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Submission for the National Heavy Vehicle Braking Strategy Phase 1

31 May 2013

This submission details the views of the members of the Australian Trucking Association’s (ATA) Industry Technical Council (ITC) on the proposed changes to the Australian Design Rules (ADR) for Heavy Vehicle Braking Systems released for industry comment.

The ATA is supportive of the general thrust of these changes as they take steps to improve safety that are both sensible and affordable. We have also provided guidance on specific load sensing ‘settings’ that should be adopted; suggested exemption clauses; and offered detailed comments and recommendations that the ATA believes improves the proposal and strengthens the grounding for taking the next step in the longer term braking strategy. We also provide an updated working draft of the joint industry administrator guide or code that is aimed at supporting these ADR changes (Attachment 1). The ATA is committed to working with governments to improve safety with workable, acceptable and viable solutions.

Anti-lock Brake Systems (ABS), Load Sensing brake systems (LS) and electronic brake systems (EBS) are all currently deployed throughout the trucking industry and the industry is managing resulting complexities. ABS and EBS are often referred to as ‘smart’ braking systems. Traditional air-operated brake systems in heavy trucks and trailer have accordingly been termed “dumb” braking systems, which is poor testament to
the very satisfactory service achieved by a standard, well set-up air brake system. Smart systems are being used in all driving environments in Australia with the exception of trailers with more than four axles, which should remain exempt because the technology is not currently available to provide ‘smart’ brakes in these unusual applications.