On 8th Dec 2020 I wrote to the Rt Hon Grant Shapps MP (Secretarary of State for Transport), the Department of Transport itself and to the DVSA. The DVSA have kindly responded via email but, eight weeks on, my correspondence to Rt Hon Grant Shapps and the DfT hasn't even been acknowledged, let alone replied to.
I can only assume they don't take the A-Frame towing of cars seriously.
Below is My letter.
08 December 2020
Open letter to
Rt Hon Grant Shapps MP
DVSA
DfT
and other interested parties.
Ref: A-Frame Towing.
Dear Sirs,
I previously wrote (20.10.2020) to both the DfT and the DVSA regarding the issues surrounding A-Frames but to date, have received no response.
As a retired trailer and towbar manufacturer and a past director of the National Trailer and Towing association (NTTA), I have been aware of a major inconsistency regarding the regulation of towed and towing vehicles for over 30 years.
‘A’ frames are most commonly used in the leisure field, predominantly by Motorhomers to tow their ‘city cars’ behind them. Currently, there are in the region of 300,000 Motorhomes/Campers on UK Roads, well over a 1/3rd of which are equipped to tow cars, or ‘Toads’ as some of the users choose to refer to them.
There is an issue that this sector of the vehicle market is almost entirely unregulated and that over 75% of new product is still using outdated and incompatible technology, based purely on cost.
My concerns fall into two main categories, 1. Safety. 2. The legal/legislative aspect and the non regulation,
The current view of the DoT, according to https://www.gov.uk/government/publications/a-frames-and-dollies/a-frames-and-dollies is that a car on an ‘A’ frame (a Toad) is classed temporarily, as a trailer. Only the UK accept that a car adapted for towing is classed as a trailer although the page referred to does state that a car/A-Frame combination must meet the technical requirements for trailers when used on British roads. This is a farcical situation when a trailer has to be capable of being auto-reversed yet no car/A-Frame combination using Inertia coupling technology can be. The systems are simply incompatible.
Additionally, the page refers to the Road Vehicles (C&U) regs 1986, SI1986/1078 (as
amended) and specific regulations therein, the Road Vehicles Lighting Regs 1989, SI1989/1796 (as amended),plus European Directive 71/320EC. Added to the list should be:
European Directive 94/20EC
European Directive 98/12EC
The Vienna Convention on Road Traffic, 8.12.68
and Regulation No 13 of the Economic Commission for Europe of the United Nations (UN/ECE) — Uniform provisions concerning the approval of vehicles of categories M, N and O with regard to braking [2016/194] in particular para 5.2.2.2
The.gov Guidance page clearly states “Since 1st October 1988 Inertia braking systems have been required to allow a trailer to be reversed by the towing vehicle without imposing a sustained braking drag. Devices used to fulfil this requirement must engage and disengage automatically. This applies to A-Frames that employ inertia over-run technology”. That quite simply is impossible to achieve as trailers have a dedicated auto-reverse mechanism built into each brake assembly and no car does. On the subject of brakes, most systems are relying on the vehicle’s service brake system with a ‘dead pedal’ connection where the vehicle’s servo is inoperative resulting in poor efficiency and, in the event of an emergency breakaway, all are relying on the car’s hydraulic braking system to park the car. NONE are utilising a fully mechanical, locked, parking brake.
The page goes on to say that “the A-frame itself is neither a vehicle nor a trailer, and is therefore outside the scope of type approval.”, however, a Tow-Bar is neither a vehicle nor a trailer either but has been subject to type approval since 1st August 1998. What is the logic that dictates that towing equipment fitted to the rear has to be ‘TYPE-APPROVED’ yet towing equipment fitted to the front doesn’t and is outside regulation?
Since 2012, all trailers on U.K. roads are required to be type approved but no car/‘A’ frame combination (Toad) is, nor can it be under the trailer regulations. Not one single vehicle manufacturer has mounting points they consider suitable for A-Frame towing.
The 25th May 2007 saw the outlawing of non type approved Bull Bars on the grounds of safety regarding pedestrians yet Towing A-Frames have as much potential for injury/death to a pedestrian and are unregulated. To attach an A-Frame to a car, a number of suppliers are undertaking a major alteration to the front of the towed vehicle by removing and discarding the crash/impact beam that the car was tested and approved with and replacing it with a heavy fabrication that is permanently fitted. Of the suppliers that don’t discard the crash/impact beam, they are modifying and reinforcing the original to accommodate the necessary additional mounting points and the increased stresses imposed by A-Frame towing.
These potentially have an effect on the crumple zones built into the car and even airbag deployment, with the knock on effect of risk to driver and passengers when the vehicle is used in ‘normal’ mode.
Moreover, a large number of these have projections from the front in the form of mounting points which are potentially hazardous to pedestrians involved in any accident.
Without any guidance or regulation to go by, the converters who are adapting vehicles for this purpose are using their own judgement as to what is acceptable. In many cases, the fabrication being attached to the front of the vehicle is at least as dangerous as a bull bar and certainly more dangerous than a tow-bar.
There is no sense whatsoever that Tow-Bars, Bull Bars etc. fitted to vehicles have to be type approved but ‘A’ frames have no such requirement for ‘e’ markings and more importantly, nor do their attachment brackets, which are permanently fixed to the car.
I would argue that removing the original crash/impact beam and replacing it with a much stronger welded fabrication amounts to the car being a ‘Radically Altered Vehicle’ as it affects the basic chassis construction. As such, it should be subject to a Vehicle Inspection Report and possibly re-registration. This is already successfully undertaken in New Zealand by the lvvta.org.nz
As recent correspondence with vehicle manufactures shows, there is not one single car manufacturer that has approved mounting points for these brackets. Of 15 letters written to leading manufacturers, after more than 4 months, 8 still have not responded.
In date order, the others are summarised here.
1.Vauxhall: I can advise that we do not have any mounting points for an A-Frame on any of our vehicle range.
2. Fiat (FCA): Any faults or issues relating to the fitment of an A-Frame would possibly render our manufacturers warranty void.
3. Honda: unable to advise, refer to dealer.
4. Hyundai: None of our vehicles are suitable to be towed on an A-Frame.
5. Toyota: we cannot recommend the use of an A-Frame with any of our vehicles.
6. Skoda: we are unable to advise.
7. Ford: refer to dealer.
A poll currently running among users of A-Frames suggests that the most popular cars to convert are Mercedes-Smart, Peugeot and Citroen yet to date, none of these have commented.
Under current legislation, the ONLY truly legal way to transport a vehicle is on a trailer, however, a properly constructed, tested and approved A-Frame has the potential to provide a safer, more stable way of vehicle transportation, bearing in mind it is quite a bit lighter than a trailer/car combination and also has a lower centre of gravity. For the end user it has the added advantage of being easier to store and arguably requires less skill/training. Far from trying to have A-Frames banned, what I hope to see, eventually, is a fully legal one that can be used with confidence.
, If ‘Toads’ were reclassified as such rather than, temporarily, as a trailer, the A-Frame manufacturers would be able to comply with RELEVANT legislation, rather than trying to conform to something unfit for purpose. Equally, there would no need for any to attempt to pull the wool over the eyes of the consumer, selectively quoting bits of legislation they think suits their purpose and confusing the end user into believing their product is ‘FULLY LEGAL’ as they all claim!
I look forward to your response.
Yours sincerely
A E Maris
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