CIRCULAR 0-13-1
CONFORMITY OF PRODUCTION
Introduction
1.
Conformity
of Production (COP) audits are intended to assure the Administrator of Vehicle
Standards (the Administrator) that Licensees holding Identification Plate
Approval (IPA) only supply vehicles to the Australian market that comply with
the applicable Australian Design Rules (ADRs) and conform with the approved
design.
2.
IPAs
generally demonstrate compliance with the ADRs by testing pre-production or
early production samples of a vehicle model or its components. However, the design typically evolves
throughout the life of the vehicle model.
To be assured that all production vehicles comply, the following three
types of COP audit are conducted:
(i)
Test Facility Inspection: to confirm that the design level of the
components or systems tested to the ADRs is known, and confirm the validity of
the test procedures and results of the tests.
(ii)
Design Facility Audit: to confirm the design of the components or
systems relevant to the ADRs and the internal review of their design.
(iii)
Production Facility Audit: to confirm the design level of components
or systems relevant to the ADRs used on the production line, as well as the
general control over the production processes, so that only vehicles built to
the approved design are fitted with Identification Plates.
Quality System
Documentation
3.
Each
Licensee holding an IPA is required to maintain Quality System Documentation
(QSD). This may take the form of a
quality assurance manual, a quality plan or other relevant documents. The documentation must enable the
Administrator to determine the adequacy of the quality assurance system. This is to ensure that Identification Plates
are only fitted to vehicles that comply with the applicable ADRs and conform
with the approved design. This includes
the control of design changes.
4.
The
Administrator does not seek to impose any particular quality assurance system
on a Licensee, but the system adopted must be properly implemented and
effective. However, the COP audits are
based on the ISO 9000 ; Quality Management Systems.
COP Audit Planning
5.
Consistent
with section 9 of the Motor Vehicle
Standards Act 1989, any Licensee holding an IPA may be subject to an audit.
A risk rating is allocated to each production plant that is based on sales
volumes, previous audit performance, safety related recall incidents and any other
intelligence. The rating is reviewed at least once each year. The frequency of audits may vary between one
and five years, depending on the rating of the plant. A Licensee will generally not be scheduled for
more than one COP audit in a calendar year for each ADR vehicle category.
6.
The
information gathered from a Test Facility Inspection is referenced during the
Design Facility Audit and is then confirmed at the Production Facility
Audit. Where a test facility or design
facility has not been visited, the information will be requested from the
Licensee beforehand to refer to during the Production Facility Audit.
7.
A COP
audit of a major production facility is generally completed by a team of two
officers in two to three working days, depending on the size of the facility. Smaller
facilities (such as many trailer manufacturers) are normally audited in a
single day.
8.
Overseas
government authorities, acting as agents of the Administrator, may be used to
perform audits in countries such as
COP Audit Notification
9.
Notifications
for Test Facility Inspections are sent only to the Licensee. The Licensee
should then notify the test facility, which may be in-house or an outsourced
test facility.
10.
Notifications
will be provided a minimum of six weeks before the proposed date of the audit
and will contain details of the vehicle make, model and the ADRs to be audited.
11.
Where a
notification has been given for a Production Facility Audit, the Licensee is
required to submit a completed Variant Evidence Matrix (refer Attachment 1) for
the selected vehicle model and ADRs within two weeks of receiving the
notification.
12.
Test
Facility Inspections are generally based on a maximum of two ADRs. However, if any matters of a certification
and/or safety related nature arise during the audit, these may also be included
in the final assessment. This is required to ensure that evidence of compliance
has been submitted for all of the variants capable of being supplied to the
Australian market, and that the supplied variants are listed on the approved
Road Vehicle Descriptor (RVD). The Variant Evidence Matrix is designed to show
all the variants capable of being supplied to
13.
Production
Facility Audits and Design Facility Audits are generally based on one vehicle
model and a maximum of three ADRs for passenger cars, trucks and four-wheel
drive vehicles. For motorcycles and
buses, these are generally based on one vehicle model and all applicable
ADRs.
Facility Assessment
Test
Facility Inspection
14.
The
auditors confirm that the design level of the components or systems tested is
known and that this agrees with certification information provided in
previously submitted Summary of Evidence (SE) form(s). They also confirm that the test personnel
have appropriate levels of knowledge, skill and training, the test equipment is
suitable for the test and accurate test records are kept. The requirements are further detailed in the
0-12 series of Adiministrator’s Circulars.
Design
Facility Audit
15.
The
auditors confirm that:
(i)
The
tested design conforms with the engineering drawings;
(ii)
The
design has been controlled so that any changes made since testing continue to
comply with the ADRs and (if applicable) have been included in the approved
design; and
(iii)
All
variants in production for the Australian market are covered by the approved
design (Note: This may be carried out at the production facility where
appropriate).
The principal areas to be covered will be
Engineering and Certification and at least include (where applicable):
a)
Criteria
for the selection of test vehicles and components with respect to relevant
Administrator’s Circular guidelines;
b)
Engineering
Change Notification (ECN) history for components from the test date to the
present;
c)
Document
control procedures, especially revisions.
Production Facility Audit
16.
The auditors
confirm that:
(i)
Components
used in production are at the correct design level;
(ii)
The
correct components are used for each variant/option and only vehicles built to
approved designs are supplied to the Australian market.
This involves detailed examination of
procedures and records to confirm that quality procedures are being followed
throughout all manufacturing processes.
The principal areas to be covered will at least include (where
applicable):
a)
Quality
Management – organisation chart and position responsibilities, management
review, external quality audit reports;
b)
Internal
Audits – audit schedule plan, audit reports and satisfactory closure of
corrective action requests;
c)
Field
Service Feedback and Recall – ADR related feedback from vehicles supplied,
issues resolution, service records;
d)
Purchasing
– purchase orders confirming design level ordered;
e)
Supplier
Quality Control – supplier rating records for critical ADR parts, supplier
audit records and countermeasure reports, control of design to/from suppliers;
f)
Production
planning and control – broadcast sheets, check of vehicles able to be supplied
to
g)
Manufacturing
Engineering – welding parameters, torque control specifications;
h)
Production
Shop Floor – torque check and tool identification recorded for ADR-critical
joints, welding parameters, control of non-conforming product, parts
identification against broadcast sheet, body shop for passenger cars;
i)
Final
Inspection – stage inspection records, on line storage and identification,
control procedures, 3D body dimension check, final inspection records for
vehicles built, testing area check, identification plate location, ADR parts
checklist;
j)
Material
Stores – goods receiving, reject stores, segregation of reject material, store
location check for ADR parts, inspection parts flagging; and
k)
Tool
and Gauge Calibration – calibration records for tools identified on shop floor,
traceability of calibration records.
If the facility is certified to ISO 9000 ;
Quality Management Systems, or equivalent Australian Standards, Quality
Management and Internal Audit areas of the company may not be audited.
Where appropriate, some of these items may
be checked at a design facility audit.
Conduct of the COP Audit
and Audit Reporting
17.
During
the opening meeting, the lead auditor will introduce the audit team and briefly
confirm the purpose of the audit, explain its basis and the ADRs to be audited,
as well as finalise the schedule.
18.
Formal
presentations by facility personnel must be kept to a minimum, with the audit
taking place in an area agreed by both auditors and facility personnel. Any
findings will be discussed with the facility personnel at the time they are
noted.
19.
At the
end of each day the auditors will hold a brief summary meeting with the
facility’s nominated representative, to report on any Corrective Action
Requests (CARs) that have been raised during the day.
20.
A
written report is presented at the closing meeting. It details the areas audited, procedures and
records examined in each area and a list of any CARs that have been
raised. Understanding of the report’s
content is acknowledged by the facility representative countersigning the
report. Any disputed issues will be
noted as such in the report.
21.
The
written report will recommend to the Administrator whether the audit was
generally satisfactory or was unsatisfactory.
This depends on the number and significance of any CARs.
22.
For a
generally satisfactory report, the facility is requested to address any CARs
within six weeks. There must be a robust
action plan made within this period to address the CARs. The facility must submit objective evidence
of the corrective action taken for satisfactory CAR closure. In addressing the CARs, the facility should
look beyond correction of the immediate issue, to any broader aspect which allowed
it to arise in the first place or may permit it to occur again.
23.
For an
unsatisfactory report, the Administrator will consider the circumstances and
decide on an appropriate course of action.
This action may be to vary the IPA by imposing additional conditions
(e.g. third party inspection) or to suspend or cancel the IPA. Depending on the significance of the issues
raised, the intention is usually to allow the facility time to take corrective
action and continue operating while the corrective action is put into place.
24.
Upon
receipt of satisfactory evidence addressing all the CARs, the audit will be
closed and the Licensee and/or facility advised within six weeks.
Other COP Measures,
Conformance Testing
25.
Any COP
assessment involving lighting ADRs will allow for the use of United Nations Economic
Commission for Europe (UNECE) COP sampling criteria where conformity is
demonstrated by photometric testing.
26.
At the
discretion of the Administrator, other methods may be used to confirm the
ongoing compliance of vehicles.
27.
Vehicles
or components may be acquired through normal commercial channels and
independently tested for compliance with specific ADRs. Any such testing uses ADR test procedures and
is supervised by the Administrator or appointed agents. The vehicle/component manufacturer may be invited
to attend the tests as an observer.
28.
Component
specification checks may also be performed on randomly selected new vehicles or
during the course of a Single Uniform Type Inspection (vehicle inspection).
29.
The
Administrator may request information such as test reports at any time during
or after certification.
Attachment 1
Variant Evidence Matrix
(Sample; refer clause 12 on
page 2)
|
Equipment |
Options |
Variant 1 name |
Variant 2 name |
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|
RVD
Reference |
|
|
|
||||
|
Marketing
Designation (optional) |
|
|
|
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|
Vehicle
Dimensions |
Length
mm |
|
|
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|
Width
mm |
|
|
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|
Height
mm |
|
|
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|
Wheelbase
mm |
|
|
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|
Engine
& Transmission |
Engine,
T/m, Muffler and exhaust Package
1 |
Std/Opt/ NA |
SE
79 |
|
Std/Opt/ |
SE
79 |
|
|
SE
81 |
|
SE
81 |
|
||||
|
SE
83 |
|
SE
83 |
|
||||
|
|
Wheel
(tyre/wheel rim designation) Package 1 |
Std/Opt/ |
SE
23 |
|
Std/Opt/ |
SE
23 |
|
|
Front/ |
Front/ |
|
|||||
|
Mirrors |
External
Mirrors LH/RH |
Std/Opt/ |
SE
14 |
|
Std/Opt/ |
SE
14 |
|
|
Internal
Mirror |
Std/Opt/ |
SE
14 |
|
Std/Opt/ |
SE
14 |
|
|
|
Glass |
Standard
glass Windscreen/ |
Std/Opt/ |
SE
8 |
|
Std/Opt/ |
SE
8 |
|
|
Seats
& Seatbelts |
Front
Package 1 |
Std/Opt/ |
SE
3 |
|
Std/Opt/ |
SE
3 |
|
|
SE
4 |
|
SE
4 |
|
||||
|
SE 5 |
|
SE 5 |
|
||||
|
Rear Package 1 |
Std/Opt/ |
SE 3 |
|
Std/Opt/NA |
SE 3 |
|
|
|
SE 4 |
|
SE 4 |
|
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|
SE 5 |
|
SE 5 |
|
||||
|
Airbags |
Front Package 1 |
Std/Opt/ |
SE
73 |
|
Std/Opt/NA |
SE
73 |
|
|
Side/curtain/ |
Std/Opt/ |
SE
72 |
|
Std/Opt/NA |
SE
72 |
|
|
|
Brakes |
Unique
Braking System Package 1 ABS
y/n;front/rear |
Std/Opt/ |
SE 31 |
|
Std/Opt/NA |
SE31 |
|
|
SE 35 |
|
SE 35 |
|
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