Two governmental bodies have dispelled operators’ fears by confirming that the Jimmy Beam Down Light (JBDL) system can be fitted to new-build trailers under current legislation and does not require type approval.
Since 29 October 2012, trailer manufacturers have been required to produce trailers that adhere to whole vehicle type approval (ECWVTA). As a result, several operators queried whether JBDL, a 1W light system that shines downwards, needed type approval to be fitted during production.
ECE Regulation 48 (5.22) says “with the exception of retro-reflectors, a lamp even bearing an approval mark is deemed not to be present when it cannot be made to operate by the sole installation of a light source and/or a fuse”.
Now the Vehicle Certification Agency (VCA), which oversees ECWVTA and the Certificate of Conformity (CoC) issued by the manufacturer once a trailer is completed, and the DVSA, which polices road-going CVs, have both confirmed that the JBDL doesn’t need type approval under existing regulations.
However, during the Conformity of Production process, manufacturers must include details of non-functional lights and indicate that they do not affect other areas of type approval.
Nick Sanderson, VCA principal engineer product certification, said: “If non-functioning lights, under the meaning of the [aforementioned] regulation, are fitted to a vehicle, then this would not directly affect the vehicle’s status under type approval. If any passive interference with other requirements can also be discounted then there would be no effect on the ECWVTA.”
DVSA heavy vehicle technical officer Kevin Gist said subsequent communications involving the DfT and the VCA suggested that the fitment of supporting brackets and unconnected lighting units could be acceptable, depending upon infringement of any other area of approval.
Jim Thomson, who created the JBDL, said the lights are not type-approved but have been certificated to Regulation 10 and are marked with an E number on the lens.
“This means that operators can have the down lights fitted to new-builds in preparation for in-service use. To adhere to legislation, the fuse must
be removed by the trailer manufacturer to prevent the down lights from working. Once the trailer has been received by the operator, the fuse can be inserted ready for on-the-road use,” he said.
JBDL was a finalist in this year’s Motor Transport Awards in the Innovation category, sponsored by Haulage Exchange.