OK shall we consider this from the beginning? This is how I understand the rules. Its long winded and not intended as a criticism of anyone, I also have no allegiance to any supplier, but it might help put it all in perspective.
In the EU all road vehicles when new are required to conform to some form of type approval. This is to ensure a uniform standard of safety and other conformities. In mass produced vehicles all the tests are done for us by the manufacturer. If you build your own car or bring one in from outside the EU you have to submit it for SVA or now IVA (individual vehicle approval) to ensure it complies.
So are we allowed to modify them afterwards? Well in the UK within reason then generally yes, as long as they still comply with the Con & Use, Vehicle lighting regs, MOT etc. it will normally be OK. Unless the vehicle is radically altered it will not need to be submitted for further type approval testing.
Elsewhere in the EU I believe they are much stricter and modifications are prohibited completely. In Germany and Austria all modified parts must have TUV approval, which is an independent test that ensures the parts are of a quality standard equivalent to type approval. This is why it is often good to buy parts intended for the German market because they have been tested.
For steering type approval requirements, a T3/T25 van of this age falls under the EC directive 74/297/EEC. (you can read it here if you are bored
http://eur-lex.europa.eu/LexUriServ/Lex ... 297:en:NOT" onclick="window.open(this.href);return false;)
But briefly the steering must meet the following criteria
When the unladen car without a dummy is collision-tested against a barrier at a speed of 48.3 km/h, the top of the steering column and its shaft shall not move backwards, horizontally and parallel to the longitudinal axis of the vehicle, by more than 12.7 cm in relation to a point of the vehicle not affected by the impact, the distance being determined by dynamic measurement
When the steering control is struck by a body block released against this control at a relative speed of at least 24.1 km/h ; the force exerted on the "chest" of the body block by the steering control shall not exceed 1 111 daN. 5.2.1. The steering control shall be so designed, constructed and fitted as not to comprise either any dangerous roughness or sharp edges likely to increase the danger or severity of injuries to the driver in the event of impact
The steering control shall be so designed, constructed and fitted as not to embody components or accessories, including the horn control and assembly accessories, capable of catching in the driver's clothing or jewellery in normal driving movements
So say for example you wanted to modify your steering but keep within the rules. A good place to start would perhaps be to keep it in line with the original type approval. If you keep the standard wheel and switches then the bottom 2 paragraphs aren’t a problem. The top paragraph is the one to consider because it relates to the collapsible element of the column.
Personally if I were to buy an after market column I wouldn’t expect a full destructive test of a vehicle to have been completed, because that is unrealistic. But I would expect some effort had been made to retain or improve on the original safety features and I would want to assess this for myself or have proof that someone else had. If you present a kit car for type approval they check the steering system by judgement and experience to assess if it meets the criteria. Usually the correct use of recognised OE parts such as collapsible boss and column will be sufficient.
So what if you don’t care about keeping to the original type approval? Leaving aside insurance and product liability issues, you might want to consider that if it doesn’t reach the standard that was required when the vehicle was new then could it breach the following?
Con + Use regulation 29
All steering gear fitted to a motor vehicle shall at all times while the vehicle is used on a road be maintained in good and efficient working order and be properly adjusted
S.40 Road Traffic Act - Using a vehicle in a dangerous condition
A person is guilty of an offence if he uses, causes or permits the use of a motor vehicle when the condition of the vehicle or its parts and accessories or equipment is such that the use of the motor vehicle involves a danger of injury to any person.
I am not against modifying vehicles, but it shouldn't be at the expense of safety. I have built/driven numerous kit cars and drive an modified old van. None of which in the event of collision are going to protect me in the same way as my wife’s horrible Scenic would, but all would offer more protection than any older van such as a Bay for example (and they haven’t been banned yet). But as many others here have mentioned safety is relative. I choose to drive them anyway accepting the risk, to gain the enjoyment. I would have no qualms about using the ‘right’ EPAS system, if it improved the ease of driving an old van without making it any more dangerous.