Is Type Approval all bad? Have we sacrificed freedom for safety?


Published on 17 April 2015 by Gill


Filed under categories: Features, Campaigning

Dear BMF
Thank you to Ted Foreman for his article on European Type Approval in the last issue of Rider.

Ted says: “in some sections of the motorcycling world, the only objective of Type Approval is to spoil everyone’s fun and is a backdoor tool to eradicate motorcycles from Europe‘s road.” 

Well Ted, I am one of those sections and I agree with that statement. I once owned an MZ. It was a lovely, simple bike and I could work on it myself. However, it and other similar bikes are now not available due to EU interference! You say that once Type Approval is gained by the manufacturer, “this enables the manufacturer to sell machines in unlimited
quantities into the European market, with no further testing by the Approval Authority”.
ta8Why then can I NOT purchase a brand-new sidecar outfit manufactured by leading manufacturers in Holland and other European countries to use in the UK? They are manufactured with the sidecar fitted to the right-hand side of the motorcycle, but it is legal for me to buy and use a left-hand-drive car!

However they CAN buy and use a new UK-type and built sidecar outfit (with the sidecar on the left), but we can’t use theirs? Some very well made sidecar manufacturers in France, Holland etc get their machines Type Approved, but cannot legally sell them over here. Surely your statement is wrong!

You say that mirrors are Type Approved, but how many bikes do you know where you can only see your elbows? You say this is being addressed, but if so, then how long has it been this way? Surely this should have been a priority years ago. I think you can still buy bikes with this fault! You mention the prop stand safety issue, as if the EU Type Approval was/is responsible for implementing this ‘non-ride-away safety feature‘. As far as I can remember (in the mists of time) a rider in the USA sued Kawasaki for
injury while riding away with the stand down. 

Very soon afterwards all manufacturers implemented these safety features. Why does a simple machine like an MZ (or similar) need ABS? I rode one for years without.
The Russian Ural sidecar outfit is still imported into Europe (including the UK). I understand that due to the EU they have had to fit fuel injection and disc brakes all around. The latter is probably due to pending ABS legislation. In my opinion, this will spoil another good machine. It runs okay as it is with carbs and a mixture of disc and drum brakes. I expect water cooling will be required next, if so then it will probably disappear along with MZ and the others.

ta6We don’t all like high-tech bikes with loads of different riding modes etc, which are supposed to be for our safety! I am sure that the EU, together with Type Approval, are trying to discourage the use of two-wheelers (and some three-wheelers). Type Approval is one way and impossible driving tests (for motorcycles only) are another way. As the BMF has to embrace politics on our behalf, I will say the following: Years ago I voted for a ‘Common Market’ not another level of government and certainly not for all this interference into my motorcycling pleasure.

Dave Greenwood

Dear Mr Greenwood
Thank you for you letter regarding my article in the last issue of Motorcycle Rider.
Please let me answer the interesting questions you raise in turn.

I too had many two-stroke MZ motorcycles, and very much regret that they are no longer on sale. However, to blame their demise on EU legislation is not completely correct. To answer the MZ issue we have to talk about the demise of the two-stroke engine. Engine emission legislation is of course the driver here, but it is not only the EU, global vehicle emissions legislation is broadly in step, so it has to be accepted that it would not be possible to market a simple piston ported, carburettor, two-stroke motorcycle almost anywhere in the world with the exception of South America.

ta3If a motorcycle manufacturer developed two-stroke technology which met EU performance for emissions, EU Type Approval would allow its approval. So what about Jawa’s 350cc two-stroke? Here is a simple two-stroke motorcycle rather like the MZ’s of the past, but still available new. How is this possible? European Whole Vehicle Type Approval allows Member States (Countries) to have their own limited country-specific approval schemes, but to prevent unfair competition, the numbers are limited and, unlike full European Whole Vehicle Type Approval, EVERY machine has to be inspected; it is the individual machine which is granted approval. This is called Motorcycle Single Vehicle Type Approval (MSVA).

Concerning the issue of motorcycle sidecars there is no provision for motorcycle sidecar European Whole Vehicle Type Approval simply because the sidecar on its own does not represent a “Whole Vehicle”, however there are provisions for a combination, and MSVA is also possible. There is nothing to prevent anyone purchasing a right-hand motorcycle/sidecar combination in the UK.

What is unlawful, is the USE of such a machine, but it is not EU Legislation which prevents the use of such a machine, it is a UK Government Statutory Instrument called “1986 No. 1078 ROAD TRAFFIC The Road Vehicles (Construction and Use) Regulations 1986. Use of sidecars regulation 93.” This has been in place since 1986.

The point you make about mirrors is a very good one, rear-view from motorcycles can be less than ideal to put it mildly. Rear vision requirements are contained within Directive 97/24 EC. Basically, all they say is that mirrors must give a clear view to the rear of the rider when seated, and they can be adjusted. However motorcycle rear vision is affected more than any other category of the vehicle by the physical size and build of the rider/driver.

Prop stands have been covered under Type Approval requirements for many years, and it is not unusual for global legislators to work to basically the same or similar standards to reduce the legislative burden on industry.

You are correct that from 2016, ABS will be a European Whole Vehicle Requirement for most machines, and hand in hand with this will be a disc brake fitment. But again, the legislation does not prevent the fitting of drum or any other type of braking system.
The reality is that most manufacturers fit disc brakes because they are simpler to ‘package’ and, due to economies of scale, cheaper to fit. It is generally accepted that, on the whole, they give a better braking performance.
ta5In the case of ABS it is unlikely that a drum brake system would be able to meet the cycle time requirements to meet the ABS performance standard, but as with the two-stroke issue referred to earlier, never rule anything out! 

In my time as a Type Approval Engineer I spent many hours circulating the MIRA test braking circuit testing motorcycle brakes for performance, so I have some experience in correctly testing motorcycle braking systems to legislative standards with instrumented machines to achieve maximum stable deceleration. 

I believe that ABS with the latest Electronic Control Units will cycle faster than even the most experienced test rider and therefore provide increased safety to motorcyclists. Concerning the wider point you make regarding the use of European Whole Vehicle Type Approval as a backdoor way of discouraging motorcycle use, I simply do not believe this is the case for the following reasons:

Legislation is developed through committees, upon these committees sit a number of experienced engineers, many of whom ride motorcycles.

ta4The UK Government’s Department for Transport International Vehicle Standards Branchare well respected and play a leading role in negotiating legislation on these committees. They are experienced engineers, many of whom started their working life on the shop floor getting their hands dirty working on vehicles. One senior Engineer in the Department even raced a Yamaha TZ 350 in the past, so they are in touch with what you and I would call ‘the real world’.

They will always seek the views of industry and the BMF before taking a position on proposed Legislation.

The key thing is, that as a valued BMF member, you are actively contributing to the process, and we are only effective if we talk from an informed position, using sound vehicle engineering arguments. Sadly, mass protests are not effective.

Do we get everything we want? No. But we do ensure that the resulting outcome is a practical, workable solution. This is the reality we all face in any type of negotiation which is more democratic than it is sometimes portrayed. I completely understand that passions can run high where the UK’s relationship with the EU is concerned, but it is my view that European Whole Vehicle Motorcycle Type Approval on the whole does more good than harm in protecting the average rider in the UK from dangerous products.

Best Wishes and safe riding.

Ted Foreman, BMF’s technical expert