by chassis basis.

I had some similiar but far less in-depth questions asked and clearly the generic testing was also being used to support my chassis's design capabilities.

By the grace of a less officious and demanding Vic-Roads and quite perhaps the engineers I was using, the validities of the tests for my chassis were accepted. Must say though my chassis was quite old so probably close to the original version, if any changes had been made.

It may push the price up for manufacturers to better document the process but as you say, the manufacturer, owner and traffic authorities then have a far easier time getting approvals done. This in the end negates the extra expense anyway.

Appears things are a whole lot better up there with the bureaucracy now so one can only hope that future builders are less hamstrung.

Anyway enjoy the car now that you are there.

Cheers

Steve

[Zedn]

Originally Posted by stephen low

A thoughful piece Baz.

It may push the price up for manufacturers to better document the process but as you say, the manufacturer, owner and traffic authorities then have a far easier time getting approvals done. This in the end negates the extra expense anyway.

Unfortunately it will negate the industry away. The manufacturers are doing it tough as it is. I dont think they are making massive margins without adding a couple of grand to the cost of a unit.

Just to test my seat and seat belt anchors the quote was well over $10k plus the cost of seats, belts and chassis as all could be damaged. I dont know how many they sell a year but im guessing its in the 10s not 100s. That doesnt include any of the other testing.

Yes it would make it easier, but there just might not be any manufacturers in business.

[boxhead]

And not all States or Territories require paperwork to the extent that NSW ask for.
Not saying they won't in the future, also not saying that NSW may relax there standards a little aswell.

I still think the issue is with the NSW RTA and not with the manufacturers.
All other States and Territories in Australia follow the same ADR's as NSW, yet these issues are only raised in NSW?
There are no more accidents or deaths in other States (or even in the USA where standards are even lower), so why should people living in the rest of Australia be expects to pay for the extra testing and unrequired paperwork, just to appease the NSW RTA.

Baz, not having a go at you or your letter, but Australia is more than NSW, and there is even less chance that a kit supplier would supply a kit that is NSW spec, another that is VIC spec etc.
If I was a kit supplier, I would simply be labeling my product as "for race use only"

[boxhead]

In the end, the procedure needs to be the same Australia wide, somewhere between the NSW standard and the NT/WA standard.
What ever happened to these "groups" that where going to "do something about it"

Writing a letter for a small niche market magazine or a Internet website will not change things.....

[BMK]

Baz, thanks for your Thread. Mmm somewhere in this whole process there must be some common sense. Many of our cars are over designed and built. Perhaps a visual check would reveal that testing would not be necessary when mounts etc are obviously strong, thickness, bracket size, bolt size etc. etc. are obviously more than required.

[suthol]

Originally Posted by BMK

Baz, thanks for your Thread. Mmm somewhere in this whole process there must be some common sense. Many of our cars are over designed and built. Perhaps a visual check would reveal that testing would not be necessary when mounts etc are obviously strong, thickness, bracket size, bolt size etc. etc. are obviously more than required.

Unfortunately public servants deal with something called CMA.

Cover My Ar5e, this is the role of the engineer but some very poor ones over the years have ruined the professional and civil relationship hopefully things are now on the mend as most of the lazy or plain dodgy ones here in Sydney at least appear to have moved on

[suthol]

Got my completed report in the mail today, all 33 pages of it so off to get a blue slip and apply to the RTA for a VIN ASAP.

Watch this space.

Regards
Dave King

[Zedn]

Originally Posted by suthol

Got my completed report in the mail today, all 33 pages of it so off to get a blue slip and apply to the RTA for a VIN ASAP.

Watch this space.

Regards
Dave King

Good luck Dave,

Im just a bit concerned though because how will you know what to do with yourself after all these years when Nemo is suddenly finished?

Perhaps you could build a cobra!

[sideshow]

it all comes down to us becoming like the USA
where everyone sues everyone so like someone above
said they cover their arse
I had a fabricating and welding workshop get in trouble for
fitting a Nissan motor to a BMW
the mvria or whatever they r called said u are not allowed to
remove any part on any car and replace it unless u have a mechanics
ticket or licence so since he had enough knowledge from over the years
all he had to do is a 3 day course and an exam
now I'm pretty sure there are thousands of shops out there
that do mechanical work on cars but not licensed
this only happened when a customer complained to mvria about
an issue and it nearly ruined his business
its annoying how if a shop sells a steering shaft for a cobra it needs a certificate
but if they sell the same modified shaft and it's fitted to an old Holden
or similar no one really cares
I think a lot of these new shops will need to think about certificates
for any parts that will be fitted to icv cars
and owners will need a 1000 page folder to hand to rta to prove
every part has past the test
I hope they don't start doing testing on wiring or I'll have to change jobs

[*Cobber*]

Just like an aircraft when the paperwork equals the weight of the aircraft it's ready to fly.

I keep saying it, have a look at the UK rules they have a very healthy kit car business with standard easy to follow rules.

Well done for getting rego, enjoy.

[Jethrow]

Interesting aircraft related comment Cobber. However did you know, that the requirements to design, build, and fly your own aircraft are actually far less restrictive than it is to do the same with a car?

Airplanes are actually easier. They have a special category (like the ICV) but unlike the ICV, many or the rules and requirements are waived on the basis that they are personal use craft, and not for fare paying passengers or commercial work.

[Treeve]

G'day All,

The RMS (formerly known as the RTA) have issued information specifically regarding ICV registration in NSW. They have been very clear about the proposed method for obtaining registration, and it really is a simple process. Here it is as a summary:

1. A certifier makes a submission to RMS for approval to begin construction. There is a specific form known as the "ICV Submission" form, which must be completed
2. The certifier can track the progress of the submission from this point forwards
3. The RMS can approve construction and issue an RMS ICV reference number. They are also allowed to refuse issuing of this number, however it is unlikely to be rejected at this point.
4. When the vehicle is completed, the certifier creates an incomplete compliance certificate using the RMS ICV reference number, but does not use a VIN
5. The certifier (or the owner) can then submit the incomplete compliance certificate to apply for a VIN
6. The RMS assess the submission, and can either approve or reject the submission.
7. If rejected, the certifier and / or owner have to work to address any areas requiring further detail for the RMS
8. If accepted, a VIN is issued
9. Once a VIN is issued, the Certifier can then complete the Compliance Certificate using this new VIN
10. The owner can then apply for registration of their ICV

So, there are two areas where the RMS can say no, however the chances of them saying no to a submission to build from a first time builder is incredibly unlikely. I actually cannot think of any reason why they can justifiably say no at this point. The second point comes down to how thorough your certifier is, how well they have performed in audits and the quality of their report. To assist with a high quality report, a high quality build goes a long way.... This doesn't mean an expensive build, but it does mean a build where shortcuts have not been taken, and correct nuts, bolts, design etc has been used to best advantage.

I am currently working on (and hope to have ready for the start of January) a condensed version of what you would need for an ICV (even a scratch build). This would make NSW one of the easiest states to register in.

As a final note, NSW has considerable rules which affect us as builders, owners, and enthusiasts. Whilst we can sit and complain about how easy the other states have it, and how green the grass is on the other side of the fence, lets look at what we do have: A requirement for quality. The rulers are set as they are to make sure that what we put on the roads are of known quality, and that we have done an outstanding job to get them there. Standards for UK cars don't even include B&T tests or bump steer requirements. This alone should let us relax a bit and be proud that although the bar is set higher in NSW, we are also able to reach the level that is required of us.

From where I am sitting, the new scheme is a good thing, and will level the playing field across NSW and stop the goal posts from moving for a considerable length of time.

Cheers,

Treeve

Edit to add: I'm on the VSCCS signatories list for ICV's; I thought I should admit this straight up so you can evaluate my post with full disclosure

[Zedn]

Nice work Treeve,

Can you also confirm that VSB14 is now the rule book? Would also be useful info for people to know.

[Treeve]

Yes, VSB14 is applicable in NSW.

Read it carefully - there are many new ways to skin old cats.

No animals were harmed in the writing of this post.

Treeve

[Rob. Smith]

The certifier needs to be very rich. To cover the 10 million $ + insurance policy that must be paid for seven years after he retires. The test that must be done for braking and handling are far beyond the requirements of major auto manufacturers. Litigation started this whole ridiculous thing...and ask Baz. They can knock back an ICV for any simple excuse. A name change doesn't change a draconian system. Treeve, you can see I am bitter and twisted about the RTA. ( I had lots of stress when I registered mine) I sincerely hope the process has been 'cleaned up' and things start to go smoothly for future builders.