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There are about 104 brake disc pad brands on the local market, of which only 44 of 97 independently tested at the RMI’s behest are fully compliant with industry standards. SHEETAL SCHNEIDER CROSS investigates.
Current research shows that in 2009 there were 17 brands of disc brake pad on the South African market but that the motor industry has since been flooded with brands that have pushed this number to 104. Although competition is essential to ensure fair pricing practices in growing markets, the alarm bells should be ringing: why so many new brands, are they safe, who does the testing and do the brakes in any way contribute to SA’s appalling road accident rate? Road safety issues are a national priority and the government has joined the United Nations Decade of Action for Road Safety 2011–2020 campaign. Extensive research by a national steering committee has been uncovering the causes and effects of the increasing number of deaths on our roads. New methods to penalise irresponsible drivers are being implemented; however, we also need to ascertain the manufacturers’ possible role in road deaths, particularly since brake disc pad products which fail to meet requirements are still ending up on the local market.
According to the Compulsory Specifications for Replacement Brake Lining Assemblies, “The Minister of Trade and Industry may, on recommendation from the Board of the National Regulator for Compulsory Specifications (NRCS), in respect of any product, commodity or service which may affect public safety, health or environment, declare a SANS (South African National Standard) as a compulsory specification.”
Noting that the government has mechanisms in place to police defective or rejected disc brake products, why is there an increasing percentage saturating the market? The requirements clearly state that “no person may import, sell or supply a commodity, product or service to which a compulsory specification applies, unless: the commodity, product or service complies with, or has been manufactured in accordance with, the compulsory specification, or both; and if applicable,the distinctive mark referred to in section 13(6) (a) has been applied…”. The mark of approval and quality refers to the South African Bureau of Standards (SABS), which is proclaimed as Africa’s leading standards-testing body. The other is the E-mark from the Economic Commission for Europe (ECE). Authorisation to display the E-mark is granted by a certified European agency hat conducts extensive testing to ensure the product meets regulated requirements such as reflectiveness, colour and durability.
ECE 90 is a South African company established in June 2001 with the objective of providing a test-and-certification service for replacement brake-lining assemblies. Its work primarily meets ECE Regulation 90 as well as other national, international and industry specifications used in the brake friction industry. Consequently, ECE 90 has been accredited by the South African National Accreditation System (SANAS)
to the requirements of ISO/IEC 17025. Andrew Thevan, the general manager of ECE 90, provides more insight into the testing processes: “The SABS mark of approval is not a compulsory requirement for brake pad manufacturers and suppliers. The compulsory specification for replacement brake pads is that they need to comply with the minimum compulsory specification, SANS20090:2010 or have an E-mark which is compliant with the European Standard, ECE Regulation 90. ECE 90 is acceptable in South Africa because of trade agreements between South Africa and Europe.”
Requirements for SANS20090:2010 (in accordance with the SABS) are comparable, with the exception that some aspects of ECE 90 tests are undertaken on the vehicle. Furthermore, the SABS mark is a quality mark that has other elements attached to it, such as a working quality system, conformance of production audit and SANS20090:2010 compliance. Thevan firmly believes that only compliant brakes should be sold. “There is good legislation in place; what is required is enforcement of the law to ensure compliance,” Thevan says. “The industry needs to work together with government to ensure non-compliant products and brands are identified and the law enforced, because substandard cheaper products that do not comply will upset the market, as opposed to cheaper products’ making the market more competitive.”
In SA, the NRCS Act states that all friction material products – brake pads – require a Letter of Authority (LOA) in terms of Section 13(6)(c), which also forms part of the pre-approval process under the applicable compulsory specification (VC 8053). The regulation of the Compulsory Specification for Replacement Brake Lining Assemblies, published in Notice No. R95 of Government Gazette No. 22 014 (2 February 2001) (VC 8053), which was later replaced by Gazette No. 33 211 of 28 May 2010, is the responsibility of the NRCS and no longer that of the SABS. However, as research by the RMI shows, this apparently has not stopped numerous manufacturers from importing products with industry-approved marks that fail the compliance requirements. The RMI recently conducted testing, as an initiative to partner with the industry and the NRCS, to help eliminate non-compliant brake products that have a negative bearing on the safety and health of the South African population. Ndaba Mhlanga, director of the MPEA at the RMI, said, “The RMI promotes the need to have affordable aftermarket parts or brake pads made available to the South African public and advocates the need to ensure that brake pads sold in SA meet the required safety-critical standards. However, this should not be achieved at the expense of quality products that meet the required safety standards and which have a direct mpact on people’s lives.”
Daniel Ndiambani Ramarumo, media and public relations specialist for the NRCS, has reiterated that manufacturers and importers of brake-lining assemblies are subject to a pre-approval process as a primary measure to ensure compliance to mandatory specifications. He added that the NRCS ensures that regulations are met by conducting inspections to assess suppliers. “Random surveillance inspections at manufacturer/importer premises are also undertaken, which is also complemented by a sampling process inclusive of the test evaluation of friction products in order to verify continuous compliance. Surveillance inspections are conducted as timeously as possible, which may vary from one manufacturer/importer to another, depending on the risk profile,” said Ramarumo.
The NRCS has further considered its policing methodologies at border crossings and checkpoints through which delinquent suppliers often import unwelcome goods. This is known as the Border Enforcement Project. Ramarumo said the project’s implementation has been instrumental in ensuring that imported products are stopped from entering the South Africa without an LOA. “The NRCS, through its automotive division, has also been visible at Automechanika exhibitions to educate potential new entrants to the brake-lining market about LOA requirements and other relevant regulatory issues, not forgetting rigorous measures that are also applied at point of sale, comprising brake-lining retailers, with the aim of preventing non-compliant friction products being sold to the consumers,” Ramarumo added. Ramarumo explained that in terms of the Compulsory Specification for Replacement Brake Lining Assemblies – VC 8053 – E-marked friction products are deemed to comply as an equivalent standard under the 1958 agreement of the United Nation Economic Commission of Europe (UNECE), to which SA is a signatory.
Nonetheless, the existence of the E-mark does not necessarily preclude the NRCS from subjecting such products to evaluation tests in order to verify compliance or eliminate the chances of fraud. The NRCS, through the 1958 agreement, is also able to verify the validity of any E-marked product by acquiring credible compliance documents from its UNECE counterparts. This is embedded in the pre-approval process.
If a disc brake pad product fails the compulsory standard set by the South African National Standards (SANS) or does not have the necessary paperwork but still ends up on the market, how does the NRCS deal with the manufacturer? “A sanctioning process will take effect by issuing a CEO directive that may compel the manufacturer concerned to stop the sale of such products. Further action may be instituted at the discretion of the NRCS board to direct the company to either implement a recall campaign and/or return the product to the country of origin where applicable (importers),” said Ramarumo. Although this should ideally deter suppliers, manufacturers and certain distributors from introducing compromised products, this problem still arises.
Filum Ho, director of Grandmark International, a South African distributor of a range of aftermarket parts from various international suppliers, believes there will always be unscrupulous operators. “The key,” he said, “is a stronger and more effective policing strategy. The problem of non-compliance needs to be dealt with at source, which is the distributor of these products. Failures occur for several reasons, some not pertaining to performance but to technical issues such as markings, batch numbering and packaging, which are easily rectifiable. It is important that the impact of an increasing focus on brake safety does not evolve into a witch-hunt that limits competition or favours a select few. We already have the correct mechanisms in place to control the quality of brake pads being sold. The key, as always, is when the rubber hits the road, and the actual policing,” said Ho.
GUD Holdings CEO Red Shuttleworth said he was aware of the issues surrounding brake pads but that the exact statistics still came as a surprise. “As an aftermarket parts service provider, this has an immense impact on our company, because the playing fields are not level. The quality of these new brands entering the local market are not at the required level, and in many cases these products are not sold any cheaper than the well-known and respected brands. Retailers are selling them for profit gain.” Shuttleworth feels strongly that because so few of the brake pads on the market adhere to standards, it has become a serious threat to the public’s health and safety. “I believe there should be a regulation that requires that every imported brake pad product be tested by the SABS, no exceptions.”
Federal-Mogul, a leading global manufacturer of friction materials and a member of the RMI friction standards committee, said it, too, was aware of the brake pad non-compliance issues in the local aftermarket. “These issues are serious, as they have a direct impact on customer safety,” said Technical and Quality Manager Reegan Govender. “Federal-Mogul prides itself on its status as a global leader in friction technology and its