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Fears expressed as British type approval date nears

2nd January 1982, Page 38
2nd January 1982
Page 38
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Page 38, 2nd January 1982 — Fears expressed as British type approval date nears
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Which of the following most accurately describes the problem?

Will the scheme limit manufacturers' inventiveness? Tim Blakemore explores this controversial subject and explains the regs and their implications

IN NINE MONTHS from now the first goods vehicles ever to be subjected to British national type approval will be rolling off manufacturers production lines, All the discussions over the principles of the scheme have now ended; or at least they should have done so, for at this stage they are futile. It only remains for a few of the finer details of the scheme's operation to be finalised.

Increasingly, manufacturers are becoming aware of exactly what type approval will mean to them. The Department of Transport's engineers have obviously already studied the regulations carefully — after all, they are the men who are going to have to enforce them, and they are working hard to try to ensure that the period of transition runs as smoothly as possible.

It is noticeable that the enthusiasm with which many homebased vehicle manufacturers greeted the news of British national type approval (CM November 15, 1980) has been tempered a good deal by their own engineers' pragmatism when faced with the reality of the additional workload that type approval will mean.

Leyland's immediate response to Norman Fowler's original proposals in 1980 was: "We have been campaigning for type approval for some time. It will stop Britain being the soft touch for European factories."

It is arguable whether Britain ever was "the soft touch" for European mari-ufacturers, but more to the point it is extremely doubtful whether the Type Approval Regulations as they stand will have any effect on the share of the British market taken by importers from EEC countries.

It is even doubtful whether non-EEC based manufacturers will be affected in that way, though certainly a distinction is made between the two types of manufacturer in the legislation.

The official reason for the scheme's introduction was stated by David Howell, Secretary of State for Transport, when he laid the Type Approval Regulations before Parliament on October 1 last year. "This new scheme is important because it will ensure that goods vehicles are checked for compliance with safety and environmental standards before they are licensed for use on the roads in this country.

This is already done for cars and its introduction for goods vehicles will bring Great Britain more into line with practices in other European countries. It will also allow the permitted operating weights of heavy goods vehicles to be firmly fixed before they are used on the roads."

An important point to note is that the type approval regulations only apply to vehicles before they are licensed. Once a vehicle has been first licensed for use on the roads in Great Britain, the technical requirements of the regulations no longer have effect.

As at present, the vehicle must then comply with the Construction and Use and Road Vehicle Lighting Regulations.

So, as the DTp points out, goods vehicle national type approval will not bear directly upon goods vehicle operators. But it is disingenuous to suggest that operators will not be affected at all by the change in the law.

A repeatedly expressed fear of many transport engineers is that their choice will become more limited as inventiveness is stifled by the regulations acting as a disincentive to manufacturers to change specifications wherever this can be avoided.

One may speculate as to thest long-term effects of the nev‘ scheme, but some aspects art indisputable. Wisely, the 13-fr prefers to concern itself with thE facts of the matter. One such fac. is that type approval will appl \ to goods vehicles manufacturer on or after October 1 1982 anc first used (normally firs licensed) on or after April 1 1983

It may seem pedantic tr further explain such ar apparently simple statement but it should be emphasised tha it means precisely what it says For example, vehicles manufac tured on or after October 1 198; but first used before April 1 198; will not have to be type ap proved.

Before any goods vehicle car be type approved, its individua systems (certain components will have to be approved.

The British regulations cur rently confine themselves to Si) specific areas namely power tr

aight ratio (not spark ignition igined vehicles or dual-purse vehicles); gaseous exhaust iissions (spark ignition enied vehicles only); particle nissions (exhaust smoke) )mpression ignition engined hides only); noise; radio in-ference suppression (spark igion engined vehicles only); d brakes.

The standards which must be met to achieve approval are specified in Schedule 1 attached to the relevant statutory instrument, The Motor Vehicles (Type Approval for Goods Vehicles) (Great Britain) Regulations 1981 (SI 1981 No 1340).

Some of them are based on Construction and Use requirements, but the majority refer to internationally agreed standards — either EEC Directives or ECE Regulations issued by the United Nations Economic Commission for Europe.

Manufacturers should have no difficulty with these standards because already vehicles are (or certainly should be) built to satisfy them. Approval to the relevant international standard is acceptable as evidence of compliance with the national type approval item concerned. However, when applying for an individual system approval, the applicant must choose whether he wants national approval (GB approval) or full approval to the international standard.

Where no international standard is listed in Schedule 1, for example power to weight ratio, only the former alternative is available.

There are important differences between GB approvals and full international approvals and these are fully described in the DTp's guide to national type approval.

Applications for both types of system approvals can be accepted only from persons domiciled in Great Britain. Therefore, manufacturers from abroad must appoint accredited representatives who live in Britain to apply on their behalf and to be responsible for paying the fees. The reason for this important condition has nothing to do with any sinister nationalism, but is simply because the British courts, which ultimately would have to enforce the law, have jurisdiction only in Britain.

Systems approval satisfactorily completed, a manufacturer can then apply for vehicle type approval. This is where a clear distinction is made between EEC and non EEC-based manufacturers. There are two types of certificates (perhaps in this context it is clearer to say "kinds of certificates").

Here I quote from the DTp's guide: "Type approval certificates (TAC) are available for vehicles manufactured in the United Kingdom or one of the other European Community countries and are issued for a vehicle type produced by a particular manufacturer in a specified country.

"Before a TAC is issued, the manufacturer's plant is examined to see that he has the necessary arrangements to ensure conformity of production. Provided the Department's engineers are satisfied on this count, the TAC is issued and the manu

facturers may then issue his own certificates of conformity for all vehicles produced to type.

"Minister's approval certificates (MAC) are the only certificates available for vehicle manufacturers outside the European Community — although applicants within the European Community may also apply for MACs. If more than one vehicle of the same type is to be produced, the certificate granted to the first vehicle is known as the "primary Minister's approval certificate" (PMAC).

"Subsequent vehicles of the same type require 'subsequent Minister's approval certificates' (sub MAC).

"These are prepared by the applicant, who submits them to the Department for issue and confirms that the vehicles in question are built in conformity to the approved type. Before issuing a sub-MAC, the Department may require information about the applicant's conformity of production arrangements and may ask to inspect one or more of the vehicles concerned to see that they are covered by the same specification as the original vehicle for which the PMAC was obtained."

So each MAC can apply only to one vehicle (one chassis , number) whereas a TAC can apply to any number of vehicles of the given type. However, the DTp has made it clear that identical vehicles made by the same manufacturer but at different locations will require separate certificates. For example, a Volvo F7 made in Belgium will require a different TAC from an identical-spec chassis assembled at Irvine.

There are those who interpret this MAC/TAC part of the scheme as discrimination against non-EEC manufacturers, but in fact there is a much more simple, practical reason, once again concerned with the jurisdiction of British courts, for the two different types of certificates.

There are bound to be many cases in non-EEC countries where it simply will not be possible for the DTp's engineers to examine manufacturers' plants. Imagine if a TAG were issued to a Polish manufacturer. In such a case there is no way in which the DTp can ensure that conformity of production arrangements are satisfactory, except by inspecting individual chassis.

Nevertheless, for Volvo and Scania this particular part of the type approval regulations does present a problem. As we reported last week, Scania is planning to switch production of all UK-bound chassis from its main factory in Sweden to the assembly plant at Zwolle, Holland, thus making it eligible for TACs.

The solution for Volvo cannot be that simple even though the company has an assembly plant in Belgium and of course one at Irvine in Scotland.

Volvo's range of vehicles in the UK is wider than Scania's and while the Belgian plant is capable of producing the full Frange, it is doubtful whether it could be used to satisfy the total UK demand. Irvine currently has the capacity to build only F7s. Clearly, Volvo is going to have to look carefully at its model range and decide for which vehicles it should apply for MACs and for which TACs.

All manufacturers, wherever they are based, are concerned about the delay in putting vehicles into service and the cost involved with type approval. There have been, and will continue to be, meetings between manufacturers and the DTp through the SMMT to try to iron out the difficulties. It should not be forgotten that type approval can be regarded more positively by pointing out that it should eliminate all the "pirate work" that too many vehicles suffer before going into service. One manufacturer described some of the modifications he has seen made to some of his chassis as "crude and awful".

Those two adjectives could never be used to describe the work done by reputable chassis engineering companies such as Halmo and the Primrose Third Axle Co. Yet the Type Approval Regulations as they stand leave these companies, they believe, in an invidious position.

Halmo is generally in favour of a type approval scheme but sees the existing regulations as "unworkable." The problem lies in the fact that when a chassis goes from a vehicle manufacturer to a convertor, the responsibility for type approval of that vehicles also passes to the convertor.

The DTp puts it this way. "Alterations that change the number, longitudinal location or nominal size of the tyres or wheels are known as 'prescribed alterations' and must be notified to the Department at the Vehicle and Component Approvals Division in Bristol.

"If any of the individual system approvals are affected by the change the convertor must apply for fresh approvals. Once these have been obtained he can apply for a vehicle type approval (either TAG or MAC) using the new individual systems approval issued to the original manufacturer where these are still valid.

However, to apply for a TAG, the convertor must negotiate a satisfactory agreement with the original manufacturer concerning conformity of production arrangements for these latter items. He must also have his conformity of production arrangements examined by the Department's engineers."

Halmo sees this as meaning in practice that a straightforward wheelbase extension which inevitably involves some alteration to the braking system (for example the load-sensing valve) would necessitate their applying for a type approval test costing perhaps £2,000 when the cost of the extension itself would be only a few hundred pounds.

Needless to say, strong representation has been made to the Department of Transport through the Association of Chassis Engineers. The Department's reply is expected before February. It is just one of several type approval problems the DTp's staff will be trying to help to solve before October 1.

NB. The DTp's detailed Guide to Goods Vehicle National Type Approval in Great Britain is available from the Vehicle and Component Approvals Division, Department of Transport, Tollgate House, Bristol.


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