Transcript PDE - Society of Motor Manufacturers and Traders

2007/46 EC Article 6
Procedures for EC Whole Vehicle Type
Approval
Mike Protheroe
25 April 2012
www.dft.gov.uk/vca
1
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/vca
2
Type Approval Information
www.dft.gov.uk/vca
3
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/vca
4
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/vca
5
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;
Type
Approval
– the information folder (supplied by the applicant)
– test reports, type approval certificates (& other docs)
added by a technical service or approval authority
www.dft.gov.uk/vca
6
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/vca
7
Compiling Information
Information
Document
Template
Information
Folder
Index
Information
Package
www.dft.gov.uk/vca
Info
Doc
Photographs &
Drawings
Type
Approval
Certificate(s) &
Test Report(s)
8
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/vca
9
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/vca
10
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/vca
11
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/vca
12
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/vca
13
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/vca
14
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/vca
15
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/vca
16
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/vca
17
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/vca
18
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/vca
19
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
www.dft.gov.uk/vca
Base Stages
Vehicle
Steps
Steps
Steps
Steps
Single
Mixed
Single
Single
Single
Single
Steps
Mixed
Mixed
Mixed
Steps
…
Mixed
Y/N
N
Y
Y
N
Y
Y
Y
Y
20
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/vca
21
Worked example of ECWVTA
Mike Protheroe
25 April 2012
www.dft.gov.uk/vca
22
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/vca
23
Overall Picture
Whole Vehicle Type Approvals (Framework Directive)
Common system approvals
for types 1 Axle, 2 Axle and
3 Axle
www.dft.gov.uk/vca
Type = 2 Axle
Type = 3 Axle
3. Rear
Protection
3. Rear
Protection
3. Rear
Protection
4. Rear
number plate
4. Rear
number plate
4. Rear
number plate
5. Steering
Effort
5. Steering
Effort
5. Steering
Effort
9. Braking
Type = 1 Axle
9. Braking
Type = 2 Axle
9. Braking
Type = 3 Axle
...
...
...
43. Spray
Suppression
43. Spray
Suppression
43. Spray
Suppression
...
...
...
System Type Approvals (‘Daughter’ directives / regulations)
Type = 1 Axle
24
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/vca
25
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/vca
26
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/vca
27
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/vca
28
System Approval Example
Spray Suppression
2010/19/EU enforced on 9 April 2011
Requirements
Mudguard
Valances
Rain Flaps
Air/Water Separator (matting)
www.dft.gov.uk/vca
29
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/vca
30
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/vca
31
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/vca
32
Spray Suppression Information
Document
Information document no … relating to EC typeapproval 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/vca
33
Spray Suppression Information
Document
0.3. Means of identification of type, if marked on
the vehicle (b)
Not applicable
0.3.1. Location of that marking:
Not applicable
0.4. Category of vehicle (c):
N1, N2, N3, O3, O4
0.5. 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/vca
34
Spray Suppression Information
Document
1. GENERAL CONSTRUCTION
CHARACTERISTICS OF THE VEHICLE
1.1. Photographs and/or drawings of a representative
vehicle:
See attachment 1
1.3. 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:
None
1.3.2. Number and position of steered axles
None
35
www.dft.gov.uk/vca
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/vca
36
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/vca
37
Spray Suppression Information
Document
9. BODYWORK
9.20. Spray-suppression system
9.20.0. Presence: yes /XXXXXXXX
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
38
www.dft.gov.uk/vca
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/vca
39
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/vca
40
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/vca
41
EC Whole Vehicle Type Approval
Example;
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/vca
42
EC / NSSTA Whole Vehicle Type Approval
Example;
N3 Skiploader
www.dft.gov.uk/vca
43
N3 Skiploader
www.dft.gov.uk/vca
44
N3 Skiploader – What needs approving?
Masses and
dimensions
Rear registration
plate space
Lighting Installation
Rear-underrun
device
Spray Suppression
www.dft.gov.uk/vca
Statutory plates
Side guards
45
N3 Skip Loader – What needs testing?
Masses and
dimensions
Rear registration
plate space
Lighting Installation
Rear-underrun device
Spray Suppression
www.dft.gov.uk/vca
Statutory plates
Side guards
46
The Administration of ECWVTA
CMS
Compliance
Management
System
www.dft.gov.uk/vca
47
Managing your administration - CMS
www.dft.gov.uk/vca
48
Types, Variants and Versions
• What is a type?
• What is a Variant?
• What is a version?
• Types
Category
Construction
Power Plant
Base vehicle
Extent of build
Power plant principle
No. & arrangement of cyl
Power (50% diff)
Capacity (50% diff)
Max laden mass (20& diff)
Powered axles
Steered axles
Bodywork
• Versions
As per base
vehicle
No. of axles
49
www.dft.gov.uk/vca
• Variants
Type
Variant
TVV Matrix continued….
• Covering the range:
Type
Variant
Bodywork
Steered axles
Powered axles
2A
Max laden mass (20& diff)
Power (50% diff)
Capacity (50% diff)
No. & arrangement of cyl
Extent of build
Power Plant
Base vehicle
Category
www.dft.gov.uk/vca
Construction
Feb-11
2 axle
N3
C section
Combustion
Scania type 1
Scania type 2
Renault type 1
Daf type 1
Daf type 2
MAN type 1
Volvo type 1
Volvotype 2
Completed
Incomplete
Diesel
4 cyl
5 cyl
6 cyl
V8 cyl
V12 cyl
180 - 270
270 - 400
400 - 600
600 - 900
4 - 6 litre
6 - 9 litre
9 - 13.5 litre
13.5 - 20 litre
3500-4200
4200 - 5000
5000 - 6000
6000 - 7000
7000 - 8000
8000 - 9000
9000 - 10000
10000 - 12000
12000 - 14000
14001 - 16000
16001 - 19200
19200 - 23000
23000 - 27000
27000 - 32000
4x2
4x4
6x2
6x4
6x6
8x2
8x4
8x6
8x8
front steer
front and mid steer
front and rear steer
GRP Box
Curtainside
Flatbed
Refridgerated
Crane
etc.
No. of axles
Master matrix
Body Builder example
Power plant principle
Type , Variants & Versions
Version (N/a)
N3
C
C
S1
S2
R1
D1
D2
M1
V1
V2
C
I
D
04
05
06
08
12
A
B
C
D
S
M
L
E
M
N
O
P
Q
R
S
T
U
V
W
X
Y
Z
42
44
62
64
66
82
84
86
88
FS
FM
FR
GB
CS
FB
RF
CR
50
TVV Matrix for a Skip Loader
Type
Variant
Bodywork
Steered axles
Powered axles
2A
Max laden mass (20& diff)
Capacity (50% diff)
Power (50% diff)
No. & arrangement of cyl
Extent of build
Base vehicle
Power Plant
2 axle
N3
C section
Combustion
Daf CF55
Completed
Diesel
6 cyl
270 - 400
6 - 9 litre
19200 - 23000
4x2
front steer
Skip loader
etc.
Construction
Oct-11
Category
Skip Loader example
No. of axles
Master matrix
Power plant principle
Type , Variants & Versions
Version (N/a)
N3
C
C
D1
C
D
06
B
M
X
42
FS
SL
So the TVV Code for this skip loader is
2AN3CCD1 / CD06BMX42FSSL / as per base
www.dft.gov.uk/vca
51
The mixed type approval
• A combination of Annex 1 (massive info
doc) and Annex 3 (smaller info doc with
systems approvals)
Lighting section +
VCA test report
Annex 3 Info Doc
Annex 1 Info Doc
Mixed Whole
Vehicle approval
Rear Underrun approval
Side guards approval
+
Statutory plates approval
=
Masses and dimensions approval
Rear Registration plate space approval
www.dft.gov.uk/vca
Spray
Suppression
section + VCA
test report
52
Whole Vehicle Type Approval Costs
the 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
• Whole Vehicle Admin fee
• Tech fee
www.dft.gov.uk/vca
£75
£73
£89
53
Whole Vehicle Type Approval Costs
the 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/vca
54
So what does it all mean?
• 1st type
– Approx £5,000 - £7,000
• Subsequent types
– from £300 if an additional
chassis for same vehicle
www.dft.gov.uk/vca
55
And afterwards?
• Issue Certificates of Conformities
– Your declaration that the vehicle in question
meets the requirements
– Used with previous stages CoC’s for
registration
– Only add information that you have affected
www.dft.gov.uk/vca
56
www.dft.gov.uk/vca
57
And after that?
Maintain your approval!!!!
Changes to your specification
Additions to your specification
Changes to base vehicle
Changes to legislation
www.dft.gov.uk/vca
58
Questions?
Contacts
• Gareth Jones, Chief Engineer, VCA Bristol
– [email protected]
• Dave Picker, Chief Engineer, VCA Midlands
– [email protected]
www.dft.gov.uk/vca
59