PM Abbott must immediately reverse the previous Governments unconsultative and very questionable April 2013 deletion of the ADR42/04(clause 10.3.1) requirement to extend engine exhaust outlets to the rear area of Motorhomes. This decision ignores a long-standing very commonly recognised RV Industry best practice for over 35 years to position the exhaust outlets at the rear area of Motorhomes.

What are the real reasons to delete it?

Canberras DIRD (Truss-Briggs duo) support this deletion because other global markets dont extend RV exhausts to the rear. SO what? DIRD believes the Euro exhaust emission standards are so stringent the exhaust outlet on new cab/chassis vehicles imported into Australia - to build caravanson - can be positioned anywhere along the RHS of the vehicle and present no danger to health and safety!!  (One hopes the Truss-Briggs duo never ever decides that diesel engine exhaust fumes for winter warmth can be directed into a Motorhome interior because the fumes are NOT UNSAFE!        

This totally flawed deletion decision completely ignores the mid-2012 World Health Organization Study (WHO) and also the President of the AMA in his March 2013 Pollution Report to Canberra both of which clearly state that diesel exhaust fumes are carcinogenic,worse than passive smoking, dangerous to health, particularly for the aged,infirm and babies or those with asthma etc.or anybody with upper respiratory tract breathing problems.WHO stressed that education programs should be instigated immediately to alert the public of the dangers.

Health risks increase with the length of time exposed to fume inhalation.

In September 2011Anthony Albaneses DIT public servant team was ordered to cover up its February 2007 mistake and try to justify this ADR exhaust deletion in Australia bycarrying out an air quality test on two (2) Avan Ovation M3 Motorhomes. The engine exhaust outlets on both vehicles remained under the front cabins and had not been extended to the rear area as ADR42/04 required. The air test contractor proved that diesel engine exhaust fumes entered the interiors of both Avan Ovation M3 Motorhomes not only through a purpose-built hole through the floor lower airvent but also through openable/adjustable windows,airvents and all other openings NOT permanently sealed eg. unsealed outside storage locker doors  etc.

HOWEVER,without submitting any supportive medical or scientific evidence whatsoever  DITS contractor concluded that the fumes were NOT AT UNSAFE LEVELSas per WorkSafe data!!

(NB:WorkSafe does NOT have any such data relating to toxicity levels of diesel fumes in the small confines of Caravans and/or Motorhomes.)

SO, the DIT contractor has lied about WorkSafe data supporting this flawed conclusion.

Nobody in DIT either had the medical expertise/ qualifications to support the contractors claim which is untrue/false and totally misleading and deceptive.

The AMA President in his abovementioned Pollution Report stated therein that diesel fume particulates are so microscopic they cannot be isolated and detected!!

SO, it is grossly negligent and a betrayal of public trust for DIRD executives or anybody anywhere at anytime to ever claim Avan Ovation M3 Motorhomes built in Pakenham,Victoria since February 2007 are all totally safe and their unextended engine exhausts and the unroadworthy hole through the floor airvents present no risk to health and safety just because there have been no health and safety problems reported.

Canberras DIT public servant bureaucrats took almost 20 months - September 2011s air test to April 2013 - without any State or Territory Transport Minister consultations to decide to officially document this stupid unnecessary ADR deletion.

Motorhomes are now classified as GOODS CARRYING VEHICLES!!??@#$&^! Goods Vehicles:     A vehicle constructed for both the carriage of persons and the carriage of goods shall be considered to be primarily for the carriage of goods if the number of seating positions times 68 kg is less than 50 percent of the difference between the Gross Vehicle Mass(GVM) and the Unladen Mass. 

NB: Current available obesity data for 45 to 55 years old claims the average weight is about 90kgs!! 

 MEDIUM GOODS VEHICLE (NB) A goods vehicle with a Gross Vehicle Massexceeding 3.5 tonnes but not exceeding 12.0 tonnes. (NB:There are no goods in a Motorhome loaded for delivery &/or pickup. Virtually everything in a Motorhome is either a permanent fixture, fitting or an essential accessory for human habitation!) No reasonable thinking prudent person would agree to Motorhomes being classified as goods carrying vehicles. 

 HEAVY GOODS VEHICLE (NC) A goods vehicle with a Gross Vehicle Mass exceeding 12.0 tonnes.  NC is the only category to which ADR42/04 clause 10.3.1 applies

Medium Goods Vehicle (NB): sub-category NB1 (3.5 4.5 tonnes) This is the most common Motorhome GVM range because they can be driven on a normal car licence. An endorsed drivers licence is required to drive any vehicle over 4.5tonnes.

My conclusion:

Anybody anywhere anytime thinking of buying any Motorhome brand must first confirm its compliance with all ADRs,all Australian Standards - especially the LPG Standard - ,all roadworthy regulations( within the State of registration) and also with all the commonly recognised and adopted  best practices of the RV Industry. Not to do so is a real risk of buying a lemon.

 www.motorhomebuyertips.com provides some relevant compliance information.

(FOOTNOTE: Health and Safety risks associated with CO (carbon monoxide) poisoning. What actions were followed up on and implemented by this Government on the recommendations of the 2012 CO Study: www.scer.gov.au/workstreams/energy-market-reform/gas-appliance-safety strategy? (This study came about after the tragic death of two youngsters in Victoria from CO poisoning).

This report recommended an immediate public awareness campaign be set up to:

*identify best practices and encourage the sharing of information to overcome CO poisoning risks in residential premises and recreational vehicles (Caravans and Motorhomes). Diesel fume inhalation is a health risk. Technical and other safety authority jurisdictions must liaise to achieve a consistent and common approach.

 I hope this Study has not gathered cobwebs and faded into obscurity?

April 2015                                                                                                        E.& O.E