LVVTA WELCOMES NZTA REVIEW OF LVV CERTIFICATION SYSTEM
LVVTA welcomes the review
The Low Volume Vehicle Technical Association (LVVTA) is welcoming the review that the New Zealand Transport Agency (NZTA) is undertaking of the LVV certification system, and foresees that the outcome of the review could well provide opportunities to make further improvements to the LVV certification system that has been in operation since 1992. LVVTA has had a long and solid relationship with NZTA and its predecessors (which are Land Transport New Zealand, the Land Transport Safety Authority, and the Ministry of Transport) going all of the way back to the initial development of the LVV certification system which began in 1989.
NZTA’s review of the LVV certification system
Tony Johnson - LVVTA’s CEO who was the initiator of the LVV certification system back in 1989 and has remained a key driver of it ever since - says that it is healthy for NZTA to review all of the vehicle certification systems in operation within New Zealand from time to time (which include WoF, CoF, Heavy, Repair, and Entry), in this case to ensure that the LVV certification system is operating as NZTA expects it to be. Additionally, LVVTA needs to have confidence that it is providing the level of technical rigour and LVV certifier performance oversight that NZTA requires. In order for NZTA to know whether they want the bar raised, left as it is, or lowered, they will obviously need to look into how the system is working, and then provide feedback to LVVTA.
NZTA wants to make sure that the various aspects of the LVV certification process are working well for everyone involved with the system; that the process is responsive and relevant, and that the technical requirements are sufficiently robust.
In order to determine where the LVV certification system is currently at in relation to where NZTA would like it to be, many of the key participants in the LVV certification process will have an opportunity to have a say about what they like and don’t like in relation to the current system. NZTA will be inviting people who use the LVV certification system in some way to comment on it, and offer their opinions and ideas, through an internet-based questionnaire. This questionnaire is being independently managed on NZTA’s behalf by Standards New Zealand.
LVVTA supports NZTA’s system review
LVVTA is very supportive of NZTA’s desire to review the LVV certification system. The LVV certification system hasn’t been reviewed by NZTA (or its predecessors) for some time, and it’s vitally important that LVVTA clearly understands what NZTA expects of the system, and that both parties’ thinking is clearly aligned.
Associate Transport Minister Craig Foss has said publicly recently, and quite rightly, that “The LVV certification process is about ensuring vehicles built from scratch or modified for a specialised purpose are safe to be on the road”. Associate Minister Foss’s view on road safety mirrors LVVTA’s most fundamental operating principle. Johnson is adamant that LVVTA will continue to take its responsibilities seriously, remain vigilant, and do everything it practically can to allow enthusiasts and the modification industry alike to continue to modify and build vehicles within safe and sensible engineering parameters.
Development of the LVV system
The current LVV certification system has been developed over 25 years, involving hundreds of technical experts from all walks of automotive engineering life during this time. A wide range of input into the system has been necessary because of the level of complexity and diversity associated with the certification of modified and scratch-built vehicles. By way of example, the LVV Standard 45-60 (Disability Transportation Systems) was developed over a period of eight years, involving a consultation process which included nine draft documents, five industry working group meetings, and input from approximately 300 people directly involved in the disability sector including modifiers, builders, importers, occupational therapists, health and medical specialists, users, formally-trained engineers, LVVTA’s technical committee and staff, Lotteries Board, Taxi Federation, and key officials across four Government agencies.
It can be easily overlooked that the LVV certification system does much more than just developing technical requirements and over-viewing the LVV certification inspection process. LVVTA applies much of its resources into areas including product and component assessment, component testing, publicising known safety problems and risks, and providing technical support to system users and industry groups, including supporting the NZ Police’s Serious Crash Unit and training front-line Police staff. One of LVVTA’s current projects is the design and construction of a cyclic test rig for assessing the durability of critical aftermarket automotive components.
Every day, LVVTA deals with people wanting to do something in a new, unique, or innovative way, and so the LVV certification system has been designed to be flexible and to continuously evolve as trends change and new technologies emerge. That said, while the LVV certification system encourages innovation, we have to be mindful that not all innovators innovate well. Most members of the motoring public would rightly expect that if people are allowed to modify motor vehicles that there is a robust certification system in place to ensure that the highest practical level of safety is incorporated within those modifications in order to protect the public from the potential risks that could accrue from unsafe modification work. LVVTA’s experience shows that many members of the modification industry in New Zealand do a very good job, and the quality players in the industry don’t want to see others in this industry taking short-cuts and putting people’s lives at risk.
For these reasons above the LVV certification system has to be robust; - and it wouldn’t have survived and continuously improved for a quarter of a century if LVVTA didn’t take its responsibilities very seriously. ‘Continuous improvement’ can be a bit of a well-worn cliché these days, but this is something that LVVTA has genuinely strived for, and has consistently achieved. “I think everyone understands that it’s better to have a system that demands a very high level of safety but still enables the hobby and the industry to prosper” says Johnson, “than to have a weak system that might provide an easy path in the short-term but fail in the long-term, leaving options for modifying vehicles in New Zealand that might be less palatable than what has been built up over the past 25 years”
Meeting the challenges
NZTA and its predecessors have all wanted the bar - in terms of safety-based technical requirements - to be set at a very high level, and this has resulted in the heavily safety-focussed technical standards that have been developed by LVVTA and co-signed by NZTA during the past 25 years. In 2006 NZTA’s predecessor LTNZ requested LVVTA put in place an in-house auditing regime to enable technical and administrative scrutiny to be applied to the certification documentation provided by LVV Certifiers when they apply for an LVV certification plate, and this led to the desk-top auditing (‘form-set review’) regime that has been in operation since 2007. In 2009 NZTA asked that an error recording system be implemented that would formally record technical and administrative errors made by LVV Certifiers, so that a view could be objectively made at any time of how each LVV certifier is performing in relation to his peers. This was introduced that same year and linked to the form-set review process, and has resulted in the formal recording of errors, which feeds quarterly into the continuously updated ‘Error Report Summary’.
Johnson is confident that NZTA will be pleased with what they learn from their review of the LVV certification system. “I have no doubt that NZTA will find, under whatever level of scrutiny is applied, that the various systems and processes that have been developed and implemented will not only meet but exceed what the Agency has asked and expected of us over the past 25 years, as we’ve worked together to build the LVV certification system.”
It’s widely-known that LVVTA has worked very hard to do a top-level job of implementing the ever-improving system, and the resultant system is generally recognised as world-leading, both from the point of view of the regulator, and that of the enthusiast and industry users.
Fresh thinking can be a big help
“The review should get some thinking and discussion going” says Johnson. “It’s very easy in any process or system-based organisation to say that we do this or that, because we have always done it that way, and fresh ideas and discussion can often result in improvements to an organisation like this. Any ideas or opportunities to build upon what we have, and make it more user-friendly and relevant without compromising safety is always welcomed”.