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SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Welcome address
Allan McKenzie.
Deputy Head and Senior Manager Vehicle Legislation,
SMMT
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Welcome address
Tony Hopkins.
Technical Manager,
SMMT
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Agenda
Time Subject Speaker
10:45 – 11:45 Type Approval – How to obtain an approval Mike Protheroe, VCA
11:45 – 12:30 VOSA IVA scheme and how to obtain approval Gary Race, VOSA
– What is it
– The approval routes available
– How to obtain approval
– What's it like to obtain approval
– The tools to assist you
Existing types
of vehicles 2013 2014
(Registrations)
29 October 2013
N1 Category Vehicles
No approval – No registration
‘As from 29th April 2013 you must not register a N1 vehicle using an
incomplete Certificate of Conformity. All N1 vehicles registered on
or after this date must only be registered using the completed
Certificate of Conformity details.’
Brakes
Emissions
Noise
Smoke
Front underrun (if applicable)
Tyres
Speed limiter (if applicable)
No requirements
EC Directive 2007/46/EC
380 + Pages
21 Annex’s
14 Amending Regulations
• From 29th April 2012, new requirements for notification and record
keeping came into force.
• What has been indicated here has been derived from the
SMMT and Members discussions and consultations at the
UK, EC and Globally through the UNECE.
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
2007/46 EC Article 6
Procedures for EC Whole Vehicle Type
Approval
Mike Protheroe
February 2013
25
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Outline
27
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Applying for Type Approval
28
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Applying for Type Approval
31
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Type Approval Information
32
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Descriptions of Type Approval
Information
See Article 3 (paragraphs 37 – 40) for definitions;
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
33
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Descriptions of Type Approval
Information
Annex I
• Complete Information Document used in Single
Step process
– about 60 pages of A4
Annex III
• Partial Information Document used in Step by Step
process
– about 7 pages of A4
Information package
• a compilation of;
Type – the information folder (supplied by the applicant)
Approval – test reports, type approval certificates (& other docs)
added by a technical service or approval authority
35
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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
36
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Compiling Information
Information
Document Photographs &
Template
Drawings
Info
Doc
Index
Information Folder
Information
Package
Type
Approval
Certificate(s) & Test
Report(s) 37
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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
38
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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
41
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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
42
www.dft.gov.uk/vca
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
43
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Single Step Type Approval
44
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Single Step Type Approval
Some Pros
• Is comparatively less expensive than Step
by Step as there is only one approval
– a single certificate fee and an admin fee
– however;
there are also fees for testing / inspection and / or
technical review time
45
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Single Step Type Approval
Some Cons
• The type approval documentation is very
large / ‘heavy’
– can be many, many pages
• It may be harder to manage the overall
project
– everything has to be made ready at once
– there may be difficulty controlling versions
46
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Single Step Type Approval
Some Cons
• Information is not very ‘portable’
– all approval information is ‘embedded’ in the
Whole Vehicle Type Approval
• e.g. 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
47
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Mixed Type Approval
48
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Mixed Type Approval
49
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Worked example of ECWVTA for a
Trailer (Category O2 vehicle)
Mike Protheroe
February 2013
50
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Outline
51
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Technical Requirements
For ECWVTA and NSSTA the technical requirements cover the following:
53
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Getting Systems Approvals
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
55
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Building Products in Compliance
Requirements
Mudguard
Valances
Rain Flaps
Air/Water Separator (matting)
59
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System Approval Example
Spray Suppression
• Spray suppression has a wide definition
“type”
From Article 2 of Regulation EU 109/2010;
(17) ‘vehicle type with regard to spray suppression’ means
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.
60
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System Approval Example
Spray Suppression
Some requirements extracted from Regulation EU
109/2010;
1.0 Category N and O vehicles, … shall be
constructed and/or fitted with spray suppression
systems …
…
6.3.4. The rain flap must not be more than 300 mm
from the rearmost edge of the tyre, measured
horizontally.
…
61
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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)
62
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Spray Suppression Information
Document
Information document no … relating to EC type-
approval of a vehicle with regard to its spray-
suppression systems (*)
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
63
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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):
O2
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]
64
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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 65
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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
66
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Spray Suppression Information
Document
67
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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 VI 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 68
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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:
69
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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
• dimensions (specify min – max range and tolerance)
– lists, tables, etc.
– part numbers & suppliers
– alternatives
70
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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.
71
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EC / NSSTA Whole Vehicle Type Approval
Example;
N3 Skiploader
72
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N3 Skiploader
73
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Skip Loader NSSTA – What needs testing ?
! Installation check only ! Means check the installation of approved components Masses and
dimensions
! Inspection only !
Rear registration
plate space
! Inspection only !
EMC
Lighting Installation ! Declaration only !
! Installation check only !
Rear-underrun device
! Installation check only !
Trade Bodies
75
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Types, Variants and Versions (TVV)
Types
• Manufacturer
Variants
• Designation • Extent of build
Versions
• Category • Structural concept
• Power plant differences • As base
• Number of Axles
• GVM vehicle
• Fundamental Design
• Powered axles
• Steered axles
• Power plant concept
76
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TVV Matrix
• Covering the range: Type Variant Version (N/a)
Powered axles
Extent of build
Steered axles
Base vehicle
Master matrix
Construction
Power Plant
No. of axles
Bodywork
Category
Body Builder example
Feb-11
2 axle 2A
N3 N3
C section C
Combustion C
Scania type 1 S1
Scania type 2 S2
Renault type 1 R1
Daf type 1 D1
Daf type 2 D2
MAN type 1 M1
Volvo type 1 V1
Volvotype 2 V2
Completed C
Incomplete I
Diesel D
4 cyl 04
5 cyl 05
6 cyl 06
V8 cyl 08
V12 cyl 12
180 - 270 A
270 - 400 B
400 - 600 C
600 - 900 D
4 - 6 litre S
6 - 9 litre M
9 - 13.5 litre L
13.5 - 20 litre E
3500-4200 M
4200 - 5000 N
5000 - 6000 O
6000 - 7000 P
7000 - 8000 Q
8000 - 9000 R
9000 - 10000 S
10000 - 12000 T
12000 - 14000 U
14001 - 16000 V
16001 - 19200 W
19200 - 23000 X
23000 - 27000 Y
27000 - 32000 Z
4 x 2 42
4 x 4 44
6 x 2 62
6 x 4 64
6 x 6 66
8 x 2 82
8 x 4 84
8 x 6 86
8 x 8 88
front steer FS
front and mid steer FM
front and rear steer FR
GRP Box GB
Curtainside CS
Flatbed FB
Refridgerated RF
Crane CR
etc.
77
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TVV Matrix for a Skip Loader
79
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Demand for VCA Services
– N1 (Light Vans & Trucks)
• Lots of interest but slow placing orders
– Now’s the last minute rush!
– SENTA helps make a good job of applications
• Multi-Stage Approval process
– Lengthy delay getting “Letter of Association”
from 1st stage manufacturers
• Panel Vans; “Equip for Service”
– Enhancement Scheme
www.dft.gov.uk/vca
Some Issues Encountered
81
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Some Issues Encountered
82
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Some Issues Encountered
Documentation
• Thought it was VCA’s job to make
manufacturers information document
• Docs sent in one page at a time, not PDF
• No drawings / drawings not good enough
• Docs only on paper
– in a shopping basket!
83
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And afterwards?
84
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And after that?
85
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Whole Vehicle Type Approval Costs,
the detail …
Whole vehicle type approval costs with VCA are;
• S&C Admin & Cert fee £110
• Technical fee £89 per hour
86
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So what does it all mean?
87
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Contacts
88
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Questions?
89
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Individual Vehicle Approval (IVA)
Gary Race,
Process Manager - Light Vehicles
& Approvals, VOSA
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Click to edit Master title style
• Manufacturer
• Distributor / Dealer / Supplier
• Body Manufacturer / Coach builder
• Operator / Converter
• To take responsibility for submitting the
application and providing the data required.
• Important to obtain Directive compliance to
support application
Click to edit Master
Complete title style
an application
• Web -https://www.gov.uk/vehicle-
approval
IVA 1H - category N2 and N3 (Heavy goods)
General info. eg
• Applicant details
• Appointment and payment details
Defrost / Demist
Dimensions
Mirrors
Reg. Plate
Glass
Space
Statutory Horn
Plates
Exterior
Spray Projections
Suppression Tyres
Towing Hooks
Lateral Protection Speed
Limiter
Click tocompliance
Directive edit Master- title style
Trailer
Dimensions
Statutory Plates
Couplings
Lights / Reflectors
Reg. Plate Space
Spray Suppression
Click
Howtotoedit
prove
Master
compliance
title style
• Technical Service
- carries out tests including response time and
energy consumption
- verifies compatibility, proforma specification
against trailer and calculations (References to
R13).
- sends complete package direct to VOSA
Swansea.
• VOSA - receives and collates data and creates
a version 1 (draft) Model Report.
Click to edit Master title style
Apply to Swansea
• Fee
Click toThe
editcosts
Master title style
• Technical Service
• Information
• Logistical
VOSA
Click testMaster
to edit sites title style
• Building
• Suitable size/specification
• Communication system / office
accommodation
• Underside inspection facility
• Headlamp test equipment
Click
POTF tosite
editrequirements
Master title ctd.
style
• Communicate
• Try it out
Click
Need
to edit
moreMaster
info. title style
• Web - https://www.gov.uk/vehicle-approval
• e mail – approvals@vosa.gov.uk
Any Questions...............
• to have an approval
Click to edit Master title style
The regulations
Offence to
• supply (also to supply without approval)
• use
• cause or permits to be used
Click to edit Master title style
Any Questions ?
The SMMT
Tim Hughes.
Membership Account Manager,
SMMT
www.dft.gov.uk/vca
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
What is the SMMT?
Established in 1902, SMMT supports the interests of UK automotive.
One of the largest and most influential trade bodies in the UK, SMMT is a
member organisation that represents over 500 automotive companies.
Promoting the interests of industry at home and abroad, SMMT acts as the
voice for UK automotive promoting a united position to government,
stakeholders and the media.
Main activities:
• Representing members’ interests to the UK government and other
relevant organisations.
• Providing technical and market information and business statistics.
• Consulting and informing its members on legislative developments.
Main activities:
• Representing members’ interests to the UK government and other
relevant organisations.
• Providing technical and market information and business statistics.
• Consulting and informing its members on legislative developments.
• Representing members’ interests to the relevant EC and ECE Technical
Committees.
Lunch
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Click to edit Master title style
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
What's it like to obtain an approval
Neil Loy, Homologation.
Mercedes-Benz Trucks
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
SMMT Seminar
•If you have an ISO Certificate to UKAS (United Kingdom Accreditation Standard)
or recognised equivalent you may not need an Audit
•No ISO, but have some COP recognition, or system for Conformity, an inspection by
the VCA
Auditors will be required, cost £712 per day
•Clearance of COP will be essential to be able to apply for any Job numbers,
Systems testing, or the 2nd and further Stage Approval Inspections
•Bespoke ?
•IVA, £230 + Transport, Labour, Fuel, Systems testing etc, Advantage no COP
Still only 5 sites designated in the UK for N2/N3,
Glasgow (Edinburgh), Manchester, Derby, Gillingham and Bristol
•Inspection arranged/cleared
•COC created
•Vehicle Registered
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Conformity of Production (CoP)
Agenda:
What is COP?
Vehicle Categories
Legislation
Who Needs COP and what does it affect?
What do I need to do?
Control Plans and Change Control
Initial Assessments
Submit Documentation and request Audit
Costs of Type Approval and COP
Contact:
Angie.Bissett@vca.gov.uk
VCA COP Technical Manager EU Op’s 157
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What is Conformity of Production?
158
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What is Conformity of Production?
159
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What is Conformity of Production?
160
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What is Conformity of Production?
• Type Approval is granted to a product that
meets a minimum set of regulatory, technical
and safety requirements.
161
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Type Approval and CoP cover:-
Passenger vehicles
M1
M2
M3 162
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Goods Vehicles (N)
N1
N2
N3 163
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Trailers (O)
O1
O2
O3 O4
164
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Motorcycles and Tractors (L/T)
165
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Components
167
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CoP and Multi Stage Build
One manufacturer builds a base vehicle, another manufacturer(s)
finishes it off.
Stage 1 Build – Chassis Cab
Manufacturer responsible for this stage only
168
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Multi Stage Build
Second stage – New manufacturer adds axle and body.
Second stage manufacturer only responsible for their additions and if
they make or affect any changes to first stage
Additional body
New mirrors
New tyre
Additional axle 169
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What legislation applies?
170
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Legislation and CoP
Some regulations have specific requirements
Test frequencies
Sampling regimes
Pass/Fail criteria
171
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Legislative references
• We can go to the UNECE or EEC web sites
and trawl through all the info.
or
• We can use one of VCA best tool’s VISTA
172
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Who needs CoP Clearance?
173
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Who needs CoP Clearance?
174
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CoP – What does it affect?
175
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What do I need to do?
• A Quality System
176
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What do I need to do?
177
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Quality Documentation
178
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Quality Documentation
• Non-conforming goods
• How does the company ensure that goods
purchased or manufactured that do not conform
are not used for production?
• Staff training/Competence
• How does the company ensure staff are properly
trained? How is this recorded?
• Calibration
• How does the company ensure that all relevant
equipment is calibrated?
179
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Quality Documentation
180
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Quality Documentation
• For Type Approval and CoP this is one of the most important
aspects of the approval
• Change to product may change validity of the approval
• Type Approvals can be extended to accommodate changeHow
does the company ensure that any changes to the design or
performance of the product which might affect the validity of
the Approval is notified to the authority?
182
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Quality Documentation
183
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For Initial Assessment (New Customer)
• Manufacturer with recognised (IAF/IATF)
certified quality system (ISO9001/TS16949),
then initial CoP audit not mandatory
• Documentation to be supplied
• Detailed control plans
• Copy of accredited ISO certificate (scope to be
appropriate for the product)
• Copy of quality manual may be requested by the
approval authority
184
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Initial Assessment Continued
185
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CoP Audit for Non ISO
• CoP audit based on:-
Quality Manual
Control Plans
Supplier selection
Incoming goods
Non conforming goods
Staff competency
Calibration
Change control
Manufacturing facility
186
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Manufacturing Facility
Real Experience of Bad Practice
187
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Change Control
188
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CoP as Part of ISO - Control Plans
189
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CoP Specific - Control Plans
Key
Inspection Type 1 Vehicle test (Reg)
Inspection Type 2 Visual/Dimensional verification
Inspection Type 3 Record details build log
Inspection Type 4 Functional check
Inspection Type 5 Supplier CoP
191
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Control Documents
192
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Control Documents
Procedure SP/SF1
?????? ??????????
193
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So again; Vista is the key –
194
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Surveillance
CoP for Non ISO
– Frequency in line with risk based result
– Reduced audit dependant on previous findings
– Review control plan results
– Witness CoP test if required (not normal practice)
COP for ISO
Frequency of audit determined by Regulation or
Directive and Technical review
195
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Whole Vehicle Type Approval Costs,
the detail …
Whole vehicle type approval costs with VCA are;
• S&C Admin & Cert fee £110
• Technical fee £89 per hour
• CoP review / audit £250 Technical Review
for an ISO company
• Non-ISO company £962 = 1 day audit and
Technical clearance + travel costs
• Non-ISO company £1674 2 day audit and
Technical Clearance + travel / £1,785 max (in the
UK)
• Whole Vehicle Cert fee £75
• Whole Vehicle Admin fee £73
• Technical fee £89 per hour 196
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So what does it all mean?
197
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Questions
Thank you for listening
198
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SENTA
Tony Hopkins.
Technical Manager,
SMMT
www.dft.gov.uk/vca
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
SENTA
For multi-stage and single stage builds, the system creates the
relevant documents for the approval route required.
Future legislation
•Index
•Revision log
MODEL B – SIDE 1
ECWVTA COMPLETED VEHICLES
EC CERTIFICATE OF CONFORMITY
Side 1
The undersigned ………………………………………………………..(Full name and position)
hereby certifies that the vehicle:
0.1Make (Trade name of the manufacturer): ………………………………………………….
0.2: Type: ………………………………………………………………………………………………………….
Variant(a):…………………………………………………………………………………………………..
Version(a) ………………………………………………………………………………………………………..
0.2.1 Commercial name: …………………………………………………………………………………………
0.4 Vehicle category: ……………………………………………………………………………………………
0.5: Name and address of the manufacturer: ………………………………………………………
0.6 Location and method of attachment of the statutory plates: ………………………
Location of the vehicle identification number: ………………………………………..
0.9 Name and address of the manufacturer’s representative (if any):
…………………………………………………………………………………………………………………………
0.10 Vehicle identification number: …………………………………………..…………………………………..
a) has been completed and altered(1) as follows: ………………………………………and
b) conforms in all respects to the type described in approval (…type-approval number including extension number) issued
on (…date of issue) and
c) can be permanently registered in Member States having right/left (b) hand traffic and using metric/imperial(c) units for
the speedometer(d)
…………………………………………… ........................................................
(Place)(Date) (Signature)
Attachments: Certificate of conformity delivered at each previous stage.
www.smmt.co.uk
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Thank you for attending
Society of Motor Manufacturers and Traders Ltd
71 Great Peter Street, London, SW1P 2BN
www.smmt.co.uk
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd