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Most areas of business are subject to various forms of approval and regulation. Road vehicles are ‘special’ though because they have a massive impact on society and have had to comply with various regulations since they first hit our roads.
The whole process is unbelievably tortuous, but means that an example of each individual model of car is tested so emissions, braking performance, fuel consumption and other standards have to be pretty consistent throughout that particular model. It’s the Type Approval testing which decides a vehicle’s carbon dioxide output, which is printed on the registration document and used to decide the level of VED payable.
Europe has been using two systems of type approval for over 20 years. One is based around EC Directives and allows for approval of whole vehicles, vehicle systems and separate components. The other is based around ECE (United Nations) regulations and provides for approval of vehicle systems and separate components, but not whole vehicles.
Automotive Type Approval
This is confirmation that production samples of a design will meet specified performance standards. The specification of the product is recorded and only that particular specification is approved.
European Automotive Directives need to be approved by a third party – that’s the testing, certification and production conformity assessment. Each member country of the EU has to appoint an independent approval authority to issue the approvals and a technical service to carry out all the testing for the Directives and Regulations. An approval issued by an authority in one member state will be valid in all other member states.
In the UK the VCA [Vehicle Certification Agency] is both the approval authority and the technical service.
There are a couple of confusing bits – automotive Directives are ‘old approach’ which means they need third party testing and approval. ‘New approach’ Directives have a different format and place more obligation on the manufacturer to make sure the product meets appropriate requirements. The EU decided that the new approach isn’t appropriate for road vehicles so lots of Ministry intervention is needed.
WHOLE VEHICLE TYPE APPROVAL
European approval of most road vehicles is based around a ‘Whole Vehicle’ framework Directive 70/156/EEC. This specifies the range of aspects of the vehicle which must be approved to separate technical Directives.
So – if a manufacturer wants whole vehicle approval for his latest motor then that motor needs approval for all the different systems – up to 48 different standards for a typical car. That means approval for the braking system, emissions, noise levels etc.
The issuing of the whole vehicle approval doesn’t in itself involve any testing, but a production sample of the complete vehicle is inspected to check that its specification matches the specifications written in all the separate Directive approvals.
The Whole Vehicle Approval framework applies to any vehicle with four or more wheels except tractors, mobile machinery etc. These have their very own set of Directives.
Environment
01. Sound Levels 1991/101
02. Emissions EC 2003/76
11. Diesel Smoke EC 2005/21
39. Fuel Consumption EC 2004/3
40. Engine Power EC1999/99
41. Diesel Emissions 2006/51/EC
Active Safety
05. Steering Equipment EC 1999/7
07. Audible Warning EC 70/388
35. Wash/Wipe EC94/68
13. Antitheft EC 95/56
32. Forward Vision EC 90/630
17. Speedometer and Reverse Gear EC 97/39
08. Rear Visibility EC 2005/27
46. Tyres EC 2005/11
34. Defrost/Demist EC 78/317
09. Braking EC 2002/78
20. Lighting Installation EC 97/28
33. Identification of Controls EC 94/53
37. Wheel Guards EC 94/78
Passive Safety
19. Safety Belt Anchorage EC 2005/41
16. Exterior Projections EC 79/488
15. Seat Strength EC 2005/39
14. Protective Steering EC 91/662
03. Fuel Tank EC 2006/20
12. Interior Fittings EC 2000/40
31. Safety Belts EC 2005/40
06. Door Latches and hinges EC 2001/31
38. Head restraints EC 78/932
45. Safety glazing EC 2001/92
53. Frontal impact EC 1999/98
54. Side impact EC 96/27 |
Lighting Equipment
21. Reflex Reflectors EC 97/29
22. Side, Rear and Stop lamps EC 97/30
23. Direction indicator lamps EC 1999/15
24. Rear registration plate lamp EC 97/31
25. Headlamps (including bulbs) EC 1999/17
26. Front fog lamps EC 1999/18
28. Rear fog lamps EC 1999/14
29. Reversing Lamps EC 97/32
30. Parking Lamps EC 1999/16
Other Directives
27. Towing Hooks EC 96/64
10. Radio Interference Suppression EC 2006/28
04. Rear Registration Plate EC 70/222
18. Statutory Plates EC 78/507
36. Heating systems 2004/78
44. Masses and Dimensions EC 95/48
50. Mechanical Couplings EC 94/20
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System or Component Approval
The separate technical Directives and Regulations require the approval of individual systems as part of a type of vehicle and some allow for the approval of separate devices. A separate device may be approved either as a Separate Technical Unit (STU) in which case the vehicle to which it is to be fitted must be declared, or as a Component if it can be fitted to any vehicle. To gain system and component approval a sample of the type must be tested by the Technical Service [The VCA] to the standards of the applicable Directive. Its technical specification is documented and that specification forms part of the approval.
The Process
The manufacturer first applies to VCA in writing and direct contact with the testing laboratory can also be made.
VCA issues a job number and the name of a contact VCA test manager.
The manufacturer contacts the VCA test manager and arranges a ‘worst case’ meeting.
VCA practises worst case selection before testing so it can trim the amount of testing needed across the range of a product type. A meeting between the VCA and the manufacturer considers the products to be tested, the tests which will be carried out and the date and place of the testing. The manufacturer is also allowed to submit any relevant information such as his own in-house testing.
Testing
As we have already seen, the VCA is the automotive approval Authority and Technical Service in the UK. This means it is responsible for witnessing or carrying out the necessary tests as well as issuing the approval certificates.
Tests don’t have to be done in the UK – the VCA has staff in the USA, Japan, Malaysia and China.
The VCA can either use the manufacturer’s equipment, or facilities hired by him. Otherwise, the VCA can provide the test instruments and facilities. MIRA at Nuneaton is one of the favoured sites. BSI (British Standards Institute) at Hemel Hempstead test lamps, mirrors, restraints, tachographs.
Before the testing can begin, the manufacturer has to submit technical documentation which adequately specifies the product in terms of the elements of the design which are relevant to the Directive concerned. These documents are used as a check list for the sample of the product which is provided for testing and also as the basis for the approval itself.
Further good quality final information documents may also be needed – to attach to the approval certificate.
For each approval a manufacturer for the product must be named. Oddly, this doesn’t have to be the actual manufacturer of the product – but it must be a company which can take and prove responsibility for the design and manufacture and thus control conformity to type of production samples.
Conformity of production requirements are based around established quality systems principles and certification to ISO9002. Conformity of Production means a manufacturer must be able to show that he can produce his product to a standard which matches that of the samples submitted for testing.
Once all the technical documentation and test reports have been done and conformity of production clearance has been given, then VCA completes the approval package by issuing an approval number, certificate and an index to the manufacturer’s documents.
The specification of a particular product is then ‘frozen’ in the approval. If the specification changes the Approval Authority must be notified of the change. Fortunately, if the change is only minor then it may be possible to add it to the existing documentation.
© Vanessa Guyll, August 08
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