LVV Certification

Phone John Brett Technology 0800 LOW VOLUME (0800 569865)

We have now discontinued LVV Certification

We suggest that customers whose vehicles require LVV Certification:-

Try to contact a LVV Certifier (good luck with that!), or

Advise NZTA on 0800 108 809 that you are unable to get LVV Certification.

Meanwhile, if you have a query, check out the post "Low Volume Vehicle Certification- Your Queries" on the right hand side bar. All queries posted will be answered.

Thank you,

John Brett

John Brett

John is a professional engineer with 50 years experience.

John has designed and built many cars, trucks, and vehicle assembly facilities.

John has worked on design of roads, bridges, cranes, transmission towers, and buildings, and operation, maintenance and upgrade of hydro and gas turbine power stations.

John was a LVV Certifier for 13 years. John has long been a whistle-blower, expressing the view that the LVV system is dangerously deficient. John's authority was revoked in December 2012.

John rides a 1992 Yamaha FJ1200ABS, and is also a keen road and off road cyclist.

NZ Designed Wheelchair vehicles – a needless mess-LVVTA and NZTA were warned in January 2011

In January 2011 the Auckland LVV Certifiers collaborated to write this report
ORS Submission2

Page 8 points out the lack of any suitable standard for Body Reconstruction, and the likely consequences
No action was taken- except to attack those Certifiers who contributed.

On this site is part of the Body Reconstruction standard that I have used for the last 10 years
Body Re-structure

Adoption of such a standard would have prevented the Skoda Yeti UDM Debacle

Adoption of the recommendations in the ORS report could have avoided deaths and injuries that have already occurred, and avoid deaths and injuries likely to happen in the future

Courtesy Automotive News:
NZ Designed Wheelchair vehicles banned here, but on show at VW event in Europe

http://www.automotivenews.co.nz/nz-designed-wheelchair-vehicles-banned-here-show-vw-event-europe/

Skoda-Yeti-

Skoda-Yeti-

New Zealand-designed vehicles for wheelchair users in Europe will go on show this month at an international Volkswagen Group exhibition in France – while transport bodies here continue to ban almost identical vehicles from our roads.

The two converted Skoda Yetis (one pictured above in France) are the first of 10 to be built for French special needs people before Christmas by Waiuku company U Drive Mobility (UDM) at its subsidiary company’s plant near Bordeaux. Two of UDM’s Waiuku technicians – production manager Dale Stevens and fabricator Ursa Faithfull – are working at the French plant.
Skoda in France

Skoda-at French Factory

Skoda-at French Factory

French factory floor: Kiwis Dale Stevens (right front) and Ursa Faithfull (right back). The three other men are French.

UDM built and sold eight of the same vehicles for NZ wheelchair users but they were ruled unsafe by the Low Volume Vehicle Technical Association last year and taken off the road by its ruling body, the NZ Transport Agency. The converted Skoda Yetis allow wheelchair users the freedom of driving the cars themselves.

The Skodas are still banned, although UDM director Roger Phillips and the NZTA have been working to resolve the stalemate. Phillips in the last 24 hours has written to Prime Minister John Key, Transport Minister Gerry Brownlee, and NZTA chief Geoff Dangerfield in an effort to move things along.

The NZTA ban means the eight NZ clients haven’t been able to use the vehicles for the past 14 months. One of the eight, a Wellington women, died last month without ever being able to use her car. The remaining seven call themselves ‘the invisible victims’ and want the NZTA to lift the ban so they can enjoy the open road again.

UDM makes major changes to the original Skodas, including cutting out the steel floor and replacing it with a lighter aluminium composite floor that sits lower to accommodate, in part, a ramp for wheelchairs.

Skoda Yeti at French Factory

Skoda Yeti at French Factory

The finished U Drive Mobility product

The ban centres mostly on the replacement composite floor. The LVVTA – set up in the late 1990s to certify hobby vehicles such as hotrods – continues to say the new floor weakens the overall structure of the vehicle, although it admits it doesn’t have a certification standard for composites. The NZTA wants the floor reinforced.

UDM cites expert analysis that says the composite floor is plenty strong as it is. Indeed the French government’s vehicle test facility, UTAC, has passed the converted Skoda for European Union certification. Phillips’ French distribution company ACA – a division of UDM Europe – has been given a $NZ600,000 provincial government grant to kickstart production. The two Skoda vehicles bound for the VW Group (VW owns Skoda) exhibition in Toulouse are the first products of the grant.

NZ Government agencies and ‘the Italian job’

The same names and faces continue to crop up when you look into demand in NZ for wheelchair-access vehicles. Many of the government agency people involved in the current standoff with UDM and Phillips were also in the picture when the Accident Compensation Commission bought 90 special needs vehicles in 2007-2009 from Italian company KIVI.

They were Kia Carnival people-movers, shipped from the Kia factory in South Korea to Italy and converted by KIVI for wheelchair users in NZ. There were 40 short-wheelbase units at $NZ89,599 each, and 50 long-wheelbase examples at $NZ94,825 each. They were signed off by allegedly unqualified NZ Government agency people at the KIVI plant, about 50km from Turin. All up the cars cost the NZ taxpayer $NZ8.325 million.

Upon their arrival here, a heavy vehicle engineer contracted to ACC said he was asked by a top ACC executive to check out one example. The engineer, along with a fellow from the NZTA and another from the LVVTA did so. He then sent a report dated November 10, 2008, to the ACC listing eight major faults and declaring the converted Kias unfit for NZ roads. His was the only signature on the report.

One of the faults was the replacement floor, the design of which was not “an accepted engineering practice,” he wrote. “There is no continuity of under-floor strengthening from the front of the vehicle to the rear as was in the original vehicle construction.” And the new floor was made of “flexible” steel that, in an accident, could “distort upwards into the passenger compartment”. He could find no documentary evidence, he wrote, that the vehicles complied with European Union standards.

A week later he got a letter from an NZTA executive saying it had had a complaint from the ACC about him and that he had better pull his head in if he wanted to remain a contractor. There began a chain of events that showed both government agencies didn’t have a clue about what they had bought from Italy for NZ$8.325m.

Watch this space …

About the Author: Alastair Sloane
Alastair Sloane has been a newspaper journalist for more than 40 years. He was the motoring editor of the New Zealand Herald for 16 years from 1996 until 2012. He owns a 1968 VW Beetle. Best days at the wheel include doing part of the Land Rover Camel Trophy route in Papua New Guinea, driving a Nissan Patrol over earthquake-hit roads in Guatemala, and a Ferrari Italia on Enzo’s old hill-climb road in Italy.

HAS THE LOW VOLUME VEHICLE SYSTEM FAILED?

The Low Volume Vehicle System has failed in the following:-

The LVVTA have failed to develop and maintain LVV Standards- SEE- ORS Submission2
The LVVTA are failing to maintain an acceptable standard of safety of vehicles modified. LVVTA DANGERS- THE FACTS
I understand that another Coroners report is pending, concerning a fatality resulting from the failure of an LVV Certified trike.

Certifying a Porche Spyder

Certifying a Porche Spyder

QUESTIONABLE OPERATION OF THE LVVTA
The LVVTA appears to be being operated in an illegal and questionable manner.
Here are two examples of the sort of questions that do need to be asked and answered before a way forward for the LVV System can be found:

QUESTION 1 How can the NZ Transport agency justify allowing the LVVTA to make Certification judgements?
The LVVTA have a contract for ‘Desktop Auditing’ to ensure LVV Certifiers are meeting the LVV Standards, however the LVVTA appear to be making Certification decisions under this guise.
We can see no provision in any legislation authorizing NZTA to allow this.

QUESTION 2 On what basis does the LVVTA assume that their knowledge is superior to that of the LVV Certifiers? None of the LVVTA Staff are LVV Certifiers, and do not even meet the requirements for many categories. Yet experienced LVV Certifiers have their judgement questioned, are required to accept the judgement of the LVVTA, and are reported to NZTA for ‘incorrect’ decisions. Several recent incidents have proven that the judgement of the LVVTA can be seriously wrong.

CONSEQUENCES
The LVV system is failing to retain the skilled Certifiers on which the system depends- (my opinion- but count them!)
The LVV system is failing to meet the needs of vehicle modifiers- the number of Certifications is falling whilst the number of vehicles and the number of mods needing LVV Certification are rising-

1…….Abandoned Certifications We receive continuous enquiries for LVV Certification, from all over New Zealand.
We give out the phone numbers of other Certifiers, we even contact them ourselves on behalf of customers.
In the end, we are left with sheaves of job-sheets, for vehicles which WILL NEVER BE LVV CERTIFIED

2……Modified cars exported- We are aware of many modified and scratch-built vehicles EXPORTED to avoid the LVV system in NZ

3……Modifiers leaving the business- We are aware of PROFESSIONAL MODIFIERS (many with export business) who have CLOSED THEIR BUSINESSES or moved out of NZ.

U Drive Mobility are one recent example of this- now building in France

4…..Avoidance of LVV System Motor-home builders IN NEW ZEALAND switching to Certification to ADR Second Stage system, to avoid the costs, delays, and irregularities of the New Zealand LVV system. Private modifiers are being forced to drive vehicles without LVV Certification

Uncertified vehicles

Police at the bottom of the cliff (Ambulances not visible in this shot)

5……Soaring costs-
The LVVTA levy, has increased, with more increases anticipated, as legal and insurance costs start to bite.
LVV Certifiers have increased their charges to cover time they now require to process Certifications.
In Auckland the total cost to the customer for LVV Certification has increased by an average of 25% in June 2014.

This means that to LVV Certify say, a set of wheel spacers, or adjustable platform suspension struts, will now cost the vehicle owner $550 to $650, which could exceed the cost of the modification.

If NZTA loses faith in the LVV System, (Quite likely)
it is possible that:

1 … Minor Modifications: TSD agents, or WOF agents be authorized to pass a range of minor modifications

2 … Self- Certification: Professional Modification businesses (seat installers, motor-home builders etc) be accredited to Self-Certify

3 ….Hobby cars and Hot-rods- (a very small part of the LVV picture) could be left out in the cold, are unable to be driven on the road.

Not road legal

Going to the Beach Hop?

4 …. The LVVTA and LVV Certification plates become history.

IS THIS THE FUTURE WE WANT?

How about some clear thinking about the LVV System of the future?

1 Trust the Certifiers to do the job they are appointed to do. Cut LVVTA out of the Certification process. Allow Certifiers to make their own plates, or use a Certifier appointed Plate printing contractor.

2 Introduce proper “Certifier Training”, conducted ‘on line’ and on the job, by Certifiers or Industry Professionals, (not by the LVVTA) and allow proper technical debate to occur.

3 Allow Certifiers to Certify to proven International Standards if they choose, instead of faulty LVVTA Standards.

4 Form a Certifier controlled “Standards Committee” to develop and change LVV Standards, instructing LVVTA to print and distribute.

5 Simplify Certifier Categories to say “Mechanic based Certifier” (able to do most certifications) and “Engineer Certifier” for situations where the skills of an Engineer are required. Allow “Engineer Certifiers” to consult to “Mechanic Certifiers” when required.

HERE IS AN EXAMPLE OF A VERY NEAT NISSAN SKYLINE UTILITY

This vehicle was built to our specifications, provided when I was still a Certifier.

Note the folded box beams connecting the Wheel-arches to the B-pillar, to replace the structure of the C-pillar and rear cant rail. The B-Pillar has been buttressed to about 400 mm depth, to withstand the bending moment from the eccentric load from the box-beam, and transmit loads to the upper cant rail.

See our new resource page about Body Restructure

Nissan Skyline Utility

Nissan Skyline Utility

LVVTA DANGERS:- THE FACTS

DISCLAIMER
THIS ARTICLE CONTAINS FACTUAL STATEMENTS MADE WHICH ARE VERIFIABLE FROM OUR CERTIFICATION RECORDS, COURT RECORDS AND OTHER SOURCES
We have been threatened with Libel action by Lawyers acting for Mr Johnson of the LVVTA, and accordingly have:-removed some clauses, and changed others that were mentioned. We have also made the offer to Mr Johnson’s Lawyers to consider changing or removal of any other statements that they still consider libelous

Mr Johnson would like the entire article removed, however as the CEO of an organization charged by NZTA with ensuring Public Safety, I believe that Mr Johnson CANNOT place himself above public scrutiny and comment.

The road toll has fallen to record lows, see annualroadtollhistoricalinformation

A large part of the improvement in safety is attributed to safer vehicles. Safer Journeys See Page 24. The LVVTA Standards exhibit no understanding of modern vehicle technologies, although LVV Certifiers have to deal with the implications of modifications on modern vehicles.

The Low Volume Vehicle system in New Zealand is failing to make the contribution that it should- Modified vehicles are being LVV Certified and allowed on the road with known safety issues, (Facts shown below) and resultant avoidable deaths and injuries occur and will continue to occur.
It is argued by Mr Johnson’s Lawyers that only one death so far has been formally attributed by the Coroner to faulty LVV Certification, and that any further discussion of safety will be regarded as defamatory to Mr Johnson.

A report by a group of LVV Certifiers identified some of the shortcomings in the LVV system, in a report compiled in 2010, and published in January 2011. This was presented to the LVVTA and to NZTA.
The recommendations were ignored, and no action was taken. ORS Submission2

The Low Volume Vehicle Technical Association controls the Low Volume Vehicle Certification system in New Zealand. It is
NOT an association of Low Volume Vehicle Certifiers, but an association of mostly enthusiast groups, but does include VANZ, the association which represents the disabled community.

The LVVTA has wrongly promoted itself to be effectively the ‘Low Volume Vehicle Technical AUTHORITY’ and not only writes LVV Standards, but audits each LVV Certification and directs LVV Certifiers on what can be Certified (refer to the current LVV ORS document)
The LVVTA has set itself ABOVE the Certifiers and appointed itself the sole technical authority on all matters, forgetting that its expertise and knowledge relies on that of the LVV Certifiers and of the modification industry.

LVV Standards are not based on overseas standards, but appear to derive from the old ‘Hot Rod’ manual. This means that e.g. seatbelt installations engineered to meet International Standards (ADR, E, JIS, FMVSS etc ) do not comply with the LVVTA (Hotrod) standards. This also means that New Zealand Installations can be sub-standard, and fail to provide the level of protection available in vehicles in other countries.

The LVVTA Standards are so inadequate that each vehicle certification requires special consideration from the Standard writers- the LVVTA.

This is in contrast to e.g. the Building Industry, in which Standards are developed with input from all sectors, Builders, Architects, Engineers, etc. The Standards are published by SANZ, which plays no part in their implementation.

The following article has been published in major newspapers, and reprinted on this site for comment. wheelchair-user-cars-pulled-from-roads

TV3 have also picked up on this item-TV3- NZTA pulls disability vehicles off the road

Axle Failures

Axle beams made of Cast Iron have been approved by the LVVTA. Some axles have failed, and lives remain at risk.

Failed axle showing brittle failure typical of Cast Iron

Failed axle showing brittle failure typical of Cast Iron

Lucky this vehicle was going so slow

Lucky this vehicle was going so slow

Beam front axles have been made from Forged Steel, in cars since the Ford Model T, and in all railway vehicles before that.

Forged Steel has high strength, and high fatigue resistance.

Hot Rod enthusiasts have fitted heavier engines, more powerful brakes, suspension systems (such as ‘Hairpin” radius arms) which apply torsion to the axle.

Now Hot Rod enthusiasts are demanding ‘Dropped Spindle’ Axles, which apply even more loading in the critical areas.

Some suppliers are offering Drop-Spindle axles made from Steel Forging.
Other suppliers are offering axles made from Cast Iron.

A comparison of the properties of Nodular Cast iron and Forged Steel:
Fatigue Performance Evaluation of Forged Steel versus Ductile Cast Iron Crankshaft: A Comparative Study

The yield strength of the forged steel is 52% higher than that of the cast iron, and the forged steel fatigue
strength at 106 cycles is 36% higher than the ductile cast iron The forged steel has a factor of 50 longer life than the
ductile cast iron

This evaluation is based on the grade of Cast Iron known as “Nodular” or ‘Spheroidal Graphite” Iron.

Nodular Cast Iron appears to be a poor substitute for Forged Steel for Axle beams, and is likely to result in eventual fatigue failures.

Mr Johnson admitted at a LVV Certifier training session that he had no knowledge of these grades of cast iron. From this, I assume that he believed that the axles being supplied were ordinary ‘grey’ Cast Iron, which is brittle, with a tensile strength below 140 Mpa, and unsuitable for any structural application such as this.

Most of the axles supplied appear to have been ‘Nodular Iron’, however some have been ‘Grey Cast Iron’. Axle failures have resulted, fortunately without injuries or deaths, so far. The LVVTA is now carrying out Quality Control inspections of axles (since the manufacturer does not) to attempt to identify the grade of Cast Iron.

LVVTA appear to have based their decision to allow these axles on the basis that other Hot Rodders in other countries use these axles. Following this logic, there would be no need for a Low Volume Vehicle Certification system in New Zealand, so long as everyone just copied what Hot Rodders did overseas!

Professional oversight would have ensured that the right questions would have been asked at the start- e.g.
“What is this material?”
“What are the properties of this material?”
“Where is the evidence that the material meets this specification?”
“Would these components be FIT FOR PURPOSE?”.

What more evidence is required that the LVV System has outgrown its origins and originators, and in the interests of public safety needs to be replaced by a professional certification process?

HUNDREDS OF UNSAFE TAXI-VANS- PASSENGERS RISK DEATH OR INJURY

Rear-facing seat, lacking strength to restrain occupants frontal impact

Rear-facing seat, lacking strength to restrain occupants in frontal impact

Rear-facing seat- view from front.  No reinforcing beam fitted

Rear-facing seat- view from front. No reinforcing beam fitted

Vehicle occupants are required to be restrained under frontal impact.
In front facing seats, the primary restraint is by seat-belts.
When seats are rearward facing, the seat becomes the primary restraint.
The loads from restraining passengers in 20 G decelleration is huge- around 1600 kg, or 16 Kilonewtons. Normal seat backs will fail at a fraction of that load.

The LVV Seat Standard 185-00 (introduced in 2002) has required that rear-facing seats be suitably reinforced, usually by a transverse cross-beam of 65 x 65 x 5 mm box section bolted to the vehicle body.

This requirement was ignored by a certain commercial seat installer, who continued to install unsafe rear-facing seating.
These installations were wrongly LVV Certified for 7 years, but never challenged by the LVVTA
The installer claimed to have an engineering report to justify their seat installations.
Concerns were raised by LVV Certifiers at a Certifier Training session, and Mr Johnson stated that these seats were justified by an Engineering report from TSL, which he did not believe was correct.
Nobody in the LVVTA was prepared to challenge the engineering report.

John Brett became the LVV Certifier for this company in August 2009. John inspected the Engineering report, and found that it DID NOT justify these seat installations.
John required that future rear-facing seat installations meet the LVV Standard 185-00, and ensured that a transverse cross-beam was fitted to all subsequent Certifications

This is supported by our Certification documents for the first vehicles FAILED by us, we still have copies of the FAIL SHEETS

Mr Johnson received complaints from the Installer, and from TSL about Mr Brett failing the unsafe seating. Mr Johnson’s response was to arrange the reinstatement of a LVV Certifier , and arrange for this person to become the LVV Certifier for this company.

It is not known whether the unsafe seating continued to be installed.

ALL OF THIS HAS BEEN ADMITTED BY MR JOHNSON UNDER CROSS EXAMINATION DURING MY APPEAL HEARING

This means that for 7 years (2002 to 2009) every vehicle built by this company, fitted with rear-facing seats, failed to meet the required standard.
This means that every passenger who travels in any of these hundreds of vehicles is at risk of being thrown out of the vehicle windscreen in any frontal impact, after impacting on the driver and front row passengers.

THEREFORE IT IS A TRUE STATEMENT THAT LARGE NUMBERS OF UNSAFE VEHICLES WERE KNOWINGLY ISSUED WITH LVV PLATES BY THE LVVTA.

IT IS ALSO AN UNTRUE STATEMENT BY MR JOHNSON THAT AS SOON AS HE BECAME AWARE OF THE PROBLEM HE CHALLENGED THE REPORT AND REJECTED THE CERTIFICATIONS.
These unsafe certifications continued until I stopped them. Even then, Mr Johnson arranged for me to be replaced as the Certifier because the Modifier complained about me failing the unsafe seat installations.

The rear-facing seats in the unsafe PSV’s met the “20 times own weight” loading of the seats in this video:-

This would be similar to the outcome in a frontal impact- visualize rear-facing passengers being thrown forwards-

WHAT ACTION IS NZTA GOING TO TAKE TO REMEDY THESE UNSAFE PASSENGER SERVICE VEHICLES?

What more evidence is required that the LVV System has outgrown its origins and originators, and in the interests of public safety needs to be replaced by a professional certification process?

BODY RE-STRUCTURE- WHAT WOULD THE LVVTA KNOW?

Body Re-structure is defined in the ORS as when a body structure has:-

(a) “all body modification, restructuring, and configuration changes, that retain the vehicle manufacturer’s occupant protection systems and structures forward of the A-Pillars, and complete (bolt off-on OE Body type) body substitution: and
(b) all chassis and sub-frame modifications, but not complete chassis substitution or complete chassis or rear half-chassis design and construction, or complete sub-frame changes”

Ford Falcon Stretch Limo Convertible

This vehicle was subjected to rigorous beam and torsional bending tests

U Drive Skoda Yeti converted to be wheelchair accessible

These vehicles have had a complete re-construction of the floor.

The criteria for LVV Certifiers in this category are defined in the ORS as:-

(a) have had two years experience operating as a Category ‘1B Modified Production Extended’ LVV Certifier, and
(b) have completed relevant and appropriate formal motor body structure training: and
(c) have an appropriate level of knowledge, expertise, and practical experience in the modification and adaptation of vehicle structures.

There are NO LVV Standards relating to Body Restructure, and NO guidance in the “Hobby Car Manual” for this type of work.

There is NOBODY working for the LVVTA who meets ANY of the criteria for a 1D Certifier.

Despite this, the LVVTA have set themselves up as ‘Judge and Jury’, as evidenced by the provisions of the ORS. A reasonable person could reasonably come to the opinion that the LVVTA have promoted themselves to be the “LOW VOLUME VEHICLE TECHNICAL AUTHORITY”

The Skoda Yeti vehicles have all been ordered off the road by NZTA, presumably at the behest of the LVVTA
The reason given has been that of safety.
However, no-body at the LVVTA is competent to make any judgement about the safety of such Certifications.

What has motivated the LVVTA to make such drastic decisions without proper engineering justification?
A ‘Complaint from a concerned member of the public’- or from a jealous competitor? NZTA need to come clean on this to avoid any suspicion!

TV3 have picked up on this now, see- TV3- NZTA pulls disability vehicles off the road

What more evidence is required that the LVV System has outgrown its origins and originators, and in the interests of public safety needs to be replaced by a professional certification process?

Wheelchair-user cars pulled from roads

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http://www.stuff.co.nz/motoring/9567938/Wheelchair-user-cars-pulled-from-roads

and

http://www.stuff.co.nz/dominion-post/news/9567870/Wheelchair-user-cars-pulled-from-roads-over-safety

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Low Volume Vehicle Certification- Your Queries

We have been answering queries about LVV Certification ever since this website was started. The queries and the replies are spread around a number of posts.

So just to make things easier to find- here are some of the pages which might already have the answer you are looking for, or where you can post […]

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Ferrari Ute 1

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CIV 2013-055-093

In the matter of Section 106 of the Transport Act 1998

And

In the matter of an appeal against a decision of the New Zealand Transport Agency to, inter alia, revoke a deed of appointment as a low volume vehicle inspector/inspecting organization

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