Different manners of type approval: UK21/G023
Adopted EU recommendation GEN-047. UK approved recommendation on the correct methods of type approval.
Question
The Merchant Shipping (Marine Equipment) Regulations 2016 as amended Schedule 2, Part 1, paragraph 2 states:
United Kingdom type-examination may be carried out in either of the following ways—
(a)examination of a specimen, representative of the production envisaged, of the complete product (production type);
(b)assessment of the adequacy of the technical design of the marine equipment through examination of the technical documentation and supporting evidence referred to in paragraph 3, plus examination of specimens, representative of the production envisaged, of one or more critical parts of the product (combination of production type and design type).
What is the intention of allowing type examination in the different manners? To which items can it be applied? Is the alternative procedure only applicable in the absence of clear guidance by the testing standard? Does it apply only apply to products which are modified in parts?
Recommendation
All new products should be assessed in their entirety and appropriate assessment and full type testing carried out on the complete physical product as a representative production sample.
Where an existing type approved product is modified or component parts and / or materials are changed, the complete modified product should be reassessed and the level of re-testing to be carried out should be agreed with the Approved Body. Depending on the level and type of modification, this may require partial or full re-testing of the complete product.
Only in cases where there is a modification to an existing type approved product that clearly will not affect the functional performance or operation of the product, or may improve it, should it be considered that assessment of technical documentation only may suffice.
In any case module B certificate should be reissued.
References
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MSN 1874 as amended
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The Merchant Shipping (Marine Equipment) Regulations 2016 as amended
Items affected
- All
More information
Maritime and Coastguard Agency
Bay 2/21
Spring Place
105 Commercial Road
Southampton
SO15 1EG
Telephone: +44 (0) 203 817 2000
Email: MEQA@mcga.gov.uk
Website: www.gov.uk/mca