Road to ruin? 04 February 2014

In October, converters and bodybuilders will face the climax of one of the biggest regulatory regime changes in their history – EC whole vehicle type approval. Brian Tinham examines the implications for them and for operators

Does the arrival of ECWVTA (European Community Whole Vehicle Type Approval) for 'multi-stage' (eg: OEM chassis cab and third party body) heavy-duty N2 and N3 commercial vehicles, on 29 October this year, mean the end of the road for bespoke conversions? Will it also usher in a new era of higher costs and longer lead times? Might some bodybuilders fall by the wayside, and certain chassis-body combinations cease to exist? On the other hand, are subsequent conversions likely to be better and/or safer?

Well, the somewhat unhelpful answer to the first three questions is 'yes and no', if experience with sub 3.5 tonnes N1 vehicles, which came in scope of the legislation last April, is anything to go by. Much depends on the extent to which bodybuilders have prepared for the forthcoming type approval legislation, mostly in terms of quality systems but also commercial arrangements with their preferred OEMs (stage one suppliers). Equally, your experience is bound to be governed by the numbers of bespoke vehicles you (and others like you) want, and whether these can be deemed part of an approved conversion range, covered by a sufficiently widely-framed specification. Ultimately, the more specialised and fewer in number, the more expensive your vehicles will become and the longer you may need to wait for them – if indeed they're available exactly as-is at all.

As for performance and safety of vehicle conversions under the new regime, in theory, that shouldn't change. The rules are aimed primarily at smartening up bodybuilders' quality processes, not tampering with the statutes that underpin C&U (Construction and Use). That said, on the one hand, the mere fact of a focus on quality systems and procedures is almost bound to have some positive impact. However, on the other, a remaining loophole in two (albeit less attractive) of the three type approval processes leaves the door wide open for older technology.

So, what's happening? Currently, DVLA (the Driver and Vehicle Licensing Agency) is still accepting vehicle conversions involving bodies added to approved chassis cabs over 3.5 tonnes, with no additional type approvals. In essence, as long as bodybuilders comply with C&U regulations for their vehicle additions, everything is hunky dory.

However, in just eight months, all that changes, and certificates of conformity for 'incomplete vehicles' (chassis cabs) will no longer be accepted for registration. Instead, the entire vehicle, including its body, will require a new ECWVTA, NSSTA (National Small Series Type approval) or IVA (Individual Vehicle Approval) certificate, under the direction of the VCA (Vehicle Certification Agency) in Bristol. The choice is primarily dependent on the numbers of vehicles likely to be built, and where converters and/or their customers want to sell them (see panel).

That puts a new onus on the bodybuilders, who will need to work with OEMs to prove and maintain multi-stage compliance, if they select the mainstream ECWVTA or smaller-scale NSSTA routes. And that's not only in terms of technical issues (masses and dimensions, conspicuity, rear under-runs, side guards, spray suppression etc), but also their manufacturing and quality standards. Even if they go for the less onerous IVA approach – which involves testing and checking single vehicles against the IVA Manual – the undertakings involved are neither trivial nor free.

There will be exemptions, but very few: fire engines, police vehicles, armed services vehicles, tracked vehicles, engineering plant, mobile cranes and road sweepers not built on truck chassis, for example. However, gritters, snow ploughs, electric vehicles, breakdown trucks and several others currently exempt from the outgoing GVNTA (goods vehicle national type approval) rules, will lose their 'special purpose' status.

This is old hat for the OEMs, who have been working within the 'new' type approval rules for compete bodied vehicles under their sole control (single stage) since 2010 for new types and 2012 for the rest. However, one immediate concern is that some converters will have failed to grasp the nettle in time for this year's deadline – crucially, not obtaining accreditation of their quality and production processes – to take vehicles through the ECWVTA or NSSTA routes. These firms will be forced to go through IVA, which means driving each finished vehicle to one of the few designated VOSA stations for inspection and certification, prior to registration with DVLA through the AFRL (Automated First Registration and Licensing) system.

Therein lies the first problem. According to FTA (Freight Transport Association) head of engineering Andy Mair, IVA slots are already oversubscribed. "Although VOSA is aware of the problem and is seeking to streamline the process, new vehicle registrations through IVA are currently suffering weeks of delays and that situation can only get worse come October," he suggests. And there's the price: an additional £230 per vehicle plus any retests. Add to that the cost of drivers and fuel, and operators can also expect price hikes.

Even for bodybuilders that are prepared, additional pass-on costs and delays are almost inevitable – and there are other implications, too. Tony Soper, principal engineer at Millbrook in charge of homologation and type approval, explains that under both ECWVTA and NSSTA rules (which are predicated on a single type approval process cost and no fees for identical vehicles), the starting point will now be 'letters of association', drawn up between OEMs and bodybuilders. "These are formal documents which demonstrate that each party is aware of what the other is doing and communicating any developments that might materially affect type approval," he states. And there are legal implications: "If an approved vehicle is subsequently involved in a serious accident, those documents could be used as evidence that the stage one supplier had some knowledge of what the bodybuilder was doing."

That's already a significant change from the OEMs simply selling chassis cabs to whomever, for whatever and effectively abdicating responsibility. Not only does it imply additional administrative and potentially insurance costs for both parties, but it also means that some companies may no longer want to work with one another – either on perceived competency or competitive grounds.

But there's more: the next stage involves fees paid to the VCA ahead of a 'worst case' meeting with the VCA engineering team to agree the scope of assessments and testing, in readiness for submitting one complete bodied vehicle for technical approval. "They then inspect it and review test reports and evidence," explains Soper. "Assuming these meet the criteria, the bodybuilder then has to undertake to make all those vehicles exactly the same and in the same way to achieve his certification."

This represents a very real third hurdle: the VCA requires proof from the bodybuilder of conformity of production to complete the main type approval processes. "That involves two levels: evidence of a general quality system and production of specific control and build plans for the vehicle being type approved," says Soper. "For the first part, ISO 9001 is the gold standard, but if that's not available, a VCA conformity of production engineer will need to come in and audit the bodybuilder's quality processes." Admittedly, that's a one-off process, but for the control and build plans, each type approval will require a similar (albeit paperwork only) audit, so you're looking potentially at months of work.

Sounding costly? It is. Converters will need to: pay VCA fees; fund the production of documentation and its ongoing administration; pay for any tests, including crash testing; and shoulder the cost of parts to be tested, up to and including the body shell. And it's even worse: hidden costs will come in the form of steep learning curves for bodybuilders' management and an investment in people and processes – although some might argue they expect this level of quality conformance anyway.

What's more, most of these processes have to be repeated for each and every vehicle marque. So, for example, the same refrigerated box destined for Renault Trafic, Ford Transit and Vauxhall Movano chassis needs three separate whole vehicle type approvals. Additionally, because the OEMs' approvals have to be linked to the bodybuilders', the latter need to understand all terms and definitions specific to each vehicle type and version they deal with – and that's different for each manufacturer. And there are the ongoing costs of communicating and maintaining these approvals over time, as detailed specifications change.
So it's not difficult to see how prices and timescales will escalate. And, given that the industry is not driven by converters, but by dealerships and, in turn, customers, it's also easy to understand why innovation might be stifled. Indeed, one of the widely predicted outcomes is that converters are likely to start rationalising the bodies they offer. Another is that they'll reduce the OEMs they work with – not least because the UK only hosts national sales organisations, with OEMs' engineering authority at European head offices, meaning that accessing the right people can be difficult.

Furthermore, it's not difficult to see why some bodybuilders might plump for the IVA route for some, if not all, of their production – certainly where the volumes don't justify the expense of the alternatives. And that could be a smart move for them – and for others selecting the National Small Series approach.

Why? Because, by a quirk apparently of parliamentary time and DfT (Department for Transport) oversight, both the NSSTA and IVA type approvals are governed in the UK by Statutory Instrument 2009/717. That calls up the relevant European directives for systems to be approved, but using regulations frozen in 2009 and not likely to be updated anytime soon.

What does that mean? It means that converters and OEMs using these routes can, if they wish, use older technology vehicles. "For example, on emissions limits, for Normal IVA and NSSTA there was a phased transition to Euro 5, which is currently applicable until 2016," explains Soper. "And electronic stability control, which is mandated in ECWVTA legislation, is not a requirement in NSSTA or IVA." In practical terms, such nuances are unlikely to affect the vehicles operators' get – partly because they'll probably specify current safety systems, and partly they're unlikely to be able to get their hands on anything less.

However, for large manufacturers wanting to shift unsold stocks, this is a perfectly legal open door. No one is suggesting that OEMs perceiving a market in the UK for Euro 5 vehicles are likely to ramp-up manufacture of now obsolete ranges and pass them off under NSSTA – it simply wouldn't be practical or economic on capacity-limited production lines. And none are likely to risk their brand image. But expect to see multiple hundreds of old stock (single- and multi-stage) arriving at VOSA stations for IVA certification on the way to happy customers.

Type approval choices
ECWVTA (European Community Whole Vehicle Type Approval) is the mainstream approval route, formally and perpetually linking OEMs and bodybuilders, and requiring one-off vehicle testing and verification, as well as accreditation of production conformance and quality processes. Timeframes are six weeks to six months. Once approved, unlimited numbers of vehicles can be sold anywhere in Europe, without further testing.

NSSTA (National Small Series Type approval) is similar but, because 2009 regulations pertain in the UK, test reports are to those standards. Timeframes are still six weeks to six months. This approach makes sense for converters building 30—100 vehicles but they are only eligible for sale within the UK.

IVA (Individual Vehicle Approval) still follows type approval requirements, but with VOSA test stations inspecting each converted vehicle to the requirements of the IVA Manual, and referring to test reports on issues ranging from vehicle noise to fuel tanks, emissions, brakes, EMC and underrun protection. Current waiting times for VOSA are six to eight weeks. This route is aimed at converters building 20—50 vehicles. Again, once approved, each can only be sold in the UK.

Time to review
For operators that have always bought a particular box body, tipper, emergency vehicle or specialist semi-trailer, it's time to ask, do you really need that precise specification? As Tony Hopkins, the SMMT's (society of Motor Manufacturers and Traders) technical manager responsible for type approval, puts it: "You will probably be able to get exactly what you've always had, but it's going to cost you. If it's not already covered in the converter's range, he'll need additional type approval – probably using the IVA route unless the order involves serious numbers."

For bodybuilders, it's crunch time, with the SMMT and others urging rapid action to get their houses in order. That means not only liaising with preferred vehicle OEMs and the VCA, getting quality systems and build plans in place and documented, but also considering preferred type approval paths. For those going the ECWVTA or NSSTA route, Hopkins suggests a timeframe of six to nine months – which takes them right up to the wire.

Andy Mair, the FTA's head of engineering, agrees: "The concern is that SMEs may not have to have got contracts and quality systems in place, in line with the WVTA requirements. That could mean problems for them but also the end users, who may suffer significant delays. If they can't get a whole vehicle certificate of conformity, then it won't be registered."

Hopkins also advises working on variants and versions. "Don't nail yourself down too much: within the type approval rules there is room for some flexibility, so give some thought to what your customers are likely to want... Spend some time with fleet buyers and dealers. That will save you a lot of money [on type approval extensions] in the long run."

Mair adds that operators and converters should also know that there is provision for derogations under the new type approval rules. "Where it can be demonstrated that a requirement is incompatible with the operation or use of the vehicle, then there is some flexibility. This is not about specific exemptions, as it used to be. It's a case-by-case situation."

Author
Brian Tinham

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