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Why a 4-2-2 MOT regime is not in the interests of the UK public
Dec. 2006MOT TRADE FORUM
The Better Regulation Commission argues for 4.2.2 because “MODERN CARS ARE SAFER AND MORE RELIABLE”
THE MOTOR TRADE AGREES SAFETY AND RELIABILITY ARE MUCH IMPROVED - IF IRRELEVANT TO THE MOTTHE MOT IS NOT ABOUT DESIGN & RELIABILITY- IT’S THE DETECTION OF ROADWORTHINESS OF PRIMARY SAFETY COMPONENTS
SWEDISH RESEARCH INTO 3 MILLION VEHICLES SHOWS NO IMPROVEMENT IN FAILURE RATES OF NEW MODELS OVER 8 YEAR PERIOD (1)
What 4-2-2 will deliver
Over 100 extra road deaths per year
Increased damage to the environment & public health
Increased net cost to ‘UK PLC’ of up to £450 million
Put 15,000+ MOT Testers out of work, plus more redundancies in other motor industry retail
A saving to motorists of £25 per year on an MOT - but a probable increase in insurance premiumsBackground
Approx. 26 million testable cars/lcv’s
Current annual fail rate is over 30% = 7.8+ million defective vehicles detected & rectified by MOT stations
Fail rate on 3yr old cars is 18% mainly tyres/lights/brakes - prime accident causative items - probably an underestimate given 3 year manufacturer service programmes
nearly 8 million vehicles are over 9 years old and probably poorly maintained.
8 out of 14 EU countries (57%) test annually
Top 3 EU countries with lowest road deaths per 100k population ((1)UK/(2)Sweden/(3)Holland) all test annually
Highest fatalities are in 4.2.2 regime countries
The MOT is not gold plated EU legislation
The UK MOT inspection was the first of its kind and introduced in September 1960
It was introduced as an annual test for 10yr and over vehicles
Because of its success, it was mandated to all 3 year old cars/light commercials in 1968, well before the UK joined the EU.
A DfT review in 1994 concluded there was no justification for changing the current regime
Some major EU countries only introduced the test in the 1990s
Risk to UK Road safety
UK target is 40% reduction in KSI (Killed/Seriously injured) by 2010
EU propose 50% reduction in road deaths by 2010
2004 (UK) casualties
Fatal 3,221, Serious 31,130, Slight 246 489
Total 280,840 (2)
Approx.2-3% of all accidents are caused by vehicle defects - resulting in 100 deaths per annum (3)
CITA have empirical data to support vehicle condition playing a higher part in road accidents than official statistics (4)
CITA data indicates that without vehicle inspection 150% increase in accidents due to vehicle condition can be anticipated
Therefore 2 year testing risks up to another 150 road deaths, 1400 serious injuries, 11,000 slight injuries per year.
Deregulation to 2 year testing will result in poorer car maintenance.With extended service intervals and no mandated visit to a garage for 24 months, mechanical defects must increase
Many cars will only get serviced as part of obtaining the MOT. 2 year testing will remove that discipline and substantially increase risk
A move to 2 years will mean over 50% of vehicles will not meet regulation - i.e.. be unsafeCost to UK PLC of 4-2-2 road casualties
Cost per accident
Fatal: £1.573 million
Serious: £0.184 million
Slight: £18500
Average: £62200 (5)
Potential annual incremental cost of 4-2-2 is £790 million in road casualty costs (based on previous casualty data).
This should be offset against the annual saving of £520 million by biennial tests
Net cost on road accidents alone to UK PLC of 4-2-2 would be £270 million.
Increased environmental damage
Despite improved design, biennial testing will inevitably increase polluting vehicles being undetected, thus raising greenhouse gas and illness-inducing diesel particulates
Approximately 15% (1.18million) of all failed cars will include failed emissions
A move to 4-2-2 will increase the number to approx. 2.4 million which is 7% of all cars/lcv’s
Analysis of 20,482 failed tests (2003) indicates:
Emissions petrol: 4.58%
Emissions CAT : 5.70%
Emissions Diesel: 4.67% (6)
17% of all diesel cars tested in this analysis failed on emissions. Current diesel car park is approx. 5 million vehicles (20%) , but will dramatically increase given in 2005 diesels were 36% of new car registrations.
4-2-2 will dramatically effect the risk of a poorer air quality with potentially around 2 million diesel vehicles not reaching emissions standards. Result is increased risk of cancer/heart/respiratory disease.
4-2-2 will seriously effect 12,000 small businesses
Of 18,300 testing stations, approx. 12,000 are independent garages who unlike dealerships rely heavily on MOT income. There are 50,000 testers whose jobs (50%?) would be under threat
Average t/o for a typical independent garage is approx. £175k with 3 technicians. They would average 1,421 tests a year generating £70,000 income. Halving this income will cost £35,000.This excludes lost MOT failure repair work - an additional £15,000.
3 technicians supporting a reduced turnover of £125k is non viable - 2 maybe viable, but given fixed overheads some will inevitably close.
4-2-2 will risk redundancies of at least 15000 trained technicians with a cost to UK PLC of £180 million+ in unemployment costs. Could be higher as excludes national fast-fit chains (Nationwide/Kwik Fit etc)
Above assumes gradual transition to 4-2-2. Sudden implementation will be even more costly.
4-2-2 Introduction
An overnight introduction will cause the system to become totally inefficient and costly
Year 1 - no tests
Year 2 - 30 million tests (inc. retests)
Year 3 - 3 million tests (4 yr. cars/vans)
Year 4 - 30 million tests
The assumption must be that Year 1, the trade will make thousands of testers redundant.This will result in massive under supply of test availability in years 2 and 4.
This will add cost and inconvenience to the motorist
The other hidden costs
If a significant proportion of smaller testing stations close or stop testing:
Public will travel further to get an MOT with the incremental costs of time/fuel/pollution etc., particularly in rural areas
A forced increase in the use of dealerships for many owners of older cars (limited incomes) will increase their costs.
2006 survey on average national labour rates, independents charged £49.61 per hour and franchises £91.07. (7)
Independents are preferred 2:1to dealerships
Current level of apprenticeships will inevitably decline
Garage equipment manufacturers will be hit badly as investment is cut back - just when VOSA is planning major upgrades
Motor factor turnover will significantly reduce
Discussions with Insurers suggest increased premiums on 3+ years cars will rise.
Risk/Reward of 4-2-2 is negative
The social and economic upheaval of a short term benefit of an annual £25 public saving is dramatically outweighed by the following negatives:
More road deaths & serious injury
More cost of at least of £390million to public and private purse
More unemployment
More inconvenience and hidden costs to motorists
Further deterioration in car maintenance standards
With a now positive UK public mindset, that annual testing is a good thing (Confirmed by VOSA MORI poll), moving to 24 months implies it was not so important after all.
4-2-2 is deregulation for deregulation’s sake with no public benefit - the current 3.1.1.regime is ‘good regulation’
References
(1) Peter Baas - Autofore (Principles of road worthiness enforcement)
(2) Department for Transport
(3) Davidson Review (Nov 06)
(4) CITA - world-wide testing association of which VOSA (UK government agency) is a member
(5) Department for Transport
(6) MOTEST survey
(7) Warranty Direct 2006 surveyMore in MOT Testing magazine every quarter
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