Guidance

PSV notifiable alterations: standards of compliance for re-approval

Published 10 July 2013

Background

The Driver and Vehicle Standards Agency (DVSA) acts on behalf of the Secretary of State to receive and evaluate notifications from operators of changes they have made to the specification of a Public Service Vehicle. The operator would notify DVSA by use of form VTP5 Notification of an Alteration to a Public Service Vehicle.

Traditionally vehicle body build requirements are contained in the Public Service Vehicles (Conditions of Fitness, Equipment, Use and Certification) Regulations 1981 (COIF) for vehicles with more than 16 seated passengers, and Schedule 6 of the Road Vehicles (Construction and Use) Regulations 1986 for vehicles up to 16 seated passengers. Other (non body) components of the vehicle not controlled by the forgoing two regulations (tyres for instance), would be covered by other GB regulations, such as, the Road Vehicles (Construction & Use) Regulations 1986.

It has for some time been possible to construct PSV bodies to the requirements of ECE Regulations 107.02, 36 or 52 or EC Directive 2001/85 (commonly termed Bus Directive), in place of the above mentioned GB requirements, such vehicles being initially accepted into service through either a COIF examination or an approval scheme (for example European Community Whole Vehicle Type Approval (ECWVTA)). Vehicles approved to one of these methods are now of an age where alterations are being carried out and notified to DVSA for acceptance.

Body specification regulations such as COIF, ECE Regulation 107.02 and EC Directive 2001/85, rely on the interaction of various requirements in the regulations, to ensure safety within the whole vehicle (for example, the size of the emergency door has a correlation with the access required, and the overall number of exits required). As the 3 alternatives have differing requirements to meet the safety aim, then any mixing of the individual requirements, of say COIF and ECE Regulation 107.02, may remove the overall safety effect contained in either of the two individual regulations, and result in an unsafe feature within the vehicle. The aim of this policy is to ensure this doesn’t happen.

Standards applied

To ensure the continued safety of vehicles subject to an alteration, the following policy will apply:

Items other than body related items, not contained within the body related regulations, will need to comply with and will be assessed against the appropriate GB legislation, for example:

  • The Road Vehicles Lighting Regulations 1989
  • The Road Vehicles (Construction and Use) Regulations 1986
  • The Public Service Vehicles (Carrying Capacity) Regulations 1984
  • The Road Vehicles (Authorised Weight) Regulations 1998

Body related items, for example seating / standing capacity, exits etc, that are contained in the requirements appertaining to the “body” will need to comply with the following requirements:

  • vehicles originally certified to the Public Service Vehicles (Conditions of Fitness, Equipment, Use and Certification) Regulations 1981 or for vehicles with not more than 16 seated passengers, Schedule 6 of The Road Vehicles (Construction and Use) Regulations 1986 will need to comply with the current version of the same regulations
  • vehicles with the body initially certified to ECE Regulation 107.02, 36 or 52 or EC Directive 2001/85, will need to comply with the same criteria as used in the original certification, however:

Note

The criteria in Section 52 of the IVA Manual (taken from the approval regulations) are based on Regulation 107.02 (or the similar Directive 2001/85) with derogations from certain requirements allowing basic safety standards to be maintained. (This will, to a degree, allow such modifications as 3 + 2 seating.)

Alterations involving accessibility requirements

Where a vehicle has been issued with an Accessibility Certificate and for its continued use after the alteration, the vehicle is required to retain the Accessibility Certificate, the same principle as applied above will apply, relating back to the regulation used to grant the previous certificate. This could be:

  • The Public Service Vehicles Accessibility Regulations 2000
  • Annex VII of Directive 2001/85
  • Annex VIII of ECE Regulation 107.02

Vehicles originally approved to either Annex VII of Directive 2001/85EC or Annex VIII of ECE Regulation 107.02, can opt for the requirements of Schedule 2 of the Road Vehicles (Approval) Regulations 2020 and as published in section 52Z of the (IVA) M2/M3 inspection manual.

Access to alternative IVA criteria

Download DVSA’s IVA inspection manual for buses and coaches – M2 / M3 vehicles.