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#1 2018-04-24 06:16:38

CrlyWrly
Member
From: Tyne & Wear
Registered: 2018-04-15
Posts: 10
Website

DVLA Clarifies Motor Home minimum cooking facilities: one ring not two

For reasons mentioned in my post Camper Conversions» Scudo Combi Camper + Insurance Nasties I got thinking again about the "minimum requirements" for a vehicle to be identified as a Motorhome aka "Motor Caravan".


Cooking Facilities: DVLA Guidance and DfT Interpretation of Legislation (EU)

The Guidance by the DVLA is that if there must be a minimum of a microwave or a 2-ring "cooking facility":

DfT Guidance: Converting a vehicle into a motorhome (Updated 22 April 2016)

This is based on Dept. of Transport interpretation of the "relevant legislation", which is the much less specific EU Legislation.


EU Legislation

The relevant legislation does not mention anything about microwaves or a minimum number of cooking "rings" (it is also less specific about other requirements):

EU Directive 2007/46/EC, a framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles

5. Special purpose vehicles

5.1.
Name Motor caravan
Code SA
Definition

A vehicle of category M with living accommodation space which contains the following equipment as a minimum:

(a) seats and table;
(b) sleeping accommodation which may be converted from the seats;
(c) cooking facilities;
(d) storage facilities.

This equipment shall be rigidly fixed to the living compartment.
However, the table may be designed to be easily removable.


FOI Request to DfT/DVLA

To cut a long story short, on 17 April I submitted an FOI to the DfT via the web site "What Do They Know":

FOI Request: Motor Caravans - Minimum Requirement of a 2 ring cooking facility or microwave

The DfT passed it on to the DVLA, who replied on 23 April saying that a one-ring cooking facility is sufficient:

FOI Reply from DVLA Re: Motor caravans – Minimum Requirement of cooking facilities

"The guidance you refer to is not prescribed in law but has been established, by the
Department for Transport, to assist motorists when they carry out “do it yourself”
conversions of their motor vehicles into “camper vans”/ “motor homes”. 

The importance of the guidance, particularly in relation to incorporating fitments to a
vehicle, is for safety not to be compromised but, there would be no concern if the
cooker comprised of either one or two rings and it has been fitted correctly."


FOI Correspondence:

For the full correspondence see FOI Request: Motor Caravans - Minimum Requirement of a 2 ring cooking facility or microwave

The text of my FOI Request and a copy of the DVLA Reply are also in this PDF File:
2018-04-15-FOI-Request-to-DfT-re-Motor-Caravan-Cooking-Facilities--Reply-from-DfT.pdf


Sharing the good news!

I think this will be helpful to members using the "2007 to present" forums too. I will post in their "Camper Conversions" forum with a link to this Topic, so that if there is any discussion it will (maybe!) be all in one place :-)

Please do pass this on to anyone who would be interested. I posted it on Facebook and a freind immediately contacted me, spitting feathers because she and her husband had just fitted a two-ring gas hob into their van conversion. Not because they wanted a two-ring "cooking facility" but because they thought it was law that they had to.


Best wishes,

Liz


Fiat Scudo 2006 Campervan
mini_2017-03-24-Scudo-collage-1000x1000.jpeg

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#2 2018-04-24 09:49:26

Casper
Member
From: East Lothian
Registered: 2015-12-20
Posts: 2,114

Re: DVLA Clarifies Motor Home minimum cooking facilities: one ring not two

I never bothered when i had my pug changing it to camper. Main reason was it would only get used at campsites and we tend to eat out anyway. Took a cooker with us but did not bother with water storage or table. I have since changed my present van into camper and went by this DVLA Doc https://assets.publishing.service.gov.u … orhome.pdf

There is no mention of twin or more burner and you can try and bend the rules but i would give them the minimum you ask and when got the camper stamp change things. I have no need for the table so doing a refit now and still thinking i may take it away to use the space for something else. They also say fixed gas pipe in that doc. I never did that, hanging gas hose dropped through hole in worktop.

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#3 2018-04-24 14:41:53

CrlyWrly
Member
From: Tyne & Wear
Registered: 2018-04-15
Posts: 10
Website

Re: DVLA Clarifies Motor Home minimum cooking facilities: one ring not two

Hi Casper,

That document looks very similar to the one that I referenced:

https://www.gov.uk/government/publicati … -motorhome

I think it might be identical - and there is a reference to a "twin burner" in the one you linked to :-)

Cooking facilities
• That are an integral part of the vehicle living accommodation and is mounted independently of other items.
• That are secured to the vehicle floor and /or side wall.
• Secured as a permanent feature, (bolted, riveted, screwed, or welded.
The cooking facility must consist of a minimum of a two ring cooking facility or a microwave in
either case having a fuel/power source.

• If the cooking facility is fuelled by gas having a remote fuel supply, the fuel supply pipe must be
permanently secured to the vehicle structure.
• If the cooking facility is fuelled by gas having a remote fuel supply, the fuel reservoir must be
secured in a storage cupboard or the reservoir secured to the vehicle structure.

I didn't spot this bit before though, specifying "powered by gas or electricity" . . . what about spirit stoves? Or maybe they count as "gas"? :-)

a permanently fixed cooking facility within the vehicle, powered by gas or electricity

I feel another FOI Request coming on :-)

I did a fair bit of reading around different forums last week and it struck me that people do vary very greatly in how rigorously, or not, they strive to meet all the Guidance.

Something else that struck me is where "Directive 2007/46/EC (Framework Directive)" falls within EU law:

"European Commission > Growth > Sectors > Automotive industry > Legislation > Directives and regulations on motor vehicles, their trailers, systems and components > Directive 2007/46/EC (Framework Directive)"

https://ec.europa.eu/growth/sectors/aut … 7-46-ec_en

I presume that within the automotive and "professional conversion" industries that companies in different EU countries might well have different Government "Guidance" to follow, since the DfT and DVLA documents consist primarily of "interpretation" of the much simpler, less specific wording in the EU Directive.

I think this must be so! I have come across discussions in forums where people whose vehicles have been "passed" by the DVLA have been fined when they travelled elsewhere in the EU, because of differing interpretations. (I didn't pay enough attention at the time to be able to recall the specifics.)

On the "number of ring burners" issue, I find it re-assuring to have it in writing that the DVLA is happy to accept a one-ring burner, in contradiction of the official Guidance. There is no telling how flexibly or strictly an individual application might be considered, so it is very useful evidence for anyone who has fitted a single-ring burner and applies to the DVLA :-)

Best wishes,

Liz


Fiat Scudo 2006 Campervan
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#4 2018-04-24 15:39:54

Casper
Member
From: East Lothian
Registered: 2015-12-20
Posts: 2,114

Re: DVLA Clarifies Motor Home minimum cooking facilities: one ring not two

Lol i was just looking at a few documents myself from various site. They all say just gas no mention of two rings until the talk about the DFT Definitions.  Now a lot of sites are saying "The following is taken from the DFT website now in the National Archives." Im wondering what this National Archives actually is, could it be possible this is an old document what should have been updated a while back. I have seen many a small van changed to camper through DVLA with single ring burners. I have also seen people get a pass without a fixed table

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#5 2018-04-24 22:05:46

CrlyWrly
Member
From: Tyne & Wear
Registered: 2018-04-15
Posts: 10
Website

Re: DVLA Clarifies Motor Home minimum cooking facilities: one ring not two

Hi Casper,

I have to admit that it just nosiness that has had me delving further into the National Archives than I ever imagined this would take me! I have been left with a puzzle at the end of it all but I am quite content to leave it at that. Maybe someone else will happen along this way with answers to the questions left trailing at the end of all this?

Anyway, I think I might have found the answer to the mystery of the "Archived DfT Interpretation" - I should have stopped just there :-)


Archived Guidance: June 2010

I don't know if you can remember back to Spring 2010? There was a General Election on 6 May and a change of Government as a result. I was working in the NHS and the Dept of Health provided loads of educational resources for staff. Most of it was swept away within days, or the pages were headed by big banners saying that the information should not be relied on as it was pending review by the new government. The same thing happened right across all Government Dept websites. The Government then amalgamated all the separate sites under the new "GOV dot UK" domain and new content started edging in. In this case however, it seems that the old DfT pages were never reviewed.

Some of parts of the old Government sites and materials were archived by the National Archive at Kew. I think there is a big clue here as to why the DfT Guidance has remained the same for so long and that the DVLA and other bodies rely on archived material even when updating their own publications:

How to import your vehicle permanently into Great Britain

This document, which includes the detailed definitions we are familiar with, seems to be the most recent instance of a publication where there is no reference back to earlier, archived material. 

"Motor caravan" means a special purposes passenger car constructed to include living accommodation which contains at least the following equipment:

- seats and table,

- sleeping accommodation which may be converted from the seats,

- cooking facilities, and

- storage facilities.

This equipment shall be rigidly fixed to the living compartment; however, the table may be designed to be easily removable.

The interpretation applied to this definition is as follows

Seats and a Table

- Are required to be an integral part of the living accommodation area, and mounted independently of other items.

- The table must be capable of being mounted directly to the vehicle floor and /or side wall.

- The table mounting arrangement must be secured as a permanent feature, (bolted, riveted, screwed or welded), although the table may be detachable.

- Permanently secured seating must be available for use at the table.

- The seats must be secured directly to the vehicle floor and/or side wall.

- The seats must be secured as a permanent feature, (bolted riveted, screwed or welded).

Sleeping Accommodation

- Must be an integral part of the living accommodation area.

- Either beds or a bed converted from seats (to form a mattress base)

- Secured as a permanent feature, with base structures bolted, riveted, screwed or welded to the vehicle floor and / or side wall, (unless the sleeping accommodation is provided as a provision over the driver’s cab compartment.

Cooking Facilities

- That are an integral part of the vehicle living accommodation and is mounted independently of other items.

- That are secured to the vehicle floor and / or side wall.

- Secured as a permanent feature, (bolted, riveted, screwed, or welded.

- The cooking facility must consist of a minimum of a two ring cooking facility or a microwave in either case having a fuel/power source.

- If the cooking facility is fuelled by gas having a remote fuel supply, the fuel supply pipe must be permanently secured to the vehicle structure.

- If the cooking facility is fuelled by gas having a remote fuel supply, the fuel reservoir must be secured in a storage cupboard or the reservoir secured to the vehicle structure.

Storage Facilities

- Storage facilities must be provided by a cupboard or locker.

- The facility must be an integral part of the vehicle living accommodation, ie mounted independently of other items, unless incorporated below seat/sleeping accommodation or the  cooking facility.

- The storage facility must be a permanent feature, (bolted, riveted, screwed or welded).

- The storage facility must be secured directly to the vehicle floor and / or side wall, unless a storage provision is provided over the driver’s cab compartment.

Look at the date that it was archived:
6 June 2010 (one month after the change of Government, when all the old Government web sites were being purged by the new Government)

Look at the "advisory" inserted above the content:
"Content on this site is under review following the formation of a new government."

2018-04-24-National-Archive-DfT-vehicle-definitions---highlighted.png

No Government since 6 May 2010 has got around to reviewing the definitions, so the archived version is all that the Civil Service has as a point of reference. If the definitions had been reviewed then there would be an updated version somewhere on the "GOV dot UK" site.


Archived Guidance 2005/2006

This letter looks to be from the DVLA:

Re. Motor Caravans – Assessment for First Licensing/Registration Purposes.

Full text:

Issued November 2005

Re. Motor Caravans – Assessment for First Licensing/Registration Purposes.

The Driver and Vehicle Licensing Agency (DVLA), supported by the Vehicle and Operator Services Agency (VOSA) have since May 2005 been checking vehicles declared to be a Motor Caravan, prior to first licensing/registration.

This check is aimed at ensuring that only such vehicles considered to be a motor caravan under the Type Approval requirements are given exemption from those requirements for the purposes of first licensing/registration.

In order to maintain a consistent approach from those conducting the examinations an information photo-pack has been circulated, a copy of which follows for information.
The document aims to give general guidance on the degree of conversion that is likely to be considered necessary to a vehicle to enable it to be considered a Motor Caravan and an indication of those vehicles that would be considered to remain a passenger vehicle, and thus subject to a form of Type Approval.

Please note vehicles that are not considered to meet the Motor Caravan criteria will require evidence of Type Approval (ie Single Vehicle Approval) at the time of First Licensing/Registration.

The information in this document becomes effective from January 2006.

This is the "Photo Pack" that accompanied the Nov 2005 letter:

Motor Caravan Assessment for the purposes of Type Approval / Registration

This is the Introduction to the "Photo Pack":

Many vehicles are manufactured or adapted to provide living accommodation. The degree of accommodation that is provided ranges from the fully converted motor caravan having all the fixtures and fittings expected of a “motorised caravan” to a vehicle fitted with only the bare essentials, required for a day out, with a detachable camping stove etc. Both ends of the spectrum may well comply with the list of items that a motor caravan must include, however the initial consideration must be whether it is a vehicle that a reasonable person would consider a motor caravan.

In the case of adapted passenger/goods vehicles the consideration must be whether the degree of adaptation to the interior results in its specification being of the level expected in a caravan type vehicle resulting in the vehicles primary purpose being to provide living accommodation.

The following pictures give examples of what should and should not be considered to be a motor caravan for the purposes of Type Approval/Registration.

Each photo has a text box alongside that describes the modifications to the interior and states whether or not the vehicle should be considered to be a "motor caravan". There are photos of six vehicles that illustrate what a "motor caravan" might look like.

Then there is a photo of the exterior of a van with a warning:

This vehicle has a raisable roof which can be used for sleeping accommodation. Having such a roof does not automatically categorise the vehicle as a Motor Caravan. People carriers are manufactured with this facility. The general perception of the vehicle interior must be taken into account when considering how a “reasonable person” would view the vehicle.

Then there are photos of the interiors of seven converted vehicles which do not meet the criteria to be considered a "Motor Caravan". The descriptions for the last five vehicles all end the same way:

The vehicle is therefore primarily a passenger vehicle (sometimes termed a “Day Van” due to the facilities available) and is not a motor caravan


Searching the National Archives for relevant materials, there seems to have been a lot of consultations in 2005 about caravans, caravan sites and "travellers".

I wonder if all the added detail about what constitutes a "Motor Caravan" and the inspections, making it harder to register a vehicle as a "Motor Caravan", is related to that? It predates the "Directive 2007/46/EC (Framework Directive)", which is more detailed than the pre-2005 UK descriptions but less detailed than the 2005/2006 UK descriptions.


Archived Guidance 2001/2002

This seems to be all that the Government required of a "Motor Caravan" before 2005/2006:

Department for Transport, Local Government and the Regions Booklet SVA4 (The Single Vehicle Approval Scheme)

Updated 7 September 2001, Archived 2 January 2002.

Motor caravan means a special purposes passenger car constructed to include living accommodation which contains at least the following equipment:

- seats and table,

- sleeping accommodation which may be converted from the seats,

- cooking facilities, and

- storage facilities.

This equipment shall be rigidly fixed to the living compartment; however, the table may be designed to be easily removable.

It is the same wording as in the EU Directive 2007/46/EC (Framework Directive).


Archived 1996/1997

There might be earlier publications or others from this period but I was losing the will to live! sad

The description here is very brief and focuses on purpose rather than provision, with no mention of methods of construction!

Dept of Transport: How To Permanently Import Your Vehicle into Great Britain

Last updated 16 December 1996
Archived 29 April 1997

"Motor caravan" means a motor vehicle which is constructed or adapted for the carriage of passengers and their effects and which contains, as permanently installed equipment, the facilities which are reasonably necessary for enabling the vehicle to provide mobile living accommodation for its users.

----------------------

That is a HUGE leap from 1996 to 2006, with a slight shift towards an actual "spec" in 2001.

What is intriguing is that the 2001 wording is exactly the same as that in the EU Directive 2007/46/EC (Framework Directive). 

- Maybe there was an earlier EU Directive, some time between 1997 and 2001, that led to a change in the UK Guidance in 2001?

- What else was going on in 2005 that resulted in the DfT producing such a massively more detailed "interpretation", plus vehicle inspections, in 2005/2006?

If anyone stumbling across this topic has the answers, do tell! I have completely exhausted my nosiness into all this :-)


Best wishes,

Liz


Fiat Scudo 2006 Campervan
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#6 2018-04-25 23:52:04

vaz2121
Member
From: Glasgow Living:~ SW. Scotland
Registered: 2015-08-31
Posts: 1,311

Re: DVLA Clarifies Motor Home minimum cooking facilities: one ring not two

Having skimmed through this topic rather than deeply read through......

A couple of things intrigue me
1."Passed" by the DVLA have been fined when they traveled elsewhere"...............
Unsure of the context of that ..........  Traveling abroad?
Having a background in Haulage .....
I.E. We had a couple of Artic Units Bought and Registered in Southern Ireland and although to look at were identical to the UK bought and registered vehicles yet the Irish ones didn't require nor were they fitted with rear fog light as per UK requirement yet they were perfectly legal to run in the UK and Europe as they did on an almost weekly basis without problem ....So were actually unable to light the trailer rear fog light as all our trailers were UK or European built or bought......... I admit this wasn't recently

Another example was a South African built/bought Opel we imported it went through a SVA admittedly and we were issued a document/supplement that basically we showed the MOT man that " None fitted and It did not require a catalyst convertor nor was it be fitted with any airbags" It did require a rear fog light and strange to us ......was fitted with air con.

2.My van converted since new (2005) and is registered as a Motor Caravan But does not have nor does it appear to ever had a table.......

I thought as long as it met minimum requirement for Home/registered country all was OK ..... regardless where you drove..............

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