Roadworthiness: A rationale for vehicle inspection systems

Page Type: 

EXECUTIVE SUMMARY

The following key points emerge from the fuller report below:

  • Annual vehicle inspection has some benefits to roadworthiness of vehicles but also has severe limitations and anomalies.
  • The current annual vehicle inspection system is not fit for purpose.
  • Capacity for extended inspection cannot be sufficiently or rationally achieved without private sector partnership.
  • In addition to the formal motor sector, key partners in an improved roadworthiness system could include the insurance and finance industries.
  • Any revision of the formal system should achieve more frequent checks and encourage and enable owner-motivated inspection.
  • Vehicle inspection should be conducted:
    - daily, constantly, by vehicle owners.
    - at every service interval by professional workshops which can also undertake on-the-spot repairs.
  • State vehicle inspection systems/resources should be devoted to assessing, certifying and monitoring workshops.
  • Vehicle roadworthiness is important, but it is only one, and not the most important factor in overall road safety.
  • Distinction must be drawn between the valid Standard of KS1515 and a shorter, simpler list of safety priorities for the inspection process.
  • Policy should address the causes – not first nor only the symptoms – of unroadworthiness.
  • There is much in road transport system less "roadworthy" than vehicles.

The roadworthiness of drivers, other road users, spot-check policing, road markings and signage, road maintenance, road design, driving tuition, driving tests, pedestrian and cycle paths, public education, etc, are all more urgent and more significant priorities. NTSA should design and then “unload” its inspection system (which is viewed as corrupt beyond redemption)  to enable more focus on these other areas.

NTSA’s great strength and opportunity is not just to take over the running of existing road transport/road safety elements, but – for the first time - to co-ordinate and  prioritise their functions,  and therefore to re-package the whole set in a completely new way.

The effect would be positive … and very popular  (ergo attracting massive public and commercial support).

CONTEXT

The NTSA has declared “Road Safety” to be its highest priority.

The KMI fully supports this strategic view.  While safety can never take unconditional precedence over the mobility of people and the transport of goods, safety must be intrinsic to all road transport designs, systems, operations and plans.  Mobility for economic and social function must be achieved without undue hazard, not least on humanitarian grounds.

There is no such thing as “safe” road transport.  The target should be seen as making road use “less dangerous”, by minimizing the causes, incidence and consequences of hazards which lead to accidents, damage, injury and death.

Further, the measures which will make road use less dangerous will also make road transport more efficient in time, cost and productivity.

Thus while road safety is not all-important, it is a valid priority, especially in the context of Kenya’s especially dangerous current road transport system.

The NTSA has identified the “roadworthiness” of vehicles  as a central pillar of its road safety initiative.

The KMI strongly recognises the benefits of good quality vehicles maintained in good condition, but cautions against over-stating the importance of vehicle roadworthiness in relation to many other road safety factors. Certainly, roadworthy vehicles deliver more reliable, durable and efficient transport.  But roadworthiness alone does not achieve safety.  While some mechanical defects can and do cause some accidents, not all defective vehicles crash and not all roadworthy vehicles don’t crash.  Indeed, the overwhelming majority of road injuries and deaths involve vehicles which would be considered fully roadworthy. The “roadworthiness” of drivers, riders and pedestrians is among several more significant (and concerning) factors.

The NTSA has identified annual vehicle inspection as a key mechanism to ensure better roadworthiness of vehicles.

The KMI strongly disagrees.  The condition of a vehicle can change from perfect to lethally dangerous in a split second; some components wear out in normal use several times per year, and even safety critical components are subject to progressive deterioration and potential failure at any time during a year, whether or not they have been inspected.

Maintaining a vehicle in roadworthy condition requires the daily awareness of the user and thorough inspection, maintenance and rectification by qualified mechanics at every service (circa every three months).  Anything less than that will do little to ensure roadworthiness, and the impact on road safety, by any significant measure, will be nil. Better odds of success are offered in a game of roulette.

Formal annual vehicle inspection may have a useful but secondary part to play, but it is by no means a “key mechanism”,  it is not necessarily essential, it is fraught with anomalies and cost-benefit doubts, and it is in danger of detracting attention and resources away from many more important and effective measures.

There may be useful lessons to learn from how effective vehicle inspection systems in other countries operate.  In parallel,  Kenya’s particular socio-cultural patterns must be taken into account.  External best practice may help, but it is unlikely to translate without modification to local circumstances.

The NTSA proposes to extend compulsory annual vehicle inspection from a small fraction of the national fleet to all vehicles over four years old (>80% of the fleet), using public-private partnership to achieve the necessary capacity.

Whatever the scope or format, annual inspection cannot be meaningful unless it is more thorough than any other interim check.  The benchmark test is defined (rightly or wrongly) by KeBS Standard KS1515.  Proper conduct of this inspection on one vehicle would take a skilled diagnostic team with sophisticated equipment and elaborate facilities not less than two hours.  Applying the Standard to every vehicle, even just once a year, would require 1,200 skilled teams, working with perfect efficiency and using equipment and facilities on a scale of several major industrial complexes.

If the KS 1515 test was conducted thoroughly and with zero tolerance, even this capacity could be overwhelmed because the majority of vehicles would fail and require re-testing after repair.

Certainly, the necessary capacity cannot be achieved without substantial input from the private sector.  This input should be achieved with a simple, step-by-step approach.

PRIVATISATION

One logical option would be to reassign all existing State vehicle inspection resource to assessing commercial workshops, certifying them to conduct all vehicle inspection, and monitoring their performance.  Even such wholesale transfer can be achieved in progressive phases (eg initial limits on the types of vehicles requiring inspection under the new system).

Engaging private sector  workshops could muster the necessary capacity;  it would save time and cost by inspecting vehicles where they are routinely serviced; and any defects found could be rectified on the spot.

KMI members could immediately provide the most assured and largest part of this private sector resource, and would be willing to invest in further capacity if the technical and contractual formats were appropriate.  Within that design, KMI would propose that meaningful safety checks become a mandatory part of any and every vehicle service (ie an item on every job card), irrespective of whether or not there is also a certified  annualinspection. KMI would also propose that any safety critical parts used in service, replacement or repair  must be new, genuine,  and carry a meaningful warranty of quality recognized by major vehicle manufacturers as actual or equivalent to original equipment.

PRIORITIES

The NTSA  has an unprecedented opportunity to improve the roadworthiness of vehicles in Kenya.  As a lead agency,  it has the mandate to examine all the policies and practices which have an impact on vehicle quality and condition, and the authority to interconnect and overhaul the entire system, not just individual parts of it.

The KMI pledges its absolute support for this process, and declares that its members are ready to participate to the fullest possible extent in any practical and equitable measures to improve the roadworthiness of vehicles towards high international standards.

Until now, roadworthiness standards have been set by one organization (KeBS),  vehicles are inspected by another (Vehicle inspection Centres), and compliance is enforced by a third (Traffic Police).   All have designed and operated their systems without any form of co-ordination with each other or the many other factors which profoundly effect vehicle quality, condition and maintenance.

Among these other factors are vehicle age.  Stating roadworthiness as a priority while permitting the importation of 8-year-old vehicles – with tax incentives – is a profound contradiction.

For example:

KeBS sets a blanket technical Standard (KS1515) with which all vehicles should comply, but has no say on whether or how those Standards are prioritized, checked or enforced.  The Standard draws no distinction, and offers no guidelines, on the difference between safety-critical and cosmetic defects.

Vehicle Inspection Centres have the mandate to inspect only some vehicles, and only annually,  and lack the skills, capacity and discipline to do even that inadequately partial job in accordance with KS1515.  There is no certainty of whether, what or how checks are conducted;  the outcomes of  “pass” or “fail” (there are no other options) have no formally defined benchmark, based on safety-critical or any other criteria.   

The Traffic Police conduct roadside spot checks with motives and methods almost entirely disconnected from any other or overall strategy or context.

Their technical qualifications (where is their certification?), selection of check priorities (decided by whom, on what basis?) and discretionary powers to warn or prosecute are random and based on a rationale known only to themselves.

These three pillars of roadworthiness regulation (KeBS, Inspection Centres and Police) have considerable authority in their own limited spheres but they are not harmonized nor correlated with each other,  and the exercise of their authority and the performance of their duty is itself not regulated. They are a law unto themselves.

Their existence and operations do make an indirect contribution to public awareness and impose some pressure on some compliance, but their impact on overall roadworthiness standards is minimal and the impact of that on road safety is nearly nil. The purpose they serve most effectively is revenue collection.

This is what NTSA is in prime position to remedy.

Cause and effect

The shortcomings of the current Standards/Inspection/Policing system, separately and collectively,  are severe (to the extent of making them not fit for purpose).  But there is a more serious and important problem than that.

The current vehicle inspection strategy is to find and fix faults.  No part of the system works to prevent faults occurring - by identifying and removing factors which cause vehicle defects in the first place. These include:

  1. The importation of used vehicles which are, by dint of age,  already or imminently defective on arrival, do not have appropriate specifications for local conditions,  and are not thoroughly inspected before registration.
  2. The importation of used safety-critical components which are by definition already worn and potentially defective (previous users have already thrown them away) and whose condition is not and cannot be established without the (impractical and often destructive) testing of every individual piece.  Used components offer zero scope for batch approvals, which are logistically essential to ensure the Standard of many millions of individual items.
  3.  A very high proportion of owners are not well aware which mechanical functions are most safety-critical, or of the risks caused by mechanical defects, and are not trained or experienced in diagnosing or assessing the cause and importance of faults, or the condition of parts or the quality of service and repair.
  4. Because vehicle purchase has been made artificially low-cost by used imports with preferential tax conditions,  a high proportion of owners who can now acquire vehicles  cannot afford quality parts or competent maintenance and repair.
  5. A proliferation of “low-cost” service operations which are not trained in or subject to quality Standards of any kind and who routinely improvise makeshift repairs which are prone to catastrophic failure.
  6. A high proportion of owners who have been neither trained nor tested on the judgements and skills necessary to minimize wear-and-tear and damage.
  7. Widespread road conditions which are especially damaging through sub-standard construction, negligent maintenance, bad design or officially sanctioned abuse (illegal speed bumps, unrepaired trenches etc).

Failure to address these causative issues will proliferate, complicate and perpetuate the problem of vehicle defects with far greater force than any inspection system has to potential to correct.

NTSA has a unique opportunity, and responsibility, to address the causative anomalies:

For example:

Current duty/tax systems incentivise low quality, sub-standard vehicles, parts and components, and actively deter purchase and use of new, high-quality products. While one arm of government is established to improve vehicle condition, many other arms are pursuing policies which allow and even encourage the entry of used or poor quality products in sub-standard condition.

To the extent that quality control operates at all, it focuses most on checking brand new vehicles and components supplied by the world’s most reputable manufacturers and marketed by their highly regulated official agents (ie items of best quality in best condition) and pays little or no attention to items most likely to be in poor condition and pose a safety hazard.

All current legislation and action focuses on finding faults and penalizing vehicle owners for failing to maintain vehicles properly. The majority of vehicle owners depend on commercial workshops for vehicle maintenance, yet there is no focus at all on workshop Standards, Inspection or Policing, and no public education of motorists to encourage and enable them to seek and demand higher service standards and good quality components.

A prime cause of vehicle defects is the condition of the road environment, yet there does not appear to be any Standard, Inspection and Policing of road design, road construction, road maintenance or road interference. The degree of defect in road surfaces, road alignments, road making and road signage far exceeds the level of defects in vehicles.

The impact of bad roads on vehicle condition can be ameliorated by more skillful driving, yet there is no apparent focus on better tuition or stricter testing or ongoing public education. The level of defects in driving practice far exceeds the level of defects in vehicles.

Again and again, attention and resources are applied to symptoms instead of root causes, which gives priority to minor interventions while ignoring major ones, and  this both exacerbates and perpetuates the problems.

CONCLUSION

If the causes are remedied, there will be an automatic and significant reduction in the number of defects, even without any inspection. If the causes ignored, defects will proliferate even with the most stringent and burdensome inspection system.

One strategy solves the problem, the other perpetuates it.  NTSA strategy is urged to recognize that prevention is better than cure.  Which is better?  Which is easier?  Which has more positive impact?

Strategic decisions should, self-evidently, involve the KMI as representative of the most heavily invested supplier of new vehicles, the closest link to vehicle manufacturers, and the largest vehicle service/repair network.

Standards/Inspection/Policing could potentially improve roadworthiness, but many other policies and practices in the overall road use system have the opposite effect.  Only now, with the appointment of a lead agency, can these anomalies be addressed.

ANNEX 1

Principles

The KMI recognizes that  policies and programmes which set and enforce high technical quality standards are essential to the economy, environment and national wellbeing.

In the road transport sector, this applies inter alia to vehicles, parts, components, and systems which maintain and repair them.  It is the KMI’s position that:

  • formal Standards conforming to international norms should be set for all these elements; 
  • compliance should be rigorously tested;
  • no sub-Standard product should be allowed to enter the Kenya market;
  • all such products should be maintained to the Standard during their lifetime use.

The benefits of upholding these Standards, and the negative impacts of failing to do so, may and should be taken as self-evident.

The challenges facing the NTSA are to ensure the set of Standards is comprehensive,  and to devise and establish practical systems which best ensure they are upheld.

Such systems will inevitably involve some form of inspection. Just as surely, owing the scale of products involved, the inspection tasks must be both prioritized and delegated. It is not possible for the State to physically inspect every item (the national fleet count of auto components runs into many billions, in a constant state of condition change).

Logic insists that the first and highest inspection priority should be applied to products before they enter the market.  If products do not comply with the Standard when they first arrive, the chances of them achieving and maintaining the Standard through lifetime use are much diminished and the problem of rectifying them is much increased.  Allowing the importation of sub-Standard products (and age is a critical factor) exacerbates an already daunting problem and undermines the entire principle of Standards.

However, even if all inspection effort and resource is focused only on point of entry, the task is logistically overwhelming.

Even if the resources for such a system could somehow be assembled, it would be able to certify no more than "on the one day" each vehicle was inspected, it was in up-to-Standard condition.

ANNEX 2

Assuring the Standard of newly manufactured items is relatively simple, because a single thorough inspection can lead to valid approval of large batches and even entire brands.  Even tests so thorough that they are destructive are viable, because by testing the quality and limits of just one item,  millions of identical items can be quality assured.  New items are also warranted.  Quality brands have self-imposed quality control standards and systems that far exceed any test Kenya is likely to demand or apply.  Yet it is to these brands, and these items, that Kenya applies the strictest and most expensive inspection.

The only way to assure the quality of used items is to inspect every single one, to a level of "blueprinting". On whole vehicles, this means disassembly, close check and test of every part, reassembly, and test of the reassembly quality. On individual parts, blueprinting means high stress and potentially destructive testing.   Both are logistically impossible and economically impractical. Yet used vehicles and parts enter with the least rigorous inspection or no test at all.  For duty avoidance/evasion reasons, a high proportion of used parts fitted to used vehicles on Kenya’s roads are imported as "scrap".

ANNEX 3

Vehicle owners do and will always maintain their vehicles to the highest standard they can – within the constraints of their own knowledge, available workshops skills,  and assurance and affordability of good quality parts.

Optimising these factors will, axiomatically, maximise standards and lead to improved roadworthiness. 

"Own knowledge"  will be improved first and most by public education campaigns, both generally and through driver tuition and testing.

"Workshop skills" will be improved first and most by training and incentivized levels of licensing.

"Assurance of  good quality" vehicles and parts will depend first and most on systems which prevent the importation of sub-standard goods.

"Affordability of good quality" will depend first and most on duty/tax regimes which give advantage to high-quality new goods, deter low quality and make used/sub-standard imports economically unviable.

Low taxes on used parts actively encourage dangerous market choices.

High taxes on new parts actively make safety too expensive.

The positive effect of reversing these two positions is self-evident – and a priority.

Contact Us

12, Lang’ata Link,
Lang’ata South Road, Nairobi
Box 15300 Nairobi 00509
Tel: 0720 274365, 0733 692032
Wireless: 020-2679585
coa@churchorr.org