This is the year that in January saw the introduction of Euro-6 engine emissions legislation – and come October there will be more rules and regulations to adhere to. The reason for the upheaval is the introduction of Whole Vehicle Type Approval (WVTA), which could have an impact on operators of all types of commercial vehicles.
Affecting all rigid vehicles above 3.5-tonnes GVW (categories N2 and N3), the legislation requires that the vehicle chassis and body must together be approved as a single entity, or type. Like Euro-6, the introduction of WVTA has been well documented and promoted through various publications as well as government-generated literature and advertising campaigns, but some operators have been slow to react.
For tipper operators, help is at hand – courtesy of Thompsons, which has developed a guide to Whole Vehicle Type Approval, outlining what it is, and how it could affect said operators in their working lives.
How to get type approved
There are three ways of achieving type approval: European Community Whole Vehicle Type Approval (ECWVTA); National Small Series Type Approval (NSSTA); and Individual Vehicle Approval (IVA). ECWVTA provides for the approval of whole vehicles, in addition to vehicle systems and separate components. Accepted throughout the EU without the need for further testing until a standard is updated or the design changes, ECWVTA is aimed primarily at vehicle and bodywork manufacturers that operate in large volumes.
NSSTA is a UK national scheme for low volume manufacturers that intend to sell only in the UK. There are advantages to the scheme, namely relaxed technical requirements for some areas, a more pragmatic approach to the Conformity of Production (CoP) requirements, and a reduction in administrative requirements. Like ECWVTA, once the design is approved individual vehicles do not need to be tested.
Finally, IVA is another national scheme, and the most common to those that manufacture or import in very small volumes. It is based on an inspection of the individual vehicle by the Driver and Vehicle Standards Agency (DVSA) in Great Britain or the Driver and Vehicle Agency (DVA) in Northern Ireland. Thompsons says that this route is not practical for those building more than three vehicles a week, due to the high individual vehicle cost.
With this fact in mind, it stands to reason that the most expensive routes for a bodybuilder are ECWVTA and NSSTA. Both of these routes cost thousands of pounds to gain an approval and each approval is specific to a type of truck, so a Volvo FM, a DAF 85, an MAN TGS etc. are all different types.
Thompsons explains that an approval must be gained for every type of truck it wants to build on. In addition to the cost, the company must also gain CoP. Thus to be viable, Thompsons must build bodies in high enough quantities to justify the high initial costs.
Type Approval for tipper operators
With Type Approval, the way vehicles are built will change radically, as will the equipment that is put on a chassis, explains the Thompsons report. While previously tippers were exempt from a number of safety devices as they were considered impractical for tipper work, this will no longer be the case.
The Side Under Run System (SURS) will be compulsory for all vehicles under WVTA. All SURS will require a test report from the VCA, or a previously type approved system must be used. Welding some steel box section to the body or chassis is no longer a viable option. Nor is making your own SURS. It must be designed and fitted to certain dimensions, (including around crane legs and other chassis equipment).
Rear Under Run System (RURS) will also be compulsory for N2 (3.5–12-tonnes) and N3 (12–32-tonnes) category vehicles. Exceptions to the rule are where they are incompatible with the actual use of the vehicle, and this must be demonstrated to the VCA at the time of approval.
Thompsons points out that one exception could be category N3G ‘off-road’ vehicles, which must adhere to strict guidelines of ground clearance, including having a minimum departure angle of 25°. “Should the fitting of a RURS mean that the vehicle can no longer comply with the departure angle, then it becomes incompatible with use and is exempt. However, if it can be fitted and still comply with the departure angle, then RURS must be fitted,” it states.
Spray suppression changes
All N-class vehicles will be required to have spray suppression with the exception of Off-Road types. These requirements cover what Thompson refers to as call wings and valances, as well as spray suppression components. “At the moment we fit wings to the body and they are set quite a way from the tyre to allow adequate clearance when tipping,” states the report.
Under WVTA rules, fitting rear light cages by bodybuilders will not be permitted. This decision has been taken because it reduces the amount of light emitted by the approved lamp. However, after the vehicle is registered, operators may fit cages if they wish.
Currently, rear lights are fitted high up, off the body, to limit damage. The height is often above the legal height for the fog light, requiring an additional light to be fitted. However, lights will now need to be fitted in a lower position to comply with new height requirements and fitting additional fog lights will not be allowed.
When towing, all relevant equipment must be approved before it can be fitted, under the terms of WVTA. This list of equipment includes the mounting brackets in addition to the actual towball or coupling. The towball fitted must be capable of towing the full plated train weight.
All of these rules might sound like pettifogging bureaucracy, and to an extent they are. However, the plus side for operators and fleet managers is that a new body, selected from any manufacturer, should now be of a consistently high quality.
The complexity of the Type Approval system and the specialist knowledge required to complete separate approvals has resulted in many body builders leaving their approvals too late. With added financial and administrative pressures, not to mention time and personnel that can be tied-up in preparing Type Approval documentation, it is little wonder that many conversion companies feel swamped.
To assist body builders and converters with the Type Approval process, the SMMT has launched a Type Approval Consultancy Service alongside its online Type Approval tool. This cost effective service is available at a daily rate of £600+VAT for SMMT members £750+VAT for non-members.SMMT’s experienced Technical team provides assistance in obtaining Type Approval from the initial meeting with the Vehicle Certification Agency (VCA), through paperwork, vehicle inspection and issue of the Certificate of Conformity (CoC).
In addition, valuable guidance is on tap in relation to the Conformity of Production (CoP) process. For further information, contact Tony Hopkins, SMMT Technical Manager on thopkins@smmt.co.uk or 020 7344 9239.
