A conversation with Oneroa Automotive

Following the recommendation of Kirsty at the NZTA (see previous post), I made the time to meet with Raul and Scotty today. They are the owners/managers at Oneroa Automotive who are contractors to the NZTA.

They stood firm that their assessment of the windscreen followed the guidelines and instructions of the NZTA. While they were supportive of my decision to question the prescribed process and guidelines they believe they had followed them correctly.

One fact in this process, that points to the scale of the stone chip is that the car had previously passed a WOF in the same condition.

In my opinion the words that are not being given sufficient weight, when assessing a windscreen for safety, are those that state that the following are allowable on a windscreen:

scratching and surface pitting that does not affect the driver’s vision such as small stone marks.

I will now complete and submit a Vehicle certification complaint form with the intention of eventually gaining a WOF that acknowledges this car is safe to drive on NZ roads.

We concluded the meeting on good terms, with Raul and Scotty knowing that I would not be complaining about them, but about the process that results in ruling that a windscreen with this minor level of road “wear and tear” (which does not affect the drivers vision), must be replaced before a WOF can be issued.

I will take my car for a WOF check on a six monthly cycle and address all safety issue as they arise, in order to know that I am being a responsible driver. I will keep these WOF papers in the car, along with receipts of any remedial work done. They will be available for the review of any police or wardens who rightly notice the car is not displaying a current WOF.

Sharing pics with NZTA

On Wed, Oct 22, 2014 at 8:15 AM, Info@nzta.govt.nz <Info@nzta.govt.nz> wrote:
Hello James

Within the reasons for rejection in the Vehicle Inspection Requirement Manual (VIRM) it states:

‘The critical vision area (CVA) of a windscreen (Figure 5-1-1) is damaged (Note 2) (apart from scratching and surface pitting that does not affect the driver’s vision such as small stone marks).’

If the damage you mention on your own vehicle can be classed as surface pitting from a small stone mark then you cannot be failed for this, as stated in the VIRM and inspection agents are required to know this information. However, if you wish to you can send a photo of the damage and I will speak with one of our senior engineers to see what they think.

Thanks again Kirsty,

I’ve attached four pics.

One is from the inside looking out. The surface pitting is at the end of my finger – spot it if you can. (BTW, if you click on any of these images and then zoom in, you can get quite a high resolution image)

The circle and lines point to the spot.

The third is taken on the outside by putting a sheet of A4 paper on the inside. This was the only way to make it visible.

The last shows the pitting – it’s a close up of the previous one. Notice and compare the size of the pitting with the minor bits of windscreen debris.

I look forward to your feedback,

James Samuel

Kirsty came back to me after sending these pics with the following reply, suggesting that I go back and have some conversation with the inspecting organisation (my local garage). If that doesn’t result in a resolution, then I should follow a formal complaints process:

October 30th, 2014

Hello James,

I apologise for the delay.

I’ve spoken with one of our senior engineers who has advised me they are unable to intervene with an inspectors decision. However, if you feel that you have been failed incorrectly then you are able to follow the complaints process, which is investigated by our Transport Officers.

It is always encourage that complaints are firstly directed to the inspecting organisation in the first instance. To ensure all written complaints received are investigated, the inspecting organisation must maintain an effective complaint management process, which must meet the requirements outlined under complaints in the Vehicle Inspection Requirements Manual.

If you are not happy with their response to your initial complaint, then a formal complaint can be processed by completing theVehicle certification complaint form and forwarding it to the Vehicle Certification Unit, Head Office in Wellington. Or by return email and I can forward it to the appropriate person.

I apologise that I cannot be of more assistance to you.

Seeking clarification with NZTA

October 5, 2014

Hi Kirsty,

Thank you for the links.

On the https://vehicleinspection.nzta.govt.nz/virms/in-service-wof-and-cof/motorcycles/vision/glazing link you provided, I see a table under the Tables & Images tab, with stone chip descriptions and sizes. If I read this correctly, it indicates that a star chip in the ‘critical vision area’ is acceptable if it is less than 30mm diameter.

Is this your understanding?

Many thanks,

James Samuel

October 10th, 2014

Hello James

The damage specified in table 5-1-2 applies only to damage outside the Critical Vision Area (see points 6-8 in the “Reason for Rejection” tab at https://vehicleinspection.nzta.govt.nz/virms/in-service-wof-and-cof/motorcycles/vision/glazing).

Damage inside the CVA is only allowed to be scratching, surface pitting and small stone marks that don’t affect the driver’s vision – this would limit it to very, very small chips only (in the order of a couple of mm across). The damage specified in table 5-1-2 would certainly affect the driver’s vision if located within the CVA.

I trust this clarifies your question.

Regards,

Kirsty

October 21, 2014

Hi Kirsty,

Thank you for clarifying that the images in table 5-1-2 only apply to damage outside the CVA.

Since some damage is allowable inside the CVA (scratching, surface pitting and small stone marks that don’t affect the driver’s vision), can I assume there is some discretion involved when a WOF inspector looks at a windscreen? Or is there some similar table you can point me to, that is used as a guide when assessing chips within the CVA?

I am asking because the chip in question on my vehicle’s windscreen is not affecting either of the two driver’s vision. In fact it is only noticed when brought up in conversation – like that old mind trick of “don’t think of an elephant” 🙂

There is the issue of a $400 window replacement and throwing away an otherwise perfectly good windscreen. So I would like to get to the bottom of this and appreciate your continued help in clarifying this matter.

Kind regards,

James

NZTA response – with links

September 17th, 2014

Hello James,

Thank you for your email about windscreen damage.

The below link will take you to our Vehicle Inspection Requirement Manual which outlines the requirements of damage in the critical vision area and a link to our Vehicle windows, wipers and mirrors (Factsheet 39):

I do hope this is of assistance to you.

Regards,

Kirsty Whitaker / Customer Response Team
Customer Response Team – Customer Access

P 0800 108 809
E info@nzta.govt.nz / W nzta.govt.nz
Palmerston North Office
Private Bag 11777, Palmerston North 4442, New Zealand

NZTA Letter one

Email sent September 13, 2014

Windscreen stone chips

Stone chips on vehicle windscreens could potentially be dangerous – depending on their size and location. Imagine for example, having something like this in the centre of your field of vision.

NOT a picture of a chip on my car’s windscreen

Unlike this one, the chip on my windscreen is very small and hard to see, so I visited the NZTA website to find the details of the rulings. Here’s what I’ve found so far:

Land Transport Rule

Glazing, Windscreen Wipe and Wash, and Mirrors 1999

2.2(1) (d) a windscreen must not have scratches or other defects that unreasonably impair vision through the glazing or compromise the strength of the glazing.

The only time you see the chip on my windscreen is when searching for it, and focussing up close on the glass (not something you do when driving). It does not unreasonably impair vision and while not an engineer, I can’t imagine that it compromises the strength of the glazing either.

Light Vehicle Repair Certification

3-1 Windscreen

Figure 3-1-3. Types and maximum sizes of windscreen damage

It seems that I have what is called a “Star” chip on my windscreen. In my case this is a shallow chip with equally shallow ‘arms’ of the star, that measure 20mm across at their widest point.

If I understand this correctly, this chip falls well within the stated acceptable limits.

The next step is to write to the NZTA to see if they can point me to any other pages, in case I have misread or misinterpreted their ruling.

Why this website

At the last WOF check for our Mazda (September 2014), a number of maintenance actions were identified as needing attention, in order to keep our car safe on the road.

All maintenance was completed, except one. It was suggested by our local WOF inspection garage, that the windscreen needed to be replaced because of a small stone chip.

My research seems to indicate that the chip falls within acceptable limits, so I’m seeking clarification from the NZTA, while also inviting the garage to reconsider their assessment of the chip.

Meanwhile I’ve affixed this note to my windscreen.

Windscreens

A conversation with NZTA