Appendix 1 – Proposed technical requirements for self-containment
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Tier One: Objective
We propose an objective focusing on protecting the natural environment
Our performance-based technical requirements are set out in four tiers. The top tier is a high-level objective that all certified self-contained vehicles must satisfy.
We propose that the Freedom Camping Regulations technical requirements have the following objective:
“To protect the natural environment from contamination and pollution from wastewater and solid waste, by prescribing the minimum facilities needed to contain the waste which vehicle occupants produce and to provide fresh water which they require.”
Tier Two: Functional requirements
We propose seven functional requirements and a set of general technical requirements
The second tier of our performance-based technical requirements is the functional requirements that all certified self-contained vehicles must meet.
We propose that the Freedom Camping Regulations have seven functional requirements that all certified self-contained vehicles must meet. The vehicles must be able to meet these functional requirements for a minimum of three days. The seven functional requirements are:
- a water supply system which stores and conveys potable water to sanitary appliances for the purposes of safe food preparation and personal hygiene
- a fixed toilet to collect the human waste of a camping vehicle’s occupants
- a wastewater system of adequate capacity for the secure and safe collection and storage of grey water and black water
- a sink which is supplied with potable water, installed with a waste trap and which drains to a grey water tank
- ventilation systems to ensure unpleasant or unhealthy odours do not accumulate in a camping vehicle
- mechanisms for the safe loading of water and off-loading of wastewater which avoid spillage, leakage or cross-contamination
- sufficient secure storage of occupants’ rubbish.
We also propose that Regulations include the following set of general technical requirements for self-contained vehicles:
Fittings
A fitting or item of equipment to be used in a camping vehicle’s self-containment system must be constructed in a way and of appropriate materials which make it clearly fit for the purpose and use intended of it.
Pipes, fittings and tanks
Pipes and fittings, such as taps and valves, which reticulate water in a camping vehicle must be made of non-toxic materials suitable for contact with potable water.
Tanks for the storage of wastewater as well as associated pipes, pipe fittings and valves should be made of non-corrodible material.
Standards of installation
Fittings and equipment in a camping vehicle’s sanitary system shall be installed and secured according to good trade practice.
Tanks must be securely mounted and capped to avoid damage or leaks from volumes of water moving about when the camping vehicle is moving.
Water reticulation pipes shall be fitted so that they do not fail or leak at the system’s design pressure.
Appliances, fixtures, fittings, tanks and pipes used in a wastewater system must be made of non-toxic, non-corrodible, stable materials and shall be securely fixed, fastened or glued.
Water drainage pipes must be of sufficient diameter, without leaks and laid at grades which allows for the convenient egress of wastewater from sinks, basins and showers into a grey water tank.
Interpretation
‘Fit-for-purpose’ means that an element of a vehicle’s self-containment system has been designed for the purpose or function for which it is being used and has been installed or is used in a way which ensures that it remains functional at least for the certification period.
‘Good trade practice’ refers to a standard of work done in any installation of a self-containment system which is consistent with what would be expected from a qualified tradesperson.
Tier Three: Performance requirements
We propose a set of performance requirements for specific items in a self-contained vehicle
The third tier of our performance-based requirements is the qualitative or quantitative performance requirements all certified self-contained vehicles must meet.
We propose the Regulations include a set of performance requirements for specific items that are critical components of self-containment. These performance requirements are:
1. Water systems
1.1 Water intended for human consumption, food preparation, utensil washing, or oral hygiene must be potable.
1.2 A potable water supply system must be:
a. protected from contamination
b. installed in a manner that avoids the likelihood of contamination within the system and the water main
c. installed using components that will not contaminate the water
d. be able to breathe.
1.2 There must be sufficient capacity for storing potable water to meet the needs of the expected number of occupants of the vehicle for a minimum period of three days.
1.3 Tanks storing potable water shall be made of appropriate material and/or stored in such a way as to avoid contamination by sunlight.
1.4 Water supply systems must be installed in a manner that:
a. pipe water to sanitary fixtures and sanitary appliances at flow rates that are adequate for the correct functioning of those fixtures and appliances under normal conditions
b. avoids the likelihood of leakage
c. allows reasonable access to components likely to need maintenance.
1.5 Tanks must be adequately supported and secured to avoid creating any hazard while the motor vehicle is in motion.
2. Toilets
2.1 Toilets shall be manufactured by a reputable manufacturer and be fit-for-purpose for the expected number of occupants of the vehicle and the certified containment period (i.e., the three-day minimum).
2.2 Toilets shall be permanently fixed to the camping vehicle with the seat rigidly mounted in position and not required to be removed for the emptying of human waste.
2.3 Toilets shall drain or flush directly into a suitably designed and fitted cassette or black water tank.
3. Wastewater systems
3.1 A self-contained wastewater system must safely and reliably convey wastewater from sanitary fixtures and appliances to storage tanks or vessels and store this wastewater securely within the camping vehicle at least until it is emptied out.
3.2 Storage capacity shall be sufficient to store the wastewater produced by the expected number of occupants of the vehicle for a minimum period of three days.
3.3 Wastewater must be stored separately as grey water and black water.
3.4 Black water must either be stored in removable cassettes which fit the vehicle’s fixed toilet or in a fixed tank(s). If the latter, it must have a quick acting valve.
3.5 Grey water must be stored in fixed tanks or in portable tanks which are connected to the vehicle.
3.6 Water drainage pipes should be of sufficient diameter, without leaks and laid at grades which allows for the convenient egress of wastewater from sinks, basins and showers into a grey water tank.
4. Ventilation systems
4.1 The motor vehicle must be adequately ventilated to ensure unpleasant or unhealthy odours are not able to escape directly to the inside of the motor vehicle.
4.2 Venting pipes should be of sufficient diameters and installed in a way that ensures unpleasant odours or foul air can easily escape to the outside of the motor vehicle.
4.3 Wastewater storage tanks shall be ventilated to the outside of the vehicle to ensure that foul air and noxious gases do not accumulate in them.
4.4 Vent outlets for wastewater storage tanks shall be fixed at a height which will safely avoid wastewater leaking out.
4.5 Pipes connecting sanitary appliances and fixtures to wastewater storage tanks must be fitted with water traps to limit the passage of foul air and noxious gases from these tanks into the inside of the camping vehicle.
5. Loading and off-loading mechanisms
5.1 Pipes and hoses for loading water into water storage tanks shall either be completely separate from the tank or be fitted with mechanisms that prevent potential contamination of community water supplies through backflows from the tanks.
5.2 Pipes and hoses for discharging wastewater from a camping vehicle shall be of sufficient length, diameter, strength and durability for wastewater to be discharged cleanly, conveniently and safely into dump stations or other appropriate discharge points.
5.3 Pipes and hoses for discharging wastewater shall be appropriately stored to minimise any health risks associated with the residual contaminants left in them after use.
6. Occupant rubbish storage
6.1 Every self-contained camping vehicle shall have a sealable container of sufficient capacity to store the rubbish generated by the expected number of occupants of the vehicle for a minimum period of three days.
Some alternative performance-based technical requirements were proposed by members of the technical advisory group
Members of the technical advisory group generally are supportive of performance-based technical requirements. However, some of the group’s members have suggested alternatives to performance-based technical requirements outlined above. These options are:
Self-containment period – reduce the number of days a motor vehicle must be self-contained from three days (as is currently required in the Standard) to two days. This would better suit freedom campers who wish to camp for two nights over a weekend. It would also reduce the storage requirements and may allow for reduced water and waste storage tanks. It is understood that the average size of a cassette is 17–18L. Therefore, this alternative option would enable most vehicles with cassette toilets to meet self-containment requirements with one cassette rather than having to carry a spare cassette.
However, reducing the period to two days could result in difficulties in discharging waste due to the distance between some dump stations.
Separate toilet compartments – in addition to the requirement that toilets be fixed, it was suggested that all toilets be located inside a separate toilet compartment on the basis that this would increase the likelihood the toilet would be used. This requirement for would be difficult for smaller camping vehicles due to limits on floor space.
Sufficient capacity for occupant solid waste storage (e.g., rubbish, food scraps etc.) – It was suggested that the technical requirements for solid waste storage be removed. This is on the basis that solid waste storage should not continue to be a critical facility, noting that there are many more waste bins that freedom campers can use for solid waste than there are dump stations. This change would mean that self-contained vehicles would not need to have a sealed rubbish bin on board.
Consideration of the alternative performance-based technical requirements proposed by members of the technical advisory group
We do not have sufficient information on the costs, benefits and potential impacts of each of these alternative options to be able to assess whether any should be considered for adoption. Your feedback on any of these is welcome.
For example:
- Are there other relevant pros and cons for reducing the minimum containment period from three days to two days?
- How much floor space would be required to install a separate toilet compartment?
- What would the installation cost be?
- How critical is a solid waste container in ensuring a motor vehicle is sufficiently self-contained?