MOT testers on this forum... opinions on this issue would be much appreciated (steering lock)

[charlysays]

So I had a W202 Mercedes in for a repair the other week.
Specifically the EIS (electronic ignition barrel/ switch) was causing the car not to start and stall once started (failing microswitch in the tumbler).
I tried all sorts to fix it- tried dismantling the EIS to get to the microswitch (couldn't but have since found a video on youtube showing how to get the PCBs apart), tried soldering the ICs from the bad one into a good one but that didn't work either (one had a slightly different chip number so no play).
In the end I fitted an Immo emulator in the ECU and did the required programming changes on the ECU immo chip, fitted an ESL emulator (electronic steering lock emulator) and fitted a used barrel with two keys from another car.

Car is now fully functional but has no steering lock- the ESL has been disconnected in the open position and an emulator plugged in in its place.

My MOT tester does like to thoroughly test steering locks and nearly failed my own Merc because the steering wheel can sometimes, with force, jump the steering lock in one direction. Personally I think that this still results in immobilisation- you can't drive a car where you can only turn the steering wheel one way (with force) plus it has other forms of immobilisation as detailed below.

I found this on the MOT testing training centre

https://mtta.org.uk/wp-content/uploads/2020/08/7.-Other-equipment-MOT-inspection-manual_-cars-and-passenger-vehicles-Guidance-GOV.UK_.pdf

It says that it's acceptable to have no steering lock provided there are other means of immobilisation.

In the case of this Merc, it has an infrared key. Only that key and the spare will allow the car to move, let alone start.
If the key isn't accepted by the EIS, you can't turn the key. If you can't turn the key you can't even get the transmission out of Park, let alone start the engine.
So it appears the car still has a permanently installed immobiliser acting on both the engine and the transmission.

What's the best way to approach this? I don't want to show up to an MOT with this document and put him on the spot. Maybe calling in informally to chat about it long before the MOT would be the best route?

 

[waddycall]

Im not an MOT tester. If it was me id just put in for the test and if he fails it on it tell him you did your homework on it and thought it would be ok. Point him in the direction of the guidance.

 

[hotponyshoes]

If the mot tester you use likes to "thoroughly test" steering locks just take it to a different mot tester.
I've never had one checked in any of the tests I've had done.
I've had a couple of cars with no steering lock plus been presenting a kit car for 15+ yrs that has no obvious immobiliser, not even a key as it's just a push button start.

 

[tigdlo]

That link shows a document from 2020, always refer to the manual here, https://www.gov.uk/guidance/mot-ins...ivate-passenger-and-light-commercial-vehicles In this instance it is the same, but things do change.

It’s acceptable for a steering lock to be missing or not working as long as the vehicle has an engine immobiliser, or a permanently installed immobilisation device which acts on either the steering, brakes or the transmission.

The above is from the manual, if I understand your post then you still have an engine immobiliser so there is no need for the steering lock to work or any other kind of immobilisation device, further to that if the car needs to be placed in park to remove the key and can't be taken out of park without the key then there would also be no requirement for an engine immobiliser as that would satisfy a permanently installed immobilisation device which acts on the transmission.

I haven't tested for 6 years but interpreting the manual hasn't changed although this instance it is very clear. I'm very certain that an MOT tester should not be applying any amount of force to attempt overcome a steering lock.

 

[charlysays]

That link shows a document from 2020, always refer to the manual here, https://www.gov.uk/guidance/mot-ins...ivate-passenger-and-light-commercial-vehicles In this instance it is the same, but things do change.


The above is from the manual, if I understand your post then you still have an engine immobiliser so there is no need for the steering lock to work or any other kind of immobilisation device, further to that if the car needs to be placed in park to remove the key and can't be taken out of park without the key then there would also be no requirement for an engine immobiliser as that would satisfy a permanently installed immobilisation device which acts on the transmission.

I haven't tested for 6 years but interpreting the manual hasn't changed although this instance it is very clear. I'm very certain that an MOT tester should not be applying any amount of force to attempt overcome a steering lock.

Nice one, I hadn't found that .gov manual Will print it out and have a chat with him well before the MOT.
Yeah I was a bit concerned about the wrestling with the steering lock, mental images of metal getting chewed up inside the steering column, I mean I guess it was a real life test to see if it was working as a thief would do- the lock wasn't overcome turning to the right but was jumping to the left which would ultimately result in the front wheels being locked in the fully left position.

 

[tigdlo]

What's the best way to approach this? I don't want to show up to an MOT with this document and put him on the spot. Maybe calling in informally to chat about it long before the MOT would be the best route?

I forgot to answer this bit, I wouldn't approach it at all, give them the benefit of the doubt and only raise the issue if it fails.

 

[Keithmac]

In over 20 years of having cars tested I've never seen anyone force the steering wheel with the lock on, I would have thought that is beyond his remit.

At the end of the day if he broke it using excessive force I would assume he would have to pay for the repair.

I wouldn't be going back if someone did that to any of my cars..

 

[The_Yellow_Ardvark]

If it is fitted it should work.

The van can be immobilized by locking the doors.

 

[charlysays]

If it is fitted it should work.

The van can be immobilized by locking the doors.

In an ideal world where digital electronics age gracefully and reliably yes.
This is from the .gov website above though:

"Q. If the steering lock is not working or removed, is the immobiliser in the key acceptable as a device?

A. The inspection of steering locks only applies to certain vehicles first used from 1 September 2001, and all vehicles first used from this date will also have been fitted with an engine immobiliser from new as a Type Approval requirement (except maybe some imports). Therefore, a vehicle should only fail for a steering lock missing if it is clear that the immobiliser isn't working. Otherwise, the vehicle can be passed and customer advised

This is important as on some vehicles it may not be readily possible to determine or prove that the immobiliser is working."

So based on age alone (car is late 90s) the steering lock doesn't need to be tested. And if it is checked and found to not be working the car is still immobilised by the (very difficult to hack- believe me I tried) infrared bladeless key which acts on the doors, transmission and engine- so at least two forms of decent immobilisation still exist without the steering lock.

 

[premmington]

Pass and advise...

If you even notice the steering lock does not work!

 

[qwakers]

(a) Steering lock missing or not functioning

Minor

so not a fail anyway.

A minor defect on your MOT certificate means that the fault found is not severe enough to fail the test, but should be repaired as soon as possible. Minor defects can't cause an MOT failure, no matter how many are found.