www.dft.gov.uk/vca 1 2007/46 ec article 6 procedures for ec whole vehicle type approval mike...

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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

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Type Approval Information

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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


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

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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

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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

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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

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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


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


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



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



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


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



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



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



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


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


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


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


Worked example of ECWVTA

Mike Protheroe

25 April 2012


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


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


5. Steering Effort


...


...

Type = 3 Axle

3. Rear Protection


5. Steering Effort


...


...

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)


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


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


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


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)


2010/19/EU enforced on 9 April 2011

Requirements

Mudguard

Valances

Rain Flaps

Air/Water Separator (matting)

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



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).



Figure 4 - Diagram showing assembly of a spray-suppression system

(mudguard, rain flap, outer valance) incorporating spray-suppression devices (energy absorbers)


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



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]



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



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



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


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


XXXXXXXX



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:



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


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


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


EC / NSSTA Whole Vehicle Type ApprovalExample; O4 Trailer


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


The Administration of ECWVTA

CMSCompliance

Management System


Managing your administration - CMS


Types, Variants and Versions

• Variants

• What is a type?• What is a Variant?• What is a version?


TVV Matrix for a Trailer

So the TVV Code for this trailer is

3AO4DB / P / 18


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


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


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


So what does it all mean?

• 1st type;– approx £5,000-£7,000

• Subsequent types;– may be less for similar vehicles

or similar chassis


And afterwards?

• Issue Certificates of Conformity– Your declaration that the vehicle in question

meets the requirements– Only add information that you have affected


Changes to your specificationAdditions to your specification

Changes to base vehicleChanges to legislation

And after that?

Maintain your approval!!!!


Questions?

Contacts• Gareth Jones, Chief Engineer, VCA Bristol

– [email protected]

• Dave Picker, Chief Engineer, VCA Midlands– [email protected]

www.dft.gov.uk/vca 1 2007/46 ec article 6 procedures for ec whole vehicle type approval mike...

Documents

step type approval procedure

type approval processes

vehicle approval

multi stage type approval

type of vehicle

discrete type approval

processes mixed type

definitions step