Those two emotive words
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HE WORDS "Type approval" ave become as emotive within e road transport industry as ggernaut is outside it. Some anufacturers have welcomed e news of the release of draft pe approval regulations while thers admit that even before ey are implemented they have aused nightmares writes TIM LAKEMORE.
The general reaction from perating engineers (as oposed to manufacturing engieers) has been one of mild hoslity. Those who regard type pproval as a subtle form of irnort control favour it, and those vho consider the regulations at heir face value have more loubts.
Whichever school of thought .ou support, the fact is that the )epartment of Transport proloses to apply the scheme on a ompulsory basis to goods .ehicles manufactured on or fter October 1, 1982 and first ised op or after April 1,1983, The scope of the scheme lutlined in the draft regulations 3 limited to five areas: power to veight ratio; exhaust emissions; loise and silencers; radio in-. erference suppression; and wakes. Two items which ap'eared in the consultation paper ;sued in November 1980 — .ariation of wheel load, and prings — have been omitted rom the draft regulations, but II goods vehicles are caught in ne type approval net.
Non car-derived vans under .5 tonnes plated weight do not scape in the same way as they lo with plating and testing, and ertain types of dual purpose ehicies referred to as "dyadic ehicies" also are in scope. 'hese are passenger and goods arrying vehicles not covered by le car type-approval regulaons. Even opponents of type pproval will probably welcome -le inclusion of a category of oods vehicle which until now as managed to escape many of le safety restrictions applied to ther vehicles.
A major effect of the proposed cheme, and one which must urely be welcomed by operatig engineers, is that it shifts the urden of responsibility for platig heavy goods vehicles from the user to the manufacturer. The plated weights will be deter mined by the DTp at the time of vehicle inspection before the vehicle is licensed, so the one year "honeymoon period" which currently applies between the date of registration of a heavy goods vehicle and its first birthday plating and testing will end.
Indeed, the scheme will be enforced by making first licensing of each goods vehicle depend upon an appropriate type approval certificate being in force.
The number of GV 9 items com monly discovered by FTA inspectors on unregistered vehicles suggests that this additional responsibliity for manufacturers is overdue.
Furthermore, no longer will it be only the vehicle operator who is penalised if his vehicle fails to comply with the regulations. Under the proposals, it will become an offence to sell, supply, or use a vehicle if an appropriate type approval certificate is not in force.
A key phrase which occurs frequently in the draft regulations is "primary stage of manufac turer". Many smaller companies which modify chassis have be come worried that the cost and delay of type approval could put them out of business.
As the regulations stand, it would seem to be safe to in terpret them as not being in tended to apply to anything other than the primary stage of manufacture. Indeed, the con sultation document was unequivocal in its statement that "the scheme proposed will at the outset be confined to requirements which can be dealt with at the primary stage of manufacture. And a type approval certificate granted to a manufacturer will be regarded as being 'in force' for the purposes of first licencing notwithstanding any changes made to the approved vehicle characteristics at subsequent stages of manufacture."
Department of Transport chief mechanical engineer John Furness has been even more specific and assured a meeting of the Institute of Road Transport Engineers earlier this year (CM, February 28) that type ap
provel would be confined to chassis/cabs, the variety of design in commercial vehicle bodies making it impractical to consider type approving them. Mr Furness anticipated that, in many cases, type approval would be "merely a translation of current C&U regulations".
The requirement for operators to comply with C&U regulations will certainly not be removed by type approval.
The provision in the draft regulations for the type approval of parts has tended to be overlooked. This will apply to manufacturers of components, such as anti jack-knife equipment or any equipment fitted before a vehicle is first registered. But because the proposed regulations do not apply to trailers, the equipment fittedto them, rather than to tractive units, will not have to be approved.
There will be two types of type approval certificate — a Minister's approval certificate for a motor vehicle, and a certificate for a motor vehicle part.
Perhaps the greatest source of concern in the regulations are those sections dealing with "notifiable alterations". The draft regulation states: "Where, as a re
sult of a notifiable alteration, thE Secretary of State decides tc suspend or amend a CertificatE of Conformity or a Minister's approval certificate, he shall, soon as practicable give noticE of the decision to the persor who notified him of the opera tion."
'How soon does that mean?' is the question on many engi neers' lips. When altering E specification is likely to involve E manufacturer in considerablE delay and additional cost ther there is a strong disincentive tc change. That is what worrie: many operators when even now without national type approval there is a demand for vehiciE manufacturers to be more res. ponsive to operators' needs.
All interested parties havE been given the opportunity tc make their views on type approval known to the Departmeni of Transport, but there is not E great deal of time left to do so The deadline is August 3. Toc frequently in cases such as this busy managers and engineer: are unable to find the time tc make their opinions known. Ir this case they should be sure tc find the time for it is an impor tent matter.