This is the full text of the letter referred to in the article "4-2-2 testing proposal still causing uncertainty" published in MOT Workshop 35, August - October 2011.
(Full text of article reprinted below letter and reply)
Original letter to Rt Hon Phillip Hammond MP, Conservative MP for Runnymede and Weybridge.
Dear Mr Hammond,
Your recent release to the media to the effect that you are considering changing the MOT periodicity flies in the face of logic and, more importantly, the evidence from the industry – and VOSA’s own MOT Computer statistics – that servicing is is being curtailed by vehicle owners, probably on the basis of cost, as they have no choice but to pay the swingeing fuel price increases. Put simply, more cars owners than ever are skimping on servicing.
The argument that modern cars are more reliable fails – tyres, brake pads and discs wear out just a quickly as ever – probably more frequently as cars become more powerful, and road surface friction material improves. Add increased speed limits on motorways and ever more crowded roads generally into the mix and car service intervals – even if observed, which they increasingly are not – become irrelevant.
Speed bumps and poorly maintained roads (and possibly inferior steel) are resulting in (currently reported) massive increases in MOT failure owing to road spring fracture. This alone should be ringing very loud alarm bells.
The headlamp check, recently announced by VOSA as responsible for 23% of MOT failures alone, is more vital than ever because of the new high performance gas discharge lamps which can severely dazzle other drivers if not adjusted correctly.
Your advisors must have made you aware that the MOT Test merely tests that a safety-related component – Brakes, Tyres, Steering, Suspension, Body shell, Windscreen – has not fallen below a specified limit. This limit is only just above the level at which it will fail (in some cases, such as tyres, it has been shown that performance has already been significantly degraded by the time the MOT limit is reached).
An MOT Tester may not issue a failure notice even if the item he is inspecting is very close to the limit – he must pass it. He may issue an advisory note, but the car owner may ignore it.
You are proposing that a vehicle which has only just passed its MOT Test, and which may have advisory notices relating to its brakes, tyres, lights and steering, may be driven at high speed on any road in the country and need not be inspected for another two years! The study by TRL (‘desk-based’, not primary!) has clearly been designed to provide justification for a policy already decided.
This is clearly wrong, and I urge you to look again at the figures with which you have been presented, and for good measure, at the figures from the previous, carefully researched study (MOT Scheme Evidence Base Nov 2008). The road death figures which are being quoted in the media are very different from those in the earlier, more detailed report – there must be a reason for that.
What you may not be aware of is that the current 40% MOT failure on first presentation figures, as bad as they are, showing year on year increases, do NOT include an estimated 200,000 ‘D-Box’ (Danger Box) failures. These are vehicles which the Tester has judged would be dangerous to drive on the road and would have merited a ‘D Box’ entry but for the fact that the vehicle’s defect was repaired before the Test was completed, so a Pass was recorded.
I would have thought that as the Secretary of State for Transport you would take the safety of road users into account before changing what has proved to be an unmitigated success – Britain’s roads are currently the safest in the world, and the MOT has a very positive image with the vast majority of car drivers – whilst it is somewhat of a ‘distress purchase’ road users recognise that without it there would be a large number of very dangerous vehicles on the road.
They regard saving £25 per year on the MOT as piffling compared to the cost of fuel, and when they see the results of dangerous cars being let onto the roads for up to two years without inspection, and the insurance premiums rocketing up, they will be looking for the reasons.
BP learnt an expensive lesson about what happens when safety systems are bypassed to save costs – they could have learned from Piper Alpha, but they had to burn their own fingers. Are we about to see another disaster brought about by the DfT dismantling well-proven safety systems?
Please reconsider the option of changing the MOT Test periodicity – it is really not a sensible option.
Yours sincerely
Martin Shippey
Editor, MOT Workshop
Response, 1st July 2011, from Dr Bob Moran,
Senior Engineer, Roadworthiness
Dear Martin Shippey,
MOT Periodicity
Thank you for your email of 28 April addressed to Philip Hammond about potential changes to the MOT scheme. I have been asked to reply.
We do intend to consult on possible changes to the MOT test scheme but have no preconceptions about the outcome of a review; the aim will be to strike the right balance between vehicle safety and the burden imposed on motorists by MOT test requirements.
This will be a genuine consultation and we want to work with the industry and motorists to get the decision absolutely right. There will be a further opportunity for anyone with an interest to participate in the debate and I’d like to thank you for your contribution. The information provided will be considered by the Review.
We expect to make an announcement soon about the timing and scope of the review.
Yours sincerely,
Bob Moran
Full text of article published in MOT Workshop August 2011
4-2-2 Testing proposal still causing uncertainty
Decreased road safety is not the only by-product of Philip Hammond’s misguided proposal – the whole MOT industry has been left in limbo!
By Martin Shippey
What is going wrong?
Figures from VOSA indicate alarmingly high levels of MOT failure following initial MOT Tests. The numbers appear to be rising; the figures for private cars in the year 2009-2010, the latest available, are just over 40%, from 38.5% in 2007-2008. And every day, within this 40% of vehicles which have failed their Test, over 2,200 have at least one defect which MOT Testers judge renders the vehicle dangerous to drive.
Fuel prices are clearly causing significant pressure on household budgets, and it has been suggested that to save money, car owners are retaining their cars for longer, then making further savings by cutting back on servicing. Whatever the cause, enough money is clearly not being spent on car servicing and repair.
The wrong solution, at the wrong time
Those in the servicing industry are surely feeling the squeeze. Drivers do not usually have much of a choice about how far they must drive to the shops, schools, work, but the cost of driving to those places has risen both astronomically and quickly. So inevitably the money which might have been spent on servicing tyres, suspension, steering and lights, is now going into the coffers of the oil companies and HM Revenue and Customs.
The result? More dangerously under-serviced cars on the roads, coupled with service garages unwilling to spend money on equipment and training because of reduced revenues and the very uncertain business climate caused by the 4-2-2 dithering.
The MOT industry does not need this senseless dickering with a perfectly adequate and fit- for-purpose MOT!
We can understand how a government might wish to appear to be taking the interests of the motorist to heart, and generously conceding that perhaps the MOT Test is a little onerous; “We shall ease the burden a little – there! save £25 over a year! See how we feel your pain! That will be £25 extra every time you fill your tank by the way; thank you very much!”
Secretary of State for Transport, please note; if you want to give the electorate the impression that you’re saving them money, try to find a way of doing it which doesn’t throw an industry which has helped to give Great Britain the safest roads in the world into economic uncertainty.
Letter to the Minister
As editor of MOT Workshop Magazine, read by many thousands of MOT professionals, I decided that it wasn’t enough just to exhort readers to write to their MP – I should do something myself. So I wrote to Philip Hammond protesting that the 4-2-2 proposal just didn’t make sense, and not only that, if it was implemented, he would be responsible for the many deaths and injuries which would inevitably result.
I received a reply from Dr. Bob Moran, Senior Engineer, Roadworthiness, Department for Transport, who replied on Mr Hammond’s behalf, informing me that “We do intend to consult on the possible changes to the MOT test scheme…” [my italics] “… the aim will be to strike the right balance between vehicle safety and the burden imposed on motorists by MOT test requirements”.
The reply continues along the lines that there will be a “genuine consultation” and an “opportunity for anyone with an interest to participate in the debate…”
MOT professionals, you have been unequivocally informed, they want to work with the industry to get things right and your view will be taken into account!
In order for that to happen you must WRITE TO YOUR MP! (especially those in Runnymede and Weybridge!)
Find out who your MP is and give him your views on 4-2-2 Testing; complain that it will ruin your livelihood and cause the roads to be unsafe. Give genuine examples of vehicle defects discovered during the MOT.