A hypothetical, if I may..

[Peterng]

I got to thinking, (I do this sometimes...I just can't help it..)..when I was securing the 3500kg rated steel D Shackles incorporating the trailer chains onto the Pajs' tow bar in the process of attaching the campertrailer to the Paj. (which I might add...campertrailer weights 1600kg GVM)..

I have two of the new synthetic ADR rated and approved D Shackles that are certified to 3500kg, which can fit through the attachment holes..they are lighter, less of a hassle and quieter in tow bar holes.

What if...

Question: Is it illegal to use ADR approved synthetic, rated to 3500kg D Shackles, instead of the steel rated 3500kg D shackles to attach your drawbar chains to your tow bar?


Legal arguments please...for and against...

[Dicko1]

Cant see any problem if ADR approved and rating is stamped on the shackle. Modern technology is seeing many things move away from traditional steel. If it meets the Australian standards then shouldn't be a problem. These have been around for many years with boaties/yachties well versed in their use. The only concern I would have is that they stay in place when towing and that they are supported by a round , smooth surface. A sharp edge as found on a recovery point may cut the strap pretty quickly. I,ll just stick to the rated steel shackles on the trailer as I see no advantage with these. Weight advantage...negligible. Price...a lot dearer than steel. Ease of use...no difference Does the synthetic shackle have the relevant rating impregnated on it somewhere? Also being used on a trailer they will collect a lot of dirt/dust/mud and if constantly moving as you drive this will lead to wear on the shackle.

[old Jack]

Hi Peter,

This thread may be of some interest.

https://www2.pajeroclub.com.au/forum/showthread.php?t=53354

OJ.

[mrbitchi]

You don't need 3500KG WLL shackles for your trailer. Max required is 1000KG WLL.

[erad]

There is a lot of hype about rating of shackles etc. Yes - I know about the theory etc, but really, what is going to happen if your trailer falls off the towball? Answer - the safety chains are going to (hopefully) take up the load. However, under normal conditions, the maximum load on the safety chains (and hence the shackles) would be the towball weight. Obviously you are going to apply the brakes when you realise that something is amiss behind you, and that means some braking load transferred form the trailer to the car via the chains.



How much load? Who knows. If you hit something and your car stops suddenly, the trailer will continue on until the chains stop it, but by then there will be a fair dent in the rear of your car as well. The load could be well in excess of the trailer weight, or it could be marginally more than the towball weight. Some beanhead in the RTA or whatever probably has decreed that the rating has to be xxxx kg, and that probably has no semblance of any logical reasoning behind that rating.


OK, I'll hop off my soapbox now. By the way, I do have rated shackles on my caravan, but the rating is nowhere near the towing capacity of my Pajero. To get shackles with that rating would require ones with pins about 16 mm diameter, and there is no way those pins would fit in the holes in the towbar. Hopefully if a copper sees the yellow pins he will look for something else.

[nj swb]

Hopefully if a copper sees the yellow pins he will look for something else.

Paint them red and he'll think you're a champion!

[old Jack]

https://www2.pajeroclub.com.au/forum/showpost.php?p=511183&postcount=5

OJ.

[Having Fun]

https://www2.pajeroclub.com.au/forum...83&postcount=5

OJ.

Would you be able to post a link to the requirement for rated shackles? I've looked & can't find any for SA. Here's a link saying that you can even use a cable, instead of a chain?

https://www.sa.gov.au/__data/assets/pdf_file/0003/6375/MR25-Light-vehicle-towing-trailer-regulations-GVM-4.5-tonnes-or-less-1.18.pdf

(I use rated shackles)

[Having Fun]

Another link:

https://www.goseeaustralia.com.au/news/818-national-rules-short-on-specifics-but-south-australian-police-urge-rated-shackles-for-towing-safety

Not official, but seems legit?

[old Jack]

From Queensland, page 5&6.

https://www.tmr.qld.gov.au/~/media/Safety/Vehicle%20standards%20and%20modifications/Loads%20and%20towing/Safe%20towing/Safe_towing_guide.pdf

The physics do not change at the state borders.

Best I can do for SA is this;

https://dpti.sa.gov.au/onroad/news?a=131252

However ADR 62.02 does cover all connections between vehicles and a trailer or caravan is classed as a vehicle.

https://www.legislation.gov.au/Details/F2010C00153

OJ

[Having Fun]

Thanks for those links, it's pretty much like I thought; they advise you to use rated shackles (again I do), but they haven't legislated that you must.


Prior to my starting to use rated shackles (for my own piece of mind) I used to use non rated shackles - I've twice been pulled over for random roadworthy checks in the suburbs of Adelaide (I tow pretty much everyday) and they went through me like a dose of salts both times. On neither occasion did they fault the non rated shackles (nor anything else).


Once was outside the dump at Wingfield & they were defecting more trailers that exited than they were letting pass. The other time was on OG Rd.

[old Jack]

WA regs.

https://www.transport.wa.gov.au/mediaFiles/licensing/LBU_VS_CI_119.pdf

OJ.

[old Jack]

After much searching I found this which clearly explains the situation in regards to safety chains on trailers across Australia. It is easy to see how people including the Police get it wrong!



From the RVCS website, the table in the copied text below has not formatted correctly

http://rvcs-prodweb.dot.gov.au/

CIRCULAR 0-1-3

SAFETY CHAIN CONNECTION DEVICES FOR ROAD TRAILERS WHICH ARE UP TO 3.5 tonnes (3,500kg) AGGREGATE TRAILER MASS (ATM)

1. Scope

The purpose of this Circular is to provide assistance for owners and operators in selecting an appropriate safety chain connection device for a road trailer of up to 3,500 kg ATM.
2. Introduction

The Commonwealth’s Motor Vehicle Standards Act 1989 (the Act) requires all road vehicles (including trailers and caravans) to comply with national vehicle standards known as the Australian Design Rules (ADRs) before they can be supplied to the Australian market for use in transport. The ADRs are performance-based standards for vehicle safety, vehicle emissions, anti-theft and to promote the saving of energy.
Once a vehicle has been supplied to the Australian market, matters of in-service compliance, including registration, allowable combination vehicles,roadworthiness and modifications (including the fitting of aftermarket components) pass to relevant state or territory road authorities. Generally, state and territory road authorities require a vehicle to continue to comply with all relevant ADRs as of its date of manufacture (or later), with exceptions to account for special use vehicles and vehicle wear and tear.
The Australian Motor Vehicle Certification Board (AMVCB) provides a mechanism to manage specific issues that may occur from time to time between first supply to the market of a road vehicle and in-service operation. In this instance, the AMVCB has agreed to provide guidance material to assist owners and operators of light road trailers in selecting the appropriate safety chain connection device for a road trailer of up to 3,500 kg ATM.
This guidance material was developed with the agreement of state and territory regulators in order to provide a uniform approach in Australia to the use of safety chain connection devices. Since there is no legal obligation to comply with this guidance material, if an individual or a company chooses not to follow this material, it is the responsibility of the person or the company to demonstrate to state or territory road authorities that a particular safety chain connection device is appropriate for the combination vehicle.
3. Background to shackles as safety chain connection devices

Bow-Shackles and D-Shackles that comply with Australian Standard (AS) 2741 are rated for lifting applications and have a breaking load marked on the shackle that is higher than the Working Load Limit (WLL). Since the loading on these shackles is different when used to attach a safety chain to a road vehicle as compared to when used in lifting applications, a road trailer may be towed that is heavier than the shackle’s WLL.
The relationship between WLL and towing capacity is given in Table 1. Typical shackles recommended based on trailer ATM.

4. Safety chain connection device recommendations

Safety chains may be attached to the towbarattachment points with a Bow, D or Pin-Shackle. As they are considered integral with the towbar, safety chain attachment points on the towbarthat include a Pin-Shackle or bolt for attaching the chain are subject to performance requirements as per ADR 62/01 or 02 - Mechanical Connections between Vehicles.
Shackles used to attach safety chains to towbar attachment points should at a minimum exceed the required rating of the safety chain, as determined by the ATM of the road trailer. Additionally, the shackle should be fit for purpose and compatible with the safety chain in terms of strength and size. This may be fulfilled by:
a) The use of a shackle that is compatible with the safety chain and complying with AS 2741. In this case, the shackle must have appropriate markings, as identified below:
· Manufacturers Identification;
· Quality or Grade as M or 4, or S or 6;
· WLL, the maximum load that may be applied to the shackle; and
· Identification marking to trace the shackle to a test certificate.

Trailer ATM (kg)

For Bow or D-Shackles complying with AS 2741

Minimum shackle Working Load Limit
(WLL) (kg)

Minimum size of shackles
(Body diameter, not pin size)

Grade M (or 4) D-Shackle (mm)

Grade S (or 6) D-Shackle (mm)

Grade S (or 6) Bow-Shackle (mm)

0-1,000

250

6

6

5

1,001-1,600

400

10

6

6

1,601-2,500

625

13

8

8

2,501-3,500

875

16

10

10

Table 1 – Typical shackles recommended based on trailer ATM

b) Alternatively, the use of a shackle that is compatible with the safety chain and is of a reputable brand. In this case, the shackle will have appropriate markings to show the brand and or part identification sufficient to trace its brand and strength back the original manufacturer.

5. Definitions

For definitions used in this Circular, refer to Vehicle Standard (Australian Design Rule Definitions and Vehicle Categories) 2005, as well as the following:

AGGREGATE TRAILER MASS (ATM) - the total mass of the laden trailer when carrying the maximum load recommended by the ‘Manufacturer’. This will include any mass imposed onto the drawing vehicle when the Combination Vehicle is resting on a horizontal supporting plane.
AUSTRALIAN MOTOR VEHICLE CERTIFICATION BOARD (AMVCB) – A consultation forum that consists of representatives of government (Australian, state and territory as well as the National Heavy Vehicle Regulator and the National Transport Commission), with its primary role being to facilitate the first supply of vehicles into the Australian market.
AUSTRALIAN STANDARD 2741-2002 “SHACKLES” (AS 2741) - Specifies requirements for forged shackles.
AUSTRALIAN STANDARD 4177.4-2004 “CARAVAN AND LIGHT TRAILER TOWING COMPONENTS - SAFETY CHAINS UP TO 3,500KG CAPACITY” (AS 4177.4) - Specifies requirements for safety chains.
BOW-SHACKLE – “O” shaped body that is enclosed at the end by either a threaded clevis or cotter pin and used to connect a safety chain between a road motor vehicle and road trailer.
CARAVAN - any enclosed road trailer designed primarily for human occupation whilst stationary.
COMBINATION VEHICLE - a combination of a road motor vehicle and one road trailer.
D-SHACKLE – “U” shaped body that is enclosed at the end by either a threaded clevis or cotter pin and used to connect a safety chain between a road motor vehicle and road trailer.
PIN-SHACKLE – a device integral to a tow bar, which may consist of brackets and a bolt, clevis or cotter pin and used to connect a safety chain between a road motor vehicle and road trailer.
ROAD MOTOR VEHICLE - a motor vehicle designed solely or principally for the transport on public roads of people, animals or goods or a motor vehicle that is permitted to be used on public roads.
ROAD TRAILER - a vehicle without motive power designed for attachment to a road motor vehicle; or a piece of machinery or equipment that is equipped with wheels and designed to be towed behind a road motor vehicle.
SAFETY CHAIN – a chain, which is attached between the towbar of a road motor vehicle and the drawbar of a road trailer and, which for a road trailer with a ATM of up to 3,500kg meets the requirements of AS 4177.4, or is a cable which is appropriate for the application; and for a road trailer with a ATM exceeding 3,500kg a steel chain with a minimum of 800MPa breaking stress that conforms to the mechanical properties of Grade T chain.
SAFETY CHAIN CONNECTION DEVICE – a device that connects a safety chain to the towbar (mechanical connection) of a road motor vehicle, for example a D-shackle, Bow-Shackle or Pin shackle.
TOWBAR - a device attached to a road motor vehicle provided for connection of a road motor vehicle to a ‘Coupling’ for the towing of a road trailer.
WORKING LOAD LIMIT (WLL) – the maximum load that may be applied to a Bow, D, or Pin-Shackle.





Regards, OJ.

[Peterng]

I'll throw another one out there....

The ADR regulations, Cica 1989 act, will need a fair bit of updating for technology has moved on at such a pace that our regulators are wallowing in its' wake.

In this case..(pardon the pun)...with the introduction of synthetic material shackles being used.

There is a "bolstering of the reputation" for legal brief who wants to test it in the high court...big call....

"This guidance material was developed with the agreement of state and territory regulators in order to provide a uniform approach in Australia to the use of safety chain connection devices. Since there is no legal obligation to comply with this guidance material, if an individual or a company chooses not to follow this material, it is the responsibility of the person or the company to demonstrate to state or territory road authorities that a particular safety chain connection device is appropriate for the combination vehicle."

To argue the case / s

1/. "That the States have been "using the ADR guidance material" as fact and have implemented their own legal impost, where none should be placed..in this case with "chain connection devises" and should not consider this as part of a trailer being in an unroadworthy state...if the owner can justify / demonstrate that the connection device they have used is appropriate"

2/. That the ADR regulation circa 1989 act in relation to towing with reference to tow chain connecton devices, specifically D Shackles, is outdated and needs updating to reflect changes in manufacturing technology.

If a synthethic shackle is rated and printed with the necessary WLL on it, then used by the owner in place of a D Shackle..explained that the synthetic shackle are used in 4wd recovery, in some cases..instead of steel D shackles... plus has a WLL in excess of the GVM weight of the van/trailer etc...that may suffice...
...but then again...
the safety inspector would think.."what a smart fk ...." and would walk around and start to pick on something else...to bolster the unroadworthy ticket!

Also another. question /s....if I may..

1/. Is there a ADR regulation / s for "recovery gear"used for retrieving vehicles or has all that have now within the 4wd industry has "morphed" over time and experience from manufacturers and 4wd users?
and

2/. Is this how unscrupulous importers and OS manufacturers are infiltrating the industry...because of the lag of regulation and implementation?

[old Jack]

I completely agree with your comment that the Australia Design Rules have not kept pace with the changes in technology.

There are many many towbars which are "ADR Compliant" which become non compliant as soon as you couple a trailer! Reason is the safety chains must prevent the trailer drawbar form contacting the road surface if the trailer becomes unhitched. The actual connecting length of the safety chain on a trailer should be no longer than the distance from the safety chain lugs on the towbar, when the trailer is hitched, minus the length of the attaching shackles, this would be the absolute minimum as there is not allowance for dynamic suspension compression. Years ago the safety chain attachment was just some 1/4inch rod bent into a pig tail hook, these where a token effort, then there was a significant U Bakst welded under the towbar with a 1/4inch or 5/16th threaded rod. Both these were located near the towball, even on earlier removable tongues. It all went wrong when it was ruled that the safety chain lugs were no longer allowed on the removable tongues and the tongues become longer, so the safety chains are now on the the main drawbar some distance from the towball, the net result are safety chains are now too long so they allow the trailer drawbar yo contact the ground if the coupling becomes disconnected.

In regard to vehicle recovery gear, it is not covered by an ADR because it is not a permanent fixture to the vehicle and or does not change any of the ADR's complied with when the vehicle was new.
There is however a Australian Product Safety Standard that covers these;

https://www.productsafety.gov.au/standards/recovery-straps-for-motor-vehicles

Unfortunately there are many aftermarket Auto accessories that are legal to import and sell in Australia but if you fit them to your road registered vehicle then they can make your vehicle illegal! Go figure the logic on this!

OJ.