FMVSS 105 Compliance for After Market Suppliers

Hi Trevor, this is what I understand about the new guidelines released at the end of last year. The concern that I have is he Fade test, pushing the car that I have put my heart and sole into for almost 4 years to the push it to the point of brake fade just seems incredibly stupid and dangerous. I'm sure when GM or Ford test their vehicles prior to release, they are using specially designed tracks and professional drivers Are their any options to confirm the Aftermarket supplier has completed the relivent testing?

Trevor, you mentioned a hotrod group that has a 'pre approved' list, do you know if this list is published or which hot rod group?

With the ADR 38, you say you used a formula/equipment approach does this mean that there was no physical testing? It also states that "Compliance can be demonstrated by road testing and/or calculations based on data for 'Approved' components." Who approves the components?

This is a personal car? Wilwood brakes, installed in your own vehicle, would most certainly be an upgrade in safety and performance over stock.

Much like replacing wheels with alloys, upgrading tires, turbochaging, etc etc etc. In the US, there would be no requirement in any state I know of, to re certify the brakes, or for that matter, to even tell anyone you did it. Are you going into this venture with a resale in mind, for multiple vehicles, as a commercial venture? Seems like it could be a selling point, and if advertised, may require you to convince some NSW agency that it is an improvement mod. In that case, Wilwood may help you.

Was signatory to NATA test lab for ADR testing of automotive lighting in previous job. Was also company representative for "compliance" transfers from everseas products into the Australian market.

The international agreement is that ADR would accept directly the compliance plate cetrification of overseas vehicles (with relevant adjustments for LHD/RHD alterations like headlight alignments.)

For aftermarket items, the registration process involved lodging releveant documentation including a copy of the registered international test laboratory compliance certificate for the component or the "E" marking evidence.

Whoever is the importer of the brake kit that you have installed should be the one to register the component for "on road" use. (Register with the Federal Office of Road Safety FORS).

THEN your local engineer can determine the you have correctly selected and installed the brakes in accordance with their intended use AND the vehicle details.

So, you should contact the component importer and ask them for the registration reference with FORS, so you can then take that along with your modified vehicle to an appropriately qualified engineer for evaluation.

(As an asside, I have seen so many vehicles modified, especially raised, that would not comply to the ADR's, but because they have a structural engineers certification have been approved. They might be structurally sound, but contravene multiple regulations making it unsafe for other road users. The vehicle manufacturing companies crash test multiple vehicles and consume literally tons of parts to achieve a roadworthy and safe product. ANYONE who modifies a vehicle should expect to be held to the same high standards.

A "better" brake set might not be safer!!!

What is the international compliance certificate? For aftermarket components, what ADR's or FMVSS would they need to comply to? I purchased the parts and had them mailed to Australia so I would be the importer. I do agree with your comments in relation to modified 4x4's however, my braking system has on paper and 'road test' has improved the vehicle immensely. Now with the new 'guidelines' I have to physically prove this by taking my vehicle through potential destructive testing where a qualified and competent engineer would have been able to use their years of training and expertise to validate.

Had a quick look yesterday, and while my experience is in lighting only, there was a section in the SA code that covered individual (unique) constructed vehicles that described a brake fade test that required 13 hard braking cycles followed by two brake effectiveness tests that provided the evidence.

Test was something like 60kph to zero each time with less than ??seconds between repetitions.

Each state would have a similar option available.

Federal Office of Road Safety (FORS) may already have the item you imported on their lists. Have you ever seen the items available retail in Aus? If so, then ask that supplier, or get a picture of the compliance details from them. FORS will probably not accept submission from an individual for a product.