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www.dft.gov.uk/vca1
2007/46 EC Article 6 Procedures for EC Whole Vehicle Type
Approval
Mike Protheroe
25 April 2012
www.dft.gov.uk/vca2
Outline
• Type Approval Information– various terms and what they mean– how information is put together
• Type Approval Processes– step by step– single step– mixed approval– multi stage approval
www.dft.gov.uk/vca3
Type Approval Information
www.dft.gov.uk/vca4
Descriptions of Type Approval Information
See Article 3 (paragraphs 37 – 40) for definitions;
• it is permissible to supply information in an electronic file
• VCA prefers to receive it this way!
Information document• the document set out in Annex I or Annex III, or
in the corresponding Annex to a separate directive, or regulation, that prescribes the information to be supplied by an applicant
www.dft.gov.uk/vca5
Descriptions of Type Approval Information
Annex I • Complete Information Document used in Single
Step process– just the headings which form the template run to
about 70 pages of A4!
Annex III• Partial Information Document used in Step by Step
process – the headings in the template are about 7 pages of A4
www.dft.gov.uk/vca6
Descriptions of Type Approval Information
Information folder• is supplied by the applicant • the complete folder of information about the type of
vehicle– includes the information document, data, drawings,
photo’s, etc.
Information package • a compilation of;
– the information folder (supplied by the applicant)– test reports, type approval certificates (& other docs)
added by a technical service or approval authority
Type Approval
www.dft.gov.uk/vca7
Descriptions of Type Approval Information
Index to the information package• the document listing the contents of the
information package, it needs to;– be suitably numbered (or identified) so as to
identify clearly all the pages / items– present a record of the successive steps in
the management of the EC type approval• in particular the dates of the revisions and updating
www.dft.gov.uk/vca8
Compiling Information
Information Document
Index
Information Package
Info Doc
Info Doc
Certificate(s) & Test Report(s)
Photographs & Drawings
Type Approval
TemplateTemplate
Information Folder
www.dft.gov.uk/vca9
Type Approval Procedures (Article 6)
The manufacturer may choose one of the following procedures:
(a) step by step type approval
(b) single step type approval
(c) mixed type approval
www.dft.gov.uk/vca10
Descriptions of the Processes
See Article 3 (paragraphs 7 – 10) for definitions;Step by step type approval• a procedure where there is an incremental
collection of the complete set of EC type approval certificates for the systems, components and separate technical units relating to the vehicle, and which leads, at the final stage, to the approval of the whole vehicle
Single step type approval• a procedure whereby a vehicle is approved as a
whole by means of one operation
www.dft.gov.uk/vca11
Descriptions of the Processes
Mixed type approval• a step by step type approval procedure where one
or more system approvals are achieved during the final stage of the approval of the whole vehicle, without it being necessary to issue the EC type approval certificates for those systems
Multi-stage type approval• a procedure whereby one or more Member States
certify that, depending on the state of completion, an incomplete or completed type of vehicle satisfies the relevant administrative provisions and technical requirements
www.dft.gov.uk/vca12
Step by Step Type Approval
• Traditionally this has been the route chosen by most
• Equally well suited to both single stage and multi stage type approval
• Each System, Component or Separate Technical Unit (STU) has its own discrete type approval package– is comparatively easy to manage– “pigeon hole” approach
www.dft.gov.uk/vca13
Step by Step Type Approval
Some Pros • A systematic approach well suited to
project management techniques– Each approval can be treated as a ‘work
package’
• Makes approvals easily ‘transportable’– A system approval for spray suppression
can easily be used on many different whole vehicle types
www.dft.gov.uk/vca14
Step by Step Type Approval
Some Cons• Is comparatively more expensive than
Single Step as each approval generally has fees for at least a certificate and admin. – There may also be fees for testing and / or
technical review time
• Each time there is an extension to a lower level approval (e.g. system approvals – such as spray suppression) the whole vehicle approval must be extended
www.dft.gov.uk/vca15
Single Step Type Approval
• Some use has been made of this in the past– no where near as common as the step by
step process
• Multi stage approvals may make this more common as there is often not much for the final stage to do so it is more manageable
www.dft.gov.uk/vca16
Single Step Type Approval
Some Pros • Is comparatively less expensive than Step
by Step as there is only one approval– however, as well as a single certificate fee
and an admin fee there are also fees for testing / inspection and / or technical review time
www.dft.gov.uk/vca17
Single Step Type Approval
Some Cons• The type approval documentation is very
large / ‘heavy’ – may run to several hundred pages
• It may be harder to manage the overall project – everything has to be made ready at once– there may be difficulty controlling versions
www.dft.gov.uk/vca18
Single Step Type Approval
Some Cons• Information is not very ‘portable’
– All approval information is ‘embedded’ in the Whole Vehicle Type Approval
• e.g. about the spray suppression system data would need to be extracted and recreated in parallel if it is to be used on many different whole vehicle types
www.dft.gov.uk/vca19
Mixed Type Approval
• This is all about choice and flexibility– the applicant chooses which method suits
best, based on• any particular type of vehicle (or order) • method of operating manufacturing
• A manufacturer in a multi stage approval can always opt for the mixed process
www.dft.gov.uk/vca20
Mixed Type Approval
• As the name suggests a mixture of both step by step and single step are used
• Almost any combination is allowed– Examples
Base Vehicle
Stages Mixed
Y / N
Steps Steps N
Steps Single Y
Steps Mixed Y
Single Single N
Single Steps Y
Single Mixed Y
Mixed Steps Y
Mixed … Y
www.dft.gov.uk/vca21
Mixed Type Approval
• The principal benefit of using the mixed approval process is that the Annex III information document (the light one) is used and augmented with information extracted from Annex I for the subjects where there are no separate approvals– gives the best of both worlds
www.dft.gov.uk/vca22
Worked example of ECWVTA
Mike Protheroe
25 April 2012
www.dft.gov.uk/vca23
Outline
Walkthrough of the Step by Step process– using a trailer as an example
• What’s needed?– a look at the type approval requirements
• How to go about it– getting a system approval– putting together the information folder– types, variants and versions
www.dft.gov.uk/vca24
Overall Picture
Type = 1 Axle Type = 2 Axle
3. Rear Protection
4. Rear number plate
5. Steering Effort
9. Braking Type = 1 Axle
...
43. Spray Suppression
...
3. Rear Protection
4. Rear number plate
5. Steering Effort
9. Braking Type = 2 Axle
...
43. Spray Suppression
...
Type = 3 Axle
3. Rear Protection
4. Rear number plate
5. Steering Effort
9. Braking Type = 3 Axle
...
43. Spray Suppression
...
Common system approvals for types 1 Axle, 2 Axle and
3 Axle
Whole Vehicle Type Approvals (Framework Directive)
Sys
tem
Typ
e A
ppr
oval
s (‘D
aug
hter
’ dire
ctiv
es /
regu
latio
ns)
www.dft.gov.uk/vca25
Getting Systems Approvals
1. Understand the legislation
2. Build the product in compliance
3. Ensure Conformity of Production (CoP) systems in place
4. Prepare Information folder
5. Submit for type approval testing
6. Receive Type Approval certificate
7. Continue to build in compliance
www.dft.gov.uk/vca26
Legislation
Sources• Legislation is available
– free of charge (help yourself online)– on a subscription basis (pay someone to
find it and keep track of it for you)
• VCA has subscription based systems which can help
• There are also other providers
www.dft.gov.uk/vca27
Building Products in Compliance
• OK - you’ve got access to legislation– READ IT – UNDERSTAND THE REQUIREMENTS– If in doubt ask!
• Build your product to meet the requirements
• Ensure adequate quality management systems are in place to ensure CoP
www.dft.gov.uk/vca28
Information Folder
• Most of the directives or regulations will have a template for an information document
• Information documents follow a basic and recognisable format and contain information about;– You (the manufacturer)– Your products (the type of vehicle or
system)
www.dft.gov.uk/vca29
2010/19/EU enforced on 9 April 2011
Requirements
Mudguard
Valances
Rain Flaps
Air/Water Separator (matting)
System Approval Example Spray Suppression
www.dft.gov.uk/vca30
System Approval Example Spray Suppression
• Spray suppression has a wide definition “type”
From Annex I of 91/226/EEC as amended;15. Type of vehicle
“Type of vehicle” means, in relation to spray suppression complete, incomplete or completed vehicles, which do not differ with respect to the following aspects:— type of spray suppression device (installed on the
vehicle),— manufacturer’s spray suppression system type
designation.
One system approval can cover a range of vehicles
www.dft.gov.uk/vca31
System Approval Example Spray Suppression
Some requirements extracted from directive 91/226/EEC as amended;
1.0 Category N and O vehicles, … shall be constructed and/or fitted with spray suppression systems …
…7.3.5. In the case of multiple axles where distance
‘d’ between the tyres on adjacent axles is less than 250 mm, only the rear set of wheels must be fitted with rain flaps. There must be a rain flap behind each wheel when distance ‘d’ between the tyres on adjacent axles is at least 250 mm (Figure 4 of Annex V).
www.dft.gov.uk/vca32
System Approval Example Spray Suppression
Figure 4 - Diagram showing assembly of a spray-suppression system
(mudguard, rain flap, outer valance) incorporating spray-suppression devices (energy absorbers)
www.dft.gov.uk/vca33
Spray Suppression Information Document
Information document no … relating to EC type-approval of a vehicle with respect to the fitting of spray-suppression systems (directive 91/226/EEC, as last amended by directive 2010/19/EU) (*)
0. GENERAL
0.1. Make (trade name of manufacturer):
Paragon
0.2. Type:
X Axle (X = 1, 2 or 3)
0.2.1. Commercial name(s) (if available):
Paragon Transporter or ParaTran
www.dft.gov.uk/vca34
Spray Suppression Information Document
0.3. Means of identification of type, if marked on the vehicle (b)
Not applicable0.3.1. Location of that marking:
Not applicable0.4. Category of vehicle (c):
N1, N2, N3, O3, O40.5. Name and address of manufacturer:
Paragon Ltd, [HQ Address]0.8. Address(es) of assembly plant(s):
1) Paragon Ltd, [Plant Address]2) Para Build Ltd, [Plant Address]
www.dft.gov.uk/vca35
Spray Suppression Information Document
1. GENERAL CONSTRUCTION CHARACTERISTICS OF THE VEHICLE
1.1. Photographs and/or drawings of a representative vehicle:
See attachment 11.3. Number of axles and wheels:
1 axle, 2 wheels OR 2 axles, 4 wheels OR 3 axles, 6 wheels
1.3.1. Number and position of axles with twin wheels:
None1.3.2. Number and position of steered axles
None
www.dft.gov.uk/vca36
Spray Suppression Information Document
2. MASSES AND DIMENSIONS (f) (g)(in kg and mm) (Refer to drawing where applicable)
2.1. Wheelbase(s) (fully loaded) (g) (l):See attachment 1
2.6.Mass in running order (maximum and minimum for each variant)Mass of the vehicle with bodywork and, … in running order, or mass of the chassis or chassis with cab, without bodywork and/or coupling device if the manufacturer does not fit the bodywork and/or coupling device (including liquids, tools, spare wheel, if fitted, and driver … (h) (maximum and minimum for each variant):
See attachment 1
www.dft.gov.uk/vca37
Spray Suppression Information Document
2.6.1.Distribution of this mass among the axles and, in the case of a semi-trailer or centre-axle trailer, load on the coupling point (maximum and minimum for each variant):
See attachment 1
2.8.Technically permissible maximum laden mass stated by the manufacturer (i) (3):
See attachment 1
www.dft.gov.uk/vca38
9. BODYWORK9.20. Spray-suppression system9.20.0. Presence: yes / no / incomplete (1)9.20.1. Brief description of the vehicle with regard to its
spray-suppression system and the constituent components:Mudwing with incorporated valance and mudflaps behind rear wheels
9.20.2. Detailed drawings of the spray-suppression system and its position on the vehicle showing the dimensions specified in the Figures in Annex V to Directive 91/226/EEC and taking account of the extremes of tyre/wheel combinations:See Attachment 2
9.20.3. Approval number(s) of spray-suppression device(s), if available: Not applicable
Spray Suppression Information Document
XXXXXXXX
www.dft.gov.uk/vca39
Spray Suppression Information Document
Attachment 1 (General Information)• Here you would include the relevant information
referred to earlier• It is free form, you can use the most appropriate
method to convey your information; e.g. – photographs, drawings– lists, tables, etc.
• Include the headings again (or at least the heading number)1.1. Photographs and/or drawings of a representative vehicle:
www.dft.gov.uk/vca40
Spray Suppression Information Document
Attachment 2 (Specific Information)• Include here the detailed information about
the spray suppression equipment itself• Free form, use the most appropriate
method to convey your information; e.g. – photographs, drawings– lists, tables, etc. – part numbers & suppliers– alternatives
www.dft.gov.uk/vca41
Systems - Type Approval Testing
Book an appointment!
System type approval costs with VCA are; • Cert Fee £37 (£56 for paired Dir & Reg)• Admin Fee £73• Tech Fee £89 per hour
Approval granted if all requirements are met;
e11*91/226*2010/19*nnnn*00
www.dft.gov.uk/vca42
EC Whole Vehicle Type ApprovalExample;
Type = 2 Axle
Step by Step method• Gather all necessary system approvals
– 3. Rear protection– 4. Rear Registration Plate Space– 9. Braking– …– 43. Spray Suppression– … etc.
• Complete Annex III information document from Framework Directive 2007/46/EC
www.dft.gov.uk/vca43
EC / NSSTA Whole Vehicle Type ApprovalExample; O4 Trailer
www.dft.gov.uk/vca44
O4 Trailer – What needs approving?
Lighting Installation
Rear-underrun device
Masses and dimensions
Statutory plates
Side guards
Spray Suppression
Rear registration plate space
Brakes
Coupling & Drawbar
Tyres
www.dft.gov.uk/vca45
The Administration of ECWVTA
CMSCompliance
Management System
www.dft.gov.uk/vca46
Managing your administration - CMS
www.dft.gov.uk/vca47
Types, Variants and Versions
• Variants
• What is a type?• What is a Variant?• What is a version?
www.dft.gov.uk/vca48
TVV Matrix for a Trailer
So the TVV Code for this trailer is
3AO4DB / P / 18
www.dft.gov.uk/vca49
The mixed type approval
• A combination of Annex 1 (massive info doc) and Annex 3 (smaller info doc with systems approvals)
=+
Annex 3 Info Doc
Rear Underrun approval
Side guards approval
Statutory plates approval
Mixed Whole Vehicle approval
Lighting section + VCA test report
Spray Suppression section + VCA test report
Masses and dimensions approval
Rear Registration plate space approval
Annex 1 Info Doc
www.dft.gov.uk/vca50
Whole Vehicle Type Approval Coststhe detail…….
Whole vehicle type approval costs with VCA are; • S&C Cert Fee £37 (£56 for paired
Dir & Reg)• S&C Admin Fee £73 per job• Tech Fee £89 per hour• CoP review / audit £250 / £890 / £1785
• Whole Vehicle Cert fee £75• Whole Vehicle Admin fee £73• Tech fee £89
www.dft.gov.uk/vca51
Whole Vehicle Type Approval Coststhe factors…
• Passing and failing, don’t assume! more tests or inspections = more money!
• The complication factors – consolidate options that affect approval
• Adopting early means less panic and more knowledge of the process
• Maximise the multi-stage process to your benefit – e.g outsource to others if your approval doesn’t cover it
www.dft.gov.uk/vca52
So what does it all mean?
• 1st type;– approx £5,000-£7,000
• Subsequent types;– may be less for similar vehicles
or similar chassis
www.dft.gov.uk/vca53
And afterwards?
• Issue Certificates of Conformity– Your declaration that the vehicle in question
meets the requirements– Only add information that you have affected
www.dft.gov.uk/vca54
www.dft.gov.uk/vca55
Changes to your specificationAdditions to your specification
Changes to base vehicleChanges to legislation
And after that?
Maintain your approval!!!!
www.dft.gov.uk/vca56
Questions?
Contacts• Gareth Jones, Chief Engineer, VCA Bristol
• Dave Picker, Chief Engineer, VCA Midlands– [email protected]