2007/46 EC Article 6 Procedures for EC Whole Vehicle Type Approval

1. 2007/46 EC Article 6 Procedures for EC Whole Vehicle Type Approval Mike Protheroe 25 April 2012

2. 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

3. Type Approval Information

4. 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

5. 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

6. Type Approval 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

7. 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

8. Type Approval Certificate(s) & Test Report(s) Compiling Information Photographs & Drawings Info Doc Information Document Index Information Package Template Information Folder

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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

17. 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

18. 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

19. 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

20. As the name suggests a mixture of both step by step and single step are used Almost any combination is allowed Examples Mixed Type Approval

21. 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

22. Worked example of ECWVTA Mike Protheroe 25 April 2012

23. 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

24. Overall Picture

25. Getting Systems Approvals • Understand the legislation • Build the product in compliance • Ensure Conformity of Production (CoP) systems in place • Prepare Information folder • Submit for type approval testing • Receive Type Approval certificate • Continue to build in compliance

26. 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

27. 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

28. 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)

29. System Approval Example Spray Suppression 2010/19/EU enforced on 9 April 2011 Requirements Mudguard Valances Rain Flaps Air/Water Separator (matting)

30. 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

31. 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).  

32. 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)

33. 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

34. 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]

35. SpraySuppression 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

36. SpraySuppression 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

37. SpraySuppression 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

38. SpraySuppression Information Document XXXXXXXX 9. BODYWORK 9.20. Spray-suppression system 9.20.0. 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

39. SpraySuppression 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:

40. SpraySuppression 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

41. 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

42. 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

43. EC / NSSTA Whole Vehicle Type ApprovalExample; N3 Skiploader

44. N3 Skiploader

45. N3 Skiploader – What needs approving? Masses and dimensions Rear registration plate space Lighting Installation Rear-underrun device Spray Suppression Statutory plates Side guards

46. N3 Skip Loader – What needs testing? Masses and dimensions ! Inspection only ! Rear registration plate space ! Inspection only ! Lighting Installation ! Installation check only ! ! Installation check only ! Rear-underrun device Spray Suppression ! Installation check only ! Statutory plates ! Inspection only ! ! Installation check only ! Side guards

47. The Administration of ECWVTA CMSCompliance Management System

48. Managing your administration - CMS

49. Types, Variants and Versions • What is a type? • What is a Variant? • What is a version? • Types • Variants • Versions • As per base vehicle

50. TVV Matrix continued…. • Covering the range: