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Is Finite Element Analysis (FEA) conducted in-house by a TB manufacturer an acceptable ADR62 (eg. drawbar) evidence for TB approval application?

ADR 62 allows for approved calculations to be used.  A calculation using an ā€œapproved calculationā€ doesnā€™t need to be from an approved testing facility.  However, it must be noted that an ā€œapproved calculationā€ is processed through the component type approval (CTA) pathway, and not through the vehicle type approval (VTA) pathway.  A calculation is acceptable within a VTA application where the calculation (ie. FEA model) that is used is an ā€œapproved calculationā€.  If the FEA model has been approved by the Department, it would be appropriate for the FEA model (approved calculation) to be used for similar designs for confirmation of compliance with ADR 62/02, drawbar strength.

Note: If the FEA model has not been approved by the Department, there would need to be testing by an approved testing facility to validate the assumptions (engineering principles and methodology used) in the model when applying for a component type approval.

Furthermore, drawbar safety chain attachment point has no provision for an ā€˜approved calculationā€™, hence testing from an approved testing facility is required.