There is nothing wrong with the Motor Vehicle Inspection System or the MVIS. Technically and legally, or MVIS that is now being implemented by the Land Transportation Office has the needed legal and technical basis for it to be made mandatory for all motor vehicle registrations. And yet, a month after its awaited implementation, all sorts of complaints and opposition coming from various sectors have unified into one voice that has reached the chambers of Congress, begging for its suspension, if not a review. What gives?
From an existentialist point of view, motor vehicle use leads to wear and tear that cannot be taken lightly. More than 10,000 Filipinos die every year because of road accidents due to unroadworthy vehicles. Respiratory illnesses due to the carbon emissions from motor vehicles is the 3rd leading cause of deaths in the country. We are not even talking about our right as citizens to be provided efficiently clean and safe public transport. Hence, the need to require the periodic technical and unbiased inspection; and better with the least human intervention—that is the MVIS. This 70-point inspection, with minimal human intervention, covers all aspects of vehicle roadworthiness to include, smoke emission, brakes and suspension, light luminescence and even engine noise decibel level—a relief when you think of the noisy mufflers that we have come to accept as normal. On a legal note, the process stands on solid ground with several department and agency directives based on national legislation covering several presidential administrations.
Why then the noise of dissent? There are many concerns being raised, from exorbitant fees, strict standards, consistency of tests, choice of operators and issues relative only to specific motor types such as motorcycles and trucks. And these can all be summed up and grouped as follows: 1) Integrity questions on the MVIS to include the standards being adapted, and the selection process of operators; the questions on the 2 ) MVIS inspection process itself to include how it is conducted, the passing/ failure rates, and the inspection fees; and 3) Why now when there is a pandemic and when there are other more pressing concerns to be attended to?
We also need to look at where the noise is coming from. From an initial impression, it would seem that the noise is all over. Dissecting it further, the source of dissent comes from: 1) The motoring community, correctly wary of new procedures and fees; 2) and those who are affected commercially to include displaced businesses such as the emission centers whose services are already incorporated in the MVIS process. The rest of the noise are those reacting to it, primarily our legislators and local government officials, who are only after the best interests of their constituents, with some very much aware of the backlash come election time. And lurking in the grey area are the questions on connivance and corruption, as well as the purported lack of public consultation.
From this point of inference, it would seem that the problem, grave as it looks like, can be and should solvable. Some of the complaints raised can be resolved by mere clarification. Others will need minor policy adjustments. Still some are sector specific interests that need to be addressed. Motorists need to be convinced of its necessity, made confident of the results and agree on the fees. Displaced businesses casting doubt on the integrity of the one taking over their revenue streams will have to be convinced on the processes applied.
And maybe the only way to proceed and resolve all these concerns is a genuine engagement of those in government involved in the program with these sectors that want their questions to be answered. This is their primordial responsibility as public officials, especially for a game changing program such as the MVIS: To explain, listen, and if need be, adjust exhaustively. Transparency and clarity must be accepted as continuing tasks in government. There can never be enough of these. But that should not be a problem for a good program such as the MVIS. Unless there are gray areas that need to be cleared and corresponding adjustments made, there should be no reason in the efforts to move this forward.
Thomas “Tim” Orbos is currently a transport policy advisor for an international organization and worked in government on transport and urban development matters. He is an alumnus of Georgetown University and the MIT Sloan School of Management. He can be reached via e-mail—tmo45@georgetown.edu /thomas_orbos@sloan.mit.edu
5 comments
Additionally, why focus first on privately owned vehicles when they should more concerned and strict in public utility and for hire vehicles?
LTO apparent public perception is poor. I am of the view that LTO seemingly does not care whether the fees imposed, or penalties formulated by LTO consider compassion to the poor way of living of the Filipinos.
One senator puts it simply “arrogance”
Of the 10,000 deaths you mentioned, how many were directly caused by privately owned vehicles with wear and tear problems covered by the 70 point inspection. How many were caused by PUVs and trucks? Please check these stats first. What is the most common reason for accidents?
Lack of Discipline as well as lack of respect for others cant be adressed by this law.A country full of corruption,fr the ordinary rraffic enforcer to the powers that be,shows that most of our laws have good intention but sadly,so much room for corruption.
Old,substandard vehicles belching smoke in the highway,tricycles and motorcycles running without lights at nights,jeepneys with only one light on or even no lights at night.Tricycle drivers getting drivers licenses who doesnt even know how to read and driving with impunity and attitude on the road.Or doesnt even know about traffic laws and rules.Consider a lady who went after an ambulance driver because she felt he was blocking her,all these while he was bringing a patiemt to the hospital.Motorist racing with each other or running on the wrong side of the road,counterflowing because its traffic.Drunk driving.Gun toting ones even,drivers under the influence of alcohol or drugs.Police and enforcer being high and mighty and jst looking to get hand outs.While there is a law on clear windshield and anti distraction,laws where in drivers have to wear both face shield and masks,talk about anti distraction plus poor oxygenation..So many laws,so many burden..Well meaning Analyst who dont get exposed everyday travel in our Philippine setting should probably spend time commuting and travelling on the road to see and feel the pulse of the people.And all the possible reason for these motor vehicle accidents.
Mr. Orbos, you probably drank too much of the DoTr-LTO Kool Aid. The MVIS has the needed technical basis for it to be made mandatory, you say? If you honestly believe that, I suggest you start having a serious look at the things you don’t know you don’t know. For starters, consider the following serious technical and factual flaws of the LTO-issued implementing rules and regulations:
ABSENCE OF REFERENCE STANDARDS
1. No any specification of technical reference or standard for each any test method or testing machine; for any testing or measurement facility to be credible it must have verifiable technical reference standards for any and all test methods to assure customers of their validity.
2. No specific quality standards for the test equipment or their calibration. Nor were there any specification for traceability nor any quality system requirements for the DoTr-LTO project management Office which is supposed to accredit calibration service companies.
3. No requirement for indoor air quality nor occupational safety standards. No CO level monitoring at the inspection pit. No requirements for emergency preparedness such as for runaway vehicles, fires, or CO poisoning.
QUESTIONABLE INSPECTION GUIDELINES OR PROCEDURES
4. No specified pre-checks for proper seating or alignment of wheels with the rollers of the RBT machine before conducting RBT test. (Sec 5.4.2.21 p15 )
5. No requirements for inspection of brake pads, caliper, or brake fluid leaks. (Sec 5.4.2.21 p15)
6. No requirement for inspection of seatbelts for wear or damage (Sec 5.4.2.2 p9)
7. No inspection for windshield cracks and other damage nor prohibition against large stickers usually seen on PUJ or “owner” jeep windshields (Sec 5.4.2.12 p12)
8. No requirement for inspection of substandard electrical wiring connections, which are a common cause of vehicle fires. (Sec 5.4.2.31 p19)
9. Overly strict speedometer test. In Europe, particularly in the UK, speedometers are tested only for presence, lighting, and visibility. Only an obvious non-functional speedometer a basis for failing this test.
10. No transparent, verifiable reasons for failing grade/s in MVI Report.
POOR UNDERSTANDING OF PHYSICS
11. LTO guidelines show poor understanding of the basic of force and light:
• roller brake testing – equating brake force (unit of measure: kg, N, or kN) with brake efficiency (unit of measure: per cent)
• headlight testing – equating luminous intensity the amount of light emitted by a lighting device in a particular direction (unit of measure: candela) with luminous flux the total amount of light emitted by a light bulb (unit of measure: lumen). Sec 5.4.3.6 p27
SENSELESS, ARBITRARY PROVISIONS
12. Deviation from known inspection parameters or specifications, say in Europe or U.S., for the following items:
• headlight – luminous flux: 126,000 lumens or more vs. common HID lamps @3000 lumens. (Sec 5.4.3.6.1 and 5.4.3.6.3 p27)
• headlight – for the third year of implementation luminous flux requirement inexplicably drops to 800 lumens or more (Sec 5.4.3.6.4 p27)
• tires – 5 years vs 10 years per tire manufacturers and other testing organizations.
• fuel tanks – specified steel when >80% of the global marker had converted to plastic tanks. (Sec 5.4.2.28.2 p17)
VAGUE AND/OR SUBJECTIVE PROVISIONS
13. Headlight test standard is unclear whether the numbers given are per lamp, per side, or total output (Sec 5.4.3.6 p27-28)
14. Employs vague and subjective quasi-technical terms such as easy maintenance, major corrosion (Sec 5.4.2.1.2.1 p8), regular steel , excessively loose , or unsafe modification without defining or explaining exactly what those terms mean. (Sec 5.4.2.28.2 p17)
POOR TECHNICAL SPECIFICATIONS FOR MV TEST EQUIPMENT
15. Provide no power quality requirements that may attenuate or minimize voltage fluctuations, variations, spikes, or imbalance that may affect accuracy or operation of test equipment.
16. No specification for 60Hz roller brake tester (RBT) motors. Most motors made in Europe and UK, unless explicitly specified otherwise, are 50Hz, whereas Philippine power supply is 60 Hz.
17. No reliability requirements (e.g., MTBF) on the equipment to be used.
18. No requirements designed to limit possible sources of uncontrolled variability (i.e., errors) in measurement, including inter-site conditions, inter-equipment characteristics, environmental conditions, vehicle-to-vehicle differences for a given model, brake system changes with age, test driver differences, roller surface wear and tear, test surface friction differences between test sites, etc.
19. No common Operating System or web browser specifications for various test equipment. Sec 7 p30
20. No specifications for interconnectivity and cybersecurity. Sec 7 p30
UNREALISTIC OR SENSELESS TASK ASSIGNMENTS
21. Specifies inspection tasks that are far beyond the abilities of a TESDA Automotive Servicing NC2 technician under stated visual inspection conditions:
• welding defects inspection (Sec 5.4.2.25.1 p15),
• chassis frame integrity assessment (Sec 5.4.2.1.2.1 p8),
• detection of exhaust fumes inside the vehicle (Sec 5.4.2.1.2.4 p8),
• visual inspection of bearings (Sec 5.4.2.36 p20), etc.
LOOSE OR QUESTIONABLE TRAINING REQUIREMENTS
22. TESDA AS NC2 curriculum includes no topics relating to operation of MVIS equipment. Nor does it include any requirements for pre-employment qualification testing, or regular re-qualification.
23. No requirements for PMVIC administrative or managerial training or qualifications.
24. No requirements for test equipment manufacturers to submit English user manuals.
POORLY-CONCEIVED PROGRAM DESIGN
25. No definition of “roadworthy”. Real problem to be solved by PMVIC implementation undefined. PMVIC is a solution seeking a problem.
26. PMVIC design specs specifically tailored for light vehicles when vehicles involved in multi-fatality crashes are mostly buses and trailer trucks.
27. Provides no rational grading system that accounts for relative importance of car components to roadworthiness. For example, under the given IRR an interior light or the speedometer is given equal importance as the brakes.
28. Assigns the task of judgment, usually reserved for credible, well-trained and experienced individuals, to novice technicians fresh-out of the classroom. (Sec 5.4.2 p7)
29. Provides no clear procedure for immediate receipt or resolution of customer complaints. (Sec 10.1 p31)
30. No statement of liability on the part of the PMVIC for direct or indirect damage to a vehicle as a result of the inspection conducted by a PMVIC.
31. No blueprint towards standardization of spare parts of MVIS equipment for eventual transfer to government hands.
Lastly, out of the 73 items in the MVIS checklist, only 7 require test instruments. The rest comprise totally subjective visual inspections on the part of the raw TESDA graduate technicians. If you still remember your elementary mathematics, 66/73 means the inspection system you blindly tout is at least 90% human. And that presumes wrongly that only robots operate the test equipment.