OFF THE WIRE
Special edition - periodical technical inspections
FEMA Newsletter
Special edition - periodical technical inspections
Dear readers,
Brussels rouses from slumber. While many of us were still enjoying trips on two wheels through our peaceful and exciting Europe, the laptops in the European Commission had been restarted already and the officials remembered immediately what they have been focusing on before the summer break: motorcycling!
In concrete terms: Road Safety Programme, technical inspections, rules for type approval.
The announcement of the Road Safety Programme already dispersed any hopes that the core problems regarding motorcycle safety will be tackled. Instead of encouraging the countries of the EU to install safe guardrails, to maintain roads properly and, critically, to raise other motorists' awareness, we are required to solve our problems by ourselves. Automatic Headlamp on, mandatory ABS, extended periodic technical inspection and updated anti-tampering measures are the Commissions' suggestions to improve our safety.
Most probably, these measures will soon be proposed to the Parliament and to the Council, where each member state has a say. FEMA fears that for a non-motorcyclist these measures might sound quite reasonable, therefore we have decided to illuminate the public. Not only that but the proposed measures are merely scratching the surface, some of them can be expected to be expensive and have no positive outcome at all.
This special issue newsletter exclusively deals with Periodic Technical Inspections. Read why it is naïve to assume that regular checks will lessen the accident rates. We also present the official FEMA position on the topic, report about interest groups pressuring for the inclusion of motorcycles into inspection schemes and the actions FEMA is taking.
I would also like to invite you to visit our PTI campaign website and to join us on facebook!
Ride free,
Chris Hodder Member of the Board of Directors of FEMA
FEMA position on periodical technical inspections
The European Commission is preparing mandatory Periodical Technical Inspections in Europe (PTI). FEMA was invited to discuss options for harmonization. FEMA made its opposition to extended testing regimes clear, and submitted its official position to the Commission officials.
Picture: Courtesy of MOTORRAD
FEMA,The rules for PTI differ considerably across Europe. In some countries tests are very strict, in others the motorcycle has to be presented to a testing centre quite frequently, and in several countries, there are no mandatory inspections for bikes. For the testing organisations the case is clear cut: the more testing the safer. FEMA puts this logic into question.
While studies commissioned by test companies like DEKRA or CITA regularly point at the safety benefits resulting from more PTI, most of the members of FEMA consider added inspections as an annoying and costly administrative burden. FEMA is convinced that motorcyclists are more aware of their vehicle than other road users. Therefore they maintain it more thoroughly. They do not require a highly qualified engineer to tell them that the headlamp is not working.
Less testing in Sweden, no safety benefit in Norway
In Sweden motorcycles are in such a good shape that the government decided to check them less frequently. The list of countries entirely lacking PTI for motorcycles is prominent: Belgium, Finland, France, Greece, Malta, the Netherlands and Portugal. The crux is, countries in Europe which installed testing regimes for bikes do not show improved accident figures.
In its position paper FEMA uses the numbers of testing organisations to show that an extended PTI regime for PTWs in Europe is not desirable. It also presents an independent study with surprising results from Norway: as predicted, more technical defects were detected after the introduction of more severe PTI for cars. But the actual goal, accident reduction, was not achieved. Accident numbers even showed a slight increase.
FEMA therefore calls the Commission to refrain from introducing harmonised PTI for motorcycles. Access the FEMA position on PTI here and read why the decision about if and how PTI is applied should be left to the EU member states.
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A call for language equality to the Commission
Citizens can contribute to the debate with a public consultation on Periodical Technical Inspections, available on the Internet until September 24th. But the consultation questionnaire is only offered in English - an obvious discrimination, which prompted FEMA to file an official complaint with the Commissioner for Transport, Siim Kallas.
FEMA President Gerard Livett. Picture: Wim Taal
As with all European legislative projects, a public consultation is held, based on a questionnaire that citizens and companies can access online. The results are then taken into account in drafting a new regulation or directive.
FEMA wants to encourage riders to express their opinion regarding PTI, which is seen as an administrative burden in many countries, with very limited potential to improve the safety of riders. As FEMA reported earlier, the Commissions' Road Safety Action Programme 2011-2020 plans to extend EU legislation on road worthiness testing/inspections to motorbikes and other powered two wheelers.
The testing organizations have a natural interest in testing
However, concerned citizens will soon find that their input is not all that welcome. Of the 27 official languages of the EU, only one is offered for the consultation: English. Budget cuts are claimed to limit the Commission's ability to translate the questionnaire. In a letter to Commissioner Siim Kallas FEMA President Gerard Livett expresses his disappointment.
In the letter to the Commissioner the FEMA President also points out: "We expect that the amount and content of the contributions received will reflect the choice of language on the Commission's part, leaving the field to major lobbying organisations and various industries who have stakes in technical inspections, and casting aside the voice of road users and small businesses across the continent. The results of such a consultation cannot and will not be accepted as representing the will of Europeans."
FEMA provides translations
FEMA considers the safety benefit of PTI for motorcycles as doubtful for the simple reason that countries with PTI regimes for motorcycles do not show improved accident rates related to mechanical failures compared with countries where motorcycles lack mandatory testing regimes. Yet it is important to let riders know of the consultation, to make sure they have their say.
On its campaigns website FEMA intends to provide riders with translations of the consultation form into as many languages as possible. The first to provide a translation was the French FEMA member FFMC. In France motorcycles are not yet part of a PTI regime. FEMA also created a Facebook site to call riders for participaten. FEMA is fighting for the status quo. Join or fight!
Click here to access the FEMA position statement on PTI.
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Who wants mandatory inspections anyway?
FEMA representatives were invited to join a stakeholder workshop this week, gathering influential organisations for a dialogue with the European Commission. At first glance that sounds pretty boring, but it actually revealed the driving forces pushing for PTI for motorcycles. Private testing organisations were there in force, presenting tougher inspections as the best safety option.
Picture: courtesy of MOTORRAD
Whenever the European Commission is inventing a new rule the public and the expert and lobby groups have to be involved before it is presented to the Parliament and the Council for final votes. Inclusion of the public (EU citizens) is usually dealt with by internet consultations. The public consultation on PTI is still ongoing and FEMA is calling for motorcyclists to participate [link]. At the same time various representatives of the industry, of the consumers and of the national administrations are invited to attend workshops where the content of the new regulation is discussed.
During these workshops the responsible Commission officials are present. They present the main goals of the new regulation and ask the stakeholders for their input. In the case of the Directive for Periodical Technical Inspections the goals were described as improving road safety, improving the free movement of EU citizens and realizing a common second hand market. In principle FEMA supports these goals.
27 countries, 27 systems of PTI
If somebody moves around within the European Union taking his television with him he won't find too many obstacles. The same holds for selling the television - for example a television purchased in Ireland can be sold in Italy without any legal or administrative trouble. But when it comes to a car or a motorcycle, the case is different.
Consider the case that a Swede is travelling on her motorcycle to Spain. She decides to leave her bike there for the next holiday and flies back to Sweden. No matter what, at some point she has to ride back to Sweden because she is forced to present her bike for a technical inspection every two years. If she is not back for the test in time, legally she wouldn't even be allowed to ride her bike anymore, so she would have to transport it back to Sweden in a trailer - just to present it to a PTI.
The problem simply is that Sweden does not recognize the PTI of Spain, and vice versa. In fact, every EU member state has its own PTI, with variation in what is tested, how it is tested and how frequently the vehicle has to be presented for testing. Similar problems arise when a registered vehicle is about to be registered in another country. In most countries vehicle registration is dependent on a valid national PTI.
PTI and road safety
Back to the workshop and to the third goal of the PTI directive: road safety. The attendees of the workshop were officials of national transport departments, representatives of vehicle manufacturing association, other transport industry representatives, people of all kinds of testing bodies and, the one and only non-state and non-profit organization, FEMA - the Federation of European Motorcyclists' Associations.
During the workshop, presentations were held either by the Commission or by people of DEKRA, a German private testing organization. What DEKRA does for living is testing, as well as deliver training for testers who do the testing. Organisations like DEKRA are able to test everything and they are willing to do so as long as they are getting paid for it. DEKRA had hired a professor who presented a cost-benefit analysis.
He showed that testing would be beneficial and that increased testing would be even more beneficial, unfortunately, accompanied by increased costs. The optimum of testing would lie somewhere in between more testing and a lot more testing. Of course that would hold true for cars and motorcycles to the same extend.
FEMA raised the simple question whether the costs of the consumer, taking half a day off to go to the test centre and paying the testing fee, had been included into the cost benefit analysis. The answer of the professor took about ten minutes, but essentially the answer was ‘no'.
Does more PTI lead to fewer accidents?
Since the professor engaged by the testing organization kept on mentioning benefits, FEMA wanted to know what exactly these benefits consisted in. ‘Better maintained vehicles' was the answer. But does that directly lead to fewer accidents? ‘That's what we assume'.
Unfortunately, that is what everybody assumes. In fact, no numbers were shown indicating that the number of accidents caused by technical defects is higher in a country with low PTI standards compared to a country where high PTI standards are in place. An independent study published in an independent scientific journal in 2007 examined the situation in Norway, comparing accident statistics before and after the introduction of more severe PTI for cars. The surprising result: no effect on accidents at all.
What about motorcycles? All present testing organisations called for inclusion of all powered two wheelers, meaning big and small motorcycles, scooters and mopeds, into PTI. This is rather obvious since it would mean more clients for them. Nevertheless the Commission seems convinced that including all two wheelers into PTI is beneficial. But what about the countries in Europe where motorcycles are already included into PTI, are their accident figures indeed better than the ones e.g. in Finland, France or the Netherlands which so far exclude two wheelers from PTI? Unfortunately this question has never been examined in the course of a proper study.
PTI is useless for most common technical defects
Arguing in favour of PTI against the background of safety issues is misleading. Even the numbers given by DEKRA show that the most common technical defect responsible for the accident of a motorcycle is related to tyre pressure or tread depth. If the actual intention is to lower accidents, then training and awareness campaigns are needed. A biannual technical inspection is hardly sufficient to ensure correct tyre pressure. Besides, hardly any country has included the measurement of tyre pressure into its PTI...
FEMA is not against PTI in general but against equal test procedures across Europe. Riders in Malta face different situations than riders on German highways without speed limits, just to mention one example. The Commission has to take this into account.
How to overcome market failures caused by varying PTI
During the workshop the representative of the Dutch Road Transport Department mentioned that a few of his fellow countrymen used to live in Spain during summer. In order to not making them drive their cars back to the Netherlands every two years just for having a PTI, the Dutch authorities follow a simple but clever approach: they accept a PTI carried out by a Spanish garage.
Taking the Dutch case as a guideline the European Commission could make all EU member states recognize each other's PTI. Every country could continue testing vehicles the way it considers as suitable, no harmonisation would be required. Wouldn't it be the less costly and the most user friendly approach?
Indeed the Commission is considering this approach, mandatory mutual recognition without standardization, as one of the possible options. The testing organisations are opposing as apparently they would not win anything. Many national authorities are opposing as well because they fear loss of control over their domain. FEMA hopes that common sense will prevail. Don't expect us to be quiet!
