Conformity of Production
A key element of being eligible to obtain Vehicle Type Approvals (including Low ATM Trailers) and Component Type Approvals will be in your ability to prove, you need to have either:
- full control over all stages of the design, componentry and manufacturing process for the type of road vehicle or road vehicle component, or
- access to information, including information about any changes, relating to the design, componentry and manufacture of the type of road vehicle or road vehicle component that may affect its compliance with the applicable national road vehicle standards.
If you indicate you have full control, you will need to have some form of Quality Management System (QMS) in place to demonstrate that you have effective control on Conformity of Production.
For Low ATM Trailers, vehicle type approval applicants must keep their supporting information and all relevant documents up to date to satisfy eligibility criteria. An appropriate QMS shall demonstrate full control of the design, componentry and manufacturing process. More information on QMS is available in Appendix 2 and Appendix 3of the Guide to Vehicle Type Approval for Low ATM Trailers.
To assist Recreational Vehicle businesses in preparing their QMS, Caravan Industry of Association of Australia has developed a Quality Management System Checklist. This Checklist is based upon the requirements outlined in the Appendix 2 and 3 of the Guide to Vehicle Type Approval (or Guide to Vehicle Type Approval for Low ATM Trailers). Download the checklist HERE.
For more information about the requirements head to the Quality Management System.
What is Conformity of Production?
You can think of Conformity of Production and a Quality Management System as being asked to put together a Caravan Cake Cookbook containing a series of recipes. It may well be that the “recipes” have been the same for years and handed down from generation to generation, but now you need to turn those traditional recipes (often not well documented) into a professional and comprehensive Cookbook.
The recipes within Caravan Cookbook should contain enough detailed information (ingredients lists and quantities, method etc.) so that anyone can pick up the Cookbook and make a Caravan Cake which turns out the same EVERY time.
In order to get the Cookbook published, you will need to ensure that your key “ingredients” are “approved” and come from a reputable supermarket and ensure that your “method’ contains all the required steps and information needed for anyone to make the Caravan Cake.
Manufacturers and Importers of Recreational Vehicles are required to ensure every Recreational Vehicle they supply to market complies with the relevant Australian Design Rules (ADRs) and other regulations. To ensure every Recreational Vehicle produced consistently conforms with these mandatory regulations, manufacturers and importers need to have an effective system in place to control and document all stages of the design and manufacturing process.
Compliance with the ADRs is usually initially demonstrated by testing pre-production or early production samples of Recreational Vehicles. However, it is typical for the design to evolve throughout the life of the model. With this in mind, the Recreational Vehicle Manufacturer or Importer needs to have a system in place to control these processes.
As an RVSA approval holder, you may be subjected to a federal regulator Conformity of Production (COP) audit at any time. Failure to demonstrate that you have effective control of your processes (or access to information, including information about any changes, relating to the design, componentry and manufacture of the type of road vehicle or road vehicle component) may result in your approval being suspended or cancelled – meaning you can no longer supply Recreational Vehicles to market.
Who does it apply to?
If you manufacture or import Recreational Vehicles, to be eligible for an approval under the Road Vehicle Standards Act (RVSA), you must be able to prove you have sufficient control, or access to information, over all stages of the design, componentry and manufacturing process for the type of road vehicle or road vehicle component.
Furthermore, if you manufacture/import/ supply road vehicle (or trailer) components, to be eligible for a Component Type Approval (CTA) under the RVSA you will need to prove you have some form of Quality Management System (QMS) in place to demonstrate that you have effective control on Conformity of Production.
Why is it important?
You will not be able to obtain a vehicle (or trailer) and component type approval under the RVSA unless you can demonstrate that you have effective control on Conformity of Production. This means you have effective control (or access to information) over all stages of design, componentry, and manufacture of the recreational vehicle and component you are producing or supplying through some form of Quality Management System (QMS).
In addition, there are many other benefits to implementing an effective Quality Management System such as improved efficiency, reduced re-work costs, lower warranty rates/claims and improved customer satisfaction – just to name a few.
Conformity of Production & RVMAP
To further strengthen the Recreational Vehicle Manufacturing Accreditation Program (RVMAP), Accredited businesses moving forward must be able to demonstrate they have some form of Quality Management System in place.
To align with RVSA, the RVMAP Licence Agreement (which every accredited business must agree to) has been amended with a Conformity of Production/ Quality Management System requirement.