Caravan Industry fixing a broken regulatory regime in part with RVMAP

Stuart Lamont — 3 August 2022
Should a manufacturer/importer understand and comply with safety constraints required to build a recreational vehicle product?

I know personally if I was about to invest tens of thousands (and in some cases hundreds of thousands of dollars), the answer to both of those questions would be a resounding YES.

Yet it is a sad reality, with the transitional provisions within the Road Vehicle Standards Act (2018) being delayed until 30 June 2023, that some consumers in the coming year will put their lives and the lives of others at unnecessary risk on the road.

Sound alarmist? – maybe.  While a broken regulatory regime exists by which products can be supplied to market and registered onto the road with no safeguards other than a manufacturer’s say so, it is no wonder that I and the vast majority of manufacturers / importers doing the right thing are concerned.

Caravanning and camping is part of Australia’s psyche. Like myself,  many Australians plan to spend time after retirement crisscrossing this great country of ours in a caravan or motorhome. Add to this the simplicity of the lifestyle and the ability to bond with loved ones - it is no wonder that it is more than just “grey nomads” who are embracing this lifestyle and getting out in record numbers. 

A recreational vehicle can be the sum of many hundreds of component parts, generally assembled by hand, and subject to over 250 Australian Standards covering major items such as gas, plumbing and electrical through to towing connections, component standards and even bunk beds. Add to this over 70 Australian Design Rules (national standards for vehicle safety) which could apply and a recreational vehicle is a very complex construction. Yet the oversight and enforcement of industry by Government and regulators could be much more visible and improved.  As the peak national industry body, in the absence of limited Government interest or intervention, we had to take matters into our own hands. 

The development of RVMAP (Recreational Vehicle Manufacturing Accreditation Program) had its origins back in 2013 and continues to grow.  Since this time, compliance issues relating to construction from manufacturers / importers from within the program identified have reduced by 40%.  Why?  Because specialised resources, product inspections, and educational material are dedicated to assisting those businesses within the RVMAP program understand and meet their compliance obligations.  It’s no surprise that compliance issues identified at consumer shows and in dealerships are three times worse in non-RVMAP products than products from businesses within the program. 

Is the program perfect? – no, but it has been an invaluable exercise in driving behavioural change for the better. Designed to specifically replicate the ADR compliance obligations imposed on manufacturer / importers, the RVMAP team is comprised of specialist engineers, quality assurance experts and qualified ISO auditors.  To get into the program, a business must prove that they understand and have systems in place to consistently build products to such compliance standards. Over the past four years, we have opened up over 3,600 inspection files during a time when the federal department is estimated to have inspected less than 100.  In addition, the RVMAP team specialises only in recreational vehicle products, sits on Government working groups, ADR development forums and Australian Standards committees.  This knowledge is then applied through all stages of design, production and compliance within each RVMAP business.

In most cases, issues identified are isolated and not representative of systematic problems.  In fact, in the past month alone, two RVMAP businesses have received show-cause notices as to why they should continue to remain in the program based on a single individual safety concern observed on a display product yet to be sold.  This show-cause notice requires the business to respond in ten days as to how they aim to fix the issue concerned and procedures to be put in place to ensure that similar products do not replicate the issue identified or risk having their RVMAP licence terminated.

Businesses licenced within RVMAP adhere to a third party review process very similar to star ratings used for accommodation. It is no surprise that 68% of people looking to purchase an RV give high regard to sighting the RVMAP key badge on the product.

Looking towards the RVSA, will this make a difference? – unquestionably, but will it soften the significance of the RVMAP key? – absolutely not!  To receive a type approval under the RVSA, a manufacturer / importer must complete an application containing a declaration of their understanding of the ADR’s applicable to their product, and hold evidence that they meet these obligations, while also having a quality management system in place for the construction of the vehicle.  As an industry association, we look forward to working with the department to make sure that their risk profiles capture those worst offenders within the industry and that enforcement occurs.  In the meantime, the constant review of RVMAP licenced businesses' procedures and consistent education of current and looming regulations will see RVMAP licenced businesses continue to be ahead of the pack when it comes to compliance.

There is simply no better way to travel this vast country than in a caravan – and would I buy a caravan in today’s market? – categorically yes.  That being said, I also know I would be asking two simple questions before purchasing any RV product – is this product type approved under the RVSA (and if not, why not)? and secondly, is this product part of the RVMAP program? If I am planning to travel with my loved ones, I want to make sure that they get home safely, and will do whatever it takes to give myself the best possible opportunity for this to occur.

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