Department of Infrastructure staff attended a series of in-person and online sessions hosted by HVIA last week, to provide clarification on a range of component and vehicle issues related to the implementation of the Road Vehicle Standards Act on 1 July 2021.
The Department provided additional information on the process for phasing out of Motor Vehicle Standards Act provisions, and the phasing in of the Road Vehicle Standards Act.
Key Issues discussed included:
Component Type Approvals (CTA)
The department provided an overview of component type approvals, the associated guidance materials, and an overview of the CTA process in the departments ROVER application. These covered
- The benefits of CTAs as a mechanism for reducing the amount of effort vehicle manufacturers need to undertake to demonstrate compliance
- The criteria for being granted a CTA including the requirements for demonstrating compliance and conformity of production.
This was followed by a question-and-answer session which prompted some discussion on
- Testing facilities, test results, and using component supplier declarations to demonstrate ADR compliance;
- The use of a single CTA application to address multiple ADRs to provide equivalent functionality to SARN application;
- Future enhancement to ROVER including:
- Copy/edit/resubmit functionality
- Use a library of documents (e.g. QMS summaries) to simplify applications.
- Using multiple sources of information including referencing other CTA’s or ECE approvals within a CTA application, and additional testing if required;
- Conformity (control) of production (CoP) requirements including:
- Use of ISO standards (ISO 9001, internal QMS, or alternate standards),
- Having control over design componentry and manufacturing,
- Access to manufacturing facilities,
- Use of ECE standards,
- Use of commercial agreements to establish CoP,
- Use of Authority to Act.
As a result of this discussion the Department undertook to provide further clarification on the use on alternatives to ISO 9001, such as IATF 16949:2016 and clarification on the use of ECE standard in CTAs.
Register of Approved Vehicles (RAV)
The Department provided an overview of how the RAV process works and provided an overview of the RAV software including how the RAV system file generator works and RAV search work.
This included explaining that the organisation and submitter are synchronised between the RAV and ROVER system and the validations related to organisation, and submitter IDs and the email they are sent from.
There was some discussion around the use of agents to load information on behalf of a type approval holder and the mechanism to establish the authority for this within ROVER.
HVIA requested that the department provide clearer guidance material on organisation and submitter IDs, the process for registering these in ROVER and the validations between these IDs and email addresses.
One of the issues that came out of the presentation and the subsequent presenters was that RAV entries do not need to be made and indeed cannot be made until after the organisation has received a Vehicle Type Approval Number.
Vehicle Type Approvals (VTA)
The Department provided on overview of the vehicle type approval opt in and new application processes including an overview of the software. The department then took questions from the audience.
The discussion around vehicle type approvals revealed additional complexities around the transition arrangement, the VTA application process and the opt in processes.
In relation to the transition arrangements the department has confirmed that applications for new Identification Plate Approvals under the Motor Vehicle Standards Act will cease at the end of June but that manufacturers will be able to continue to apply for variations to IPAs under the Motor Vehicle Standards Act until the end of June 2022.
The Department has also confirmed that manufacturers who choose to opt in will need to meet the RVSA requirements around demonstrating control of the production process as soon as they process any variation under a VTA that they have created via the opt in process.
This provides some flexibility for manufacturers to deal with variations after 1 July but makes the decisions around when or if to opt in less clear.
If manufacturers get it wrong, they may introduce risks to their ability to ensure continuity of supply of their products to market.
Before deciding to use the opt in procedure manufacturers need to:
- Understand the RVSA requirements around demonstrating control of the production process;
- Ensure that they have suitable systems in place to meet these requirements;
- Be confident their suppliers will be able to provide the required supporting information for any variations to a VTA and have suitable control systems in place;
- Understand the opt in process and timing.
- If a manufacturer chooses to opt in, they must complete the process by the end of 2021 (opt in is not available after the end of the year and from 1 Jan 2022 the only option for obtaining a VTA will be to make a new application);
- Consider the relative effort and risk associated with:
- Processing variations under existing IPAs and making an application for a new VTA prior to 30 June 2022;
- Choosing to opt in prior to 31 December 2021 and dealing with variations under the VTA from the opt in date. To do this the manufacturer needs to ensure they have their processes for control of production and have the required support from their component suppliers in place by the opt in date.
HVIA has requested that the department provide additional or updated guidance material on:
- Conformity of production requirements;
- Use of agents to complete RVSA documentation requirements;
- Transitional arrangements including the advantages and disadvantages of using the opt in arrangements to convert an existing identity plate approval to a vehicle type approval v making a new VTA applications.
HVIA will notify members of any updates to this material through Talk the Torque and individual mail outs.
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