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REGULATIONS SVA/IVA

IVA To Be The New SVA With SVA to become IVA in 2009, are we looking at a simple name change or something with greater implications for the kit car enthusiast? CKC talks to VOSA and reveals all. IF YOU’RE AN active member of a kit car club, or simply a regular visitor to websites such as Pistonheads, then you may have heard about some proposed changes to Single Vehicle Approval (SVA). The SVA scheme allows for both amateur built and low volume cars to be assessed and subsequently registered in the UK without the need to meet the EC Whole Vehicle Type Approval standards which apply to mainstream manufacturers such as Ford and Jaguar. From what you may have heard or read, there appear to be conflicting views over what the changes mean for our industry. We have spoken to VOSA (Vehicle & Operator Services Agency), the agency within the Department for Transport which is responsible for implementing the changes to the SVA scheme, to give you the definitive answer.

SVA continues as is until April of 2009. Even then, the changes appear small and will still be undertaken at existing SVA test stations.

WHY THE CHANGE?

BACKGROUND SVA exists because of a section within the European Parliament’s original Framework Directive document which allows for member states to establish alternative Type Approval systems for different levels of low volume vehicles – for instance, small runs of factory assembled vehicles (the likes of Morgan may fall into this) or one-offs and cars built from a manufactured package (conventional kit cars). Single Vehicle Approval is a UK

specific response to the Framework Directive which allows the likes of you and me to build a car at home which does not have to meet the stringent tests applied to the likes of Ford in the shape of EC Whole Vehicle Type Approval. Last year, the European Parliament released details of a Recast Framework Directive 2007/46EC (RFD) and it is as a consequence of this that SVA in the UK is in the process of being rejigged to become Individual Vehicle Approvals (IVA).

Changes to SVA appear small. Perhaps most significant (in terms of cost) is the enforcement of a reverse gear. For bikeengined kits, this will mean the purchase of an aftermarket reverse gear, such as that available from Quaife.

CKC: Is there a reason why the change is occurring? VOSA: These changes are being made following the implementation of the RFD. This new European directive mandates some significant changes to the current Type Approval framework for passenger cars and will extend in scope to include trucks, trailers and buses from key dates between April 2009 and 2014. The good news for the kit car industry is that the directive does allow for national approval schemes, which means that member states can continue to allow registration of vehicles as long as they satisfy the national requirements. The UK DfT will continue to support a national scheme, however it should be noted that some changes must be made to bring the scheme up to date and ensure it is fit for purpose.

VORSOVAED

APP RT REPO

WHEN IS IT HAPPENING? CKC: When exactly does SVA become IVA? VOSA: The Recast Framework Directive 2007/46EC (RFD) comes into force on the 29th of April 2009 with M1 passenger cars being the first group of vehicles to be affected. This means that SVA will cease for M1 passenger cars and IVA will take over. N1 goods vehicles continue to fall under the SVA scheme until October 2011 as the RFD does not mandate these vehicles until then.

HOW BIG ARE THE CHANGES? CKC: Our understanding is that the changes will be nominal for amateur builds. Is this correct? VOSA: The most important point to make is that for amateur builds, presenters will continue to be able to prove compliance by way of a physical inspection by VOSA examiners without the need for documentary evidence, model or test reports. The IVA inspection will include up to 60 test areas, not all of which apply to all vehicle categories. For kit cars there will be approximately 42 test areas, many of which are identical to the 24 areas covered by SVA, but with some new items not previously included.

EXAMPLE CHANGES CKC: Can you give us some examples of the proposed changes? VOSA: Some examples of the new items are: The introduction of a check that a horn is fitted and works A check that sufficient space has been allowed for the fitment of a rear registration plate A check to confirm the presence and operation of a reverse gear or similar device A check on the identification of controls and driver information systems (tell tales, warning symbols etc) 20

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All instrumentation should be clearly marked. Not sure that masking tape and pen are suitable!

A check on towing coupling (where fitted) A check that front head restraints (or high-backed seats) are fitted A check that a VIN number is stamped on the chassis and on a plate. (As today, the VIN number can be allocated by DVLA)

CHANGES FOR TURNKEY AND NEW BUILDS CKC: We’re led to believe that it’s in the Cat C and Cat L sections of SVA where the most significant changes are likely to occur. Is that true? If so, in what way? VOSA: The 2008 approval regulations are about to go out to consultation. We’re not aware of any changes to these categories of vehicles. CKC: It has been suggested that the changes are there to stop companies building kit cars professionally, yet going through SVA as amateur builds. Is this true and, if so, what measures will be in place to stop this happening in the future? VOSA: The only reason for any changes to SVA is due to the mandatory

implementation of the RFD which extends the scope of EC Type Approval as well as each member State’s national approval scheme.

THE FUTURE CKC: Is the future of IVA/SVA secure? Obviously, a whole industry (and wider industry beyond that, such as ourselves) survives because of the UK’s ability to establish a low volume and individual vehicle system of approval. This is able to exist within the wording of the Recast Framework Directive from the European Parliament. How often is this amended? I appreciate this last question is hardly a simple one to answer, but an overview of where we’re going would be great. VOSA: The RFD comes into force on the 29th of April 2009, extending the scope of type approval for passenger cars. From this date until 2014 trucks, trailers and buses also fall into the scheme, therefore having a large impact on all sections of the automotive industry. As individual directives evolve and are changed over time the RFD will also change to reflect this. Any changes planned for the national

If you’re new to kit cars... read on IF YOU’VE NEVER heard of SVA before and have no idea what we’re talking about, here’s our beginners’ guide... Before the likes of Ford and Vauxhall can launch a new car, they have to put it through EC Whole Vehicle Type Aproval. This is a hugely complex and monstrously expensive exercise, so the European Parliament has said that EU countries can also establish lesser forms of Type Approval for smaller runs of car. In the UK we therefore have Low Volume Type Approval and Single Vehicle Approval (SVA). It’s SVA that’s most relevant to us. So you’ve built your kit car and it’s ready to go. First, the car must be presented for an SVA test, where various

aspects of its design and build are assessed. If your car passes the test, then you can move onto getting it registered, which will result in you being issued with a Q-plate, age-related plate or brand new plate, depending on the kit and the components used in its construction. If you fail SVA you can always retake it and we’ve found SVA inspectors to be fair and helpful. Your kit manufacturer should also be able to provide you with guidance and the kit itself should be manufactured in such a way that it complies with the regulations. SVA is a good safety net for the kit car industry, ensuring a base standard is maintained. Above all, don’t let the bureaucracy get in the way of enjoying your kit car.

MAY 2008

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JARGON BUSTER... It’s easy to get confused by all the different terminology and the different agencies involved with SVA. Here’s our jargon-busting guide... DfT – Department for Transport. Deals with air, sea, road and rail needs in the UK. VOSA – Vehicle & Operator Services Agency. An executive agency within the DfT. The result of a merger of the Vehicle Inspectorate (VI) and the Traffic Area Network division of the DfT. VOSA provides a range of licensing, testing and enforcement services. DVLA – Driver and Vehicle Licensing Authority. Another executive agency of the DfT. Deals with vehicle registration and collection of road tax. SVA categories – Category A is for amateur built cars built at home. Cat C and L are for those kit cars built by commercial businesses. Other categories are for personal imports (P), rebuilt vehicles (S), armoured vehicles (T) and various others. DfT categories – You will sometimes hear the term Category M vehicles. This is the DfT category for vehicles with four wheels and designed to carry passengers. There are then sub categories such as M1 (for vehicles with more than 8 seats). RFD – Recast Framework Directive. The latest document by the European Parliament and Council on the approval of cars etc. It’s this document that sets out EC Whole Vehicle Type Approval and which allows for member states to implement their own Individual Approval schemes – SVA in the UK. VOSA will implement and apply the RFD in the UK.

schemes will take time to implement and would involve a degree of consultation. The progress and status of the RFD can be monitored at the EC website.

CONCLUSIONS... Let’s not get too hung up with the name change. In 2009 Single Vehicle Approval will become known as Individual Vehicle Approvals. There’s perhaps a logical reason for the name change. Within the RFD it has only ever made reference to ‘Individual Approvals’, so perhaps it’s logical to bring the UK’s answer to this level of approval (SVA) into line with the terminology used in the wider ranging EU document. For the kit cars you build at home in your garage (and which therefore fall into Category A of the SVA test for vehicles which are amateur built), our answers from VOSA would certainly suggest that while there will inevitably be changes, we are unlikely to come across anything that will pose a serious threat to the future of the industry. Most significantly, the RFD specifically allows for member states to continue with Individual Vehicle Approval schemes. As the final document is still being constructed, it’s difficult to be definitive, but as our VOSA responses here state, there will be a period of consultation.


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REGULATIONS SVA/IVA CARS BUILT FOR YOU

It’s worth pointing out that these regs for professionally assembled cars are not new and have nothing to do with the impending IVA. They’ve always been in place since SVA was launched in 1998. It’s just that businesses offering such a build service using non compliant engines have put cars through SVA under the pretence that they are amateur built.

This is an increasingly popular route to kit car ownership, whereby owners get a manufacturer, official build agent or independent build company to assemble a car for them. While VOSA has stated that IVA offers no new regulations to tighten up on this area, it is important that you understand the existing requirements for such cars – an area where there has been a degree of misunderstanding/abuse in the past. Here’s our summary of the requirements... Cars built for you by a professional company or which are assembled using all new components should not be put through a Category A SVA test for cars which are amateur built. Instead, they should undergo a Category C or L SVA. With both Category C and L tests, the big difference is in the emissions test requirement and subsequent registration. Category C SVA: For a vehicle assembled by a business using parts from a vehicle previously registered in the UK. Significantly, the engine must be retained, along with at least one other major component. The emissions test will be based on the age of the engine and an age-related registration number will be allocated. Category L SVA: For cars built by a business using all new components. Most significantly, the engine should be brand new and comply with current emissions standards. The car will receive a brand new registration number.

SUMMARY

Last year we followed Ian Kelly through his SVA test, which he passed at the second attempt. His bike-engined Fury did not have a reverse gear, which would be required for IVA in 2009. Otherwise we don’t see any significant problems.

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The implementation of SVA in 1998 did not, as some people suggested it might, kill off the kit car industry. To the contrary, those companies operating within our scene must now meet a recognised standard that should give any potential kit car customer (and that’s you) a level of confidence that what they are building is safe. That can only be a good thing. And even we had our fears that SVA might see an end to one-off specials and the other quirky cars that have given this scene an intriguing edge in the past. But you only have to read the story we ran on Richard Brabbins’ extraordinary one-off in last month’s magazine to realise that it’s still quite possible to go your own way when it comes to building something personal. It would be naïve of us to have expected SVA to stay in its original format forever, and the move to IVA in 2009 is perhaps the first more significant tweak we’ve witnessed since SVA came into force in 1998. The industry has grown up enormously since then, and it would certainly appear that nothing within IVA will threaten that future. Keep on enjoying kit cars. 

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MAY 2008

USEFUL CONTACTS You will find most information is now pooled on the following government website... www.direct.gov.uk For IVA information www.dft.gov.uk/pgr/roads/vehicles/sectio necwholevehicletype/ For registration www.direct.gov.uk/en/Motoring/BuyingA ndSellingAVehicle/RegisteringAVehicle/D G_4022486 For DVLA Local Office directory www.direct.gov.uk/en/Dl1/Directories/Us efulContactsByCategory/MotoringContac ts/DG_10012974 For SVA testing stations www.direct.gov.uk/en/Dl1/Directories/Us efulContactsByCategory/MotoringContac ts/DG_10012449 For VOSA head office Berkeley House, Croydon Street, Bristol BS5 0DA. T: 0870 606 0440 W: www.vosa.gov.uk E: enquiries@vosa.gov.uk To buy an SVA manual www.vosa.gov.uk/vosacorp/publications/ manualsandguides/vehicletestingmanua lsandguides.htm T: 0870 60 60 440


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IVA UPDATE April 29th 2009

IVA – IT’S ALL IN THE NAME CKC Editor, Ian Stent was invited to the VOSA headquarters in Bristol to find out more about the impending arrival of IVA, which replaces the existing SVA test for newly built kits. SINGLE VEHICLE APPROVAL was introduced in the UK in 1998. It was met with much trepidation by both manufacturers and kit car enthusiasts and represented the biggest single change to the way we could get our cars on the road after we’d built them since, well... ages ago! But while SVA can certainly be a daunting hurdle for the home builder, we’ve now become accustomed to it and realise that it’s a completely achievable stage in the build process and something that manufacturers can assist and advise on. On April 29th 2009 Single Vehicle Approval will be replaced with Individual Vehicle Approval.

Stent scans through a draft version of the new IVA Inspection Manual. It’ll be accompanied by an IVA guide book, too.

Both Wilkins’ Sylva Riot and our Adrenaline Murtaya have both passed SVA recently. The Murtaya took Stent to his meeting with the men from VOSA’s

MYTHS & CONFUSION

The agency originally responsible for implementing SVA is the Vehicle & Operator Services Agency (VOSA). An executive agency of the Department for Transport, it has been charged with interpreting the new Recast Framework Directive (and subsequent National Requirements Document) for the purposes of amateur built, low volume, imported and any other vehicle which doesn’t immediately fall under the remit of EC Whole Vehicle Type Approval. From April 2009 under IVA, VOSA will be working on behalf of the UK Approval Authority, the Vehicle Certification Agency (VCA).

Not surprisingly, any change to SVA rings warning bells within our industry, but even we’ve been taken aback by some of the mis-information doing the rounds on internet forums, club newsletters or simply regurgitated to us on the phone by worried enthusiasts. I suspect some of that confusion may arise from the subtle reclassification of Enhanced SVA to Normal IVA and Standard SVA to Basic IVA. If you were to look at Normal IVA (aimed at the professional import market) and try to apply that to kit cars then you might get a fright – there is considerable onus on importers to provide approval documentation with regards to silencing and many other areas. So what are the implications of BIVA?

SVA/IVA

IVA CHANGES

SVA is currently implemented in two main tiers. Enhanced SVA is a more onerous test for the likes of imported vehicles, while Standard SVA is applicable to kit cars (there are then further subdivisions, such as MSVA for motorcycles and threewheelers under 450kg). IVA will also be split into two main tiers – Normal IVA (NIVA) for the likes of professionally imported vehicles and Basic IVA (BIVA) for kit cars, motor caravans etc.

When Complete Kit Car first looked at the IVA proposals back in our May 2008 issue, we outlined some of the areas likely to see some changes and there was one over-riding feature of all of these – they were all minor tweaks rather than fundamental alterations. Now that the regulations have been firmed up and a brand new IVA Inspection Manual produced, I’m very pleased to say that the same is true now.

VOSA

BACKGROUND SVA exists because of a section within the European Parliament’s original Framework Directive document which allows for member states to establish alternative Type Approval systems for different levels of low volume vehicles – for instance, small runs of factory assembled vehicles (the likes of Morgan may fall into this) or one-offs and cars built from a manufactured package (conventional kit cars). Single Vehicle Approval is a UK specific response to the Framework Directive which allows the likes of you and me to build a car at home which does not have to meet the stringent tests applied to the likes of Ford in the shape of EC Whole Vehicle Type Approval.

In 2007, the European Parliament released details of a Recast Framework Directive 2007/46EC (RFD) and it is as a consequence of this that SVA in the UK has been rejigged to become Individual Vehicle Approvals (IVA).

head office in Bristol.

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If you’re new to kit cars... read on IF YOU’VE NEVER heard of SVA before and have no idea what we’re talking about, here’s our beginners’ guide... Before the likes of Ford and Vauxhall can launch a new car, they have to put it through EC Whole Vehicle Type Approval. This is a hugely complex and monstrously expensive exercise, so the European Parliament has said that EU countries can also establish lesser forms of Type Approval for smaller runs of car. In the UK we therefore have Low Volume Type Approval and Single Vehicle Approval (SVA). It’s SVA that’s most relevant to us. So you’ve built your kit car and it’s ready to go. First, the car must be presented for an SVA test, where various In short, most of the changes have been to the small print, with many items merely clarifying areas previously left open to interpretation. Let me give you an example... Dash warning lights – there must now be telltale warning lights on the dash for a number of items, such as indicators, dipped and main beam. In some instances this was not mandatory for SVA, but has been made mandatory for IVA. So here’s a pretty typical example of the changes to BIVA when compared to SVA. The following is a brief list of the main sections within SVA/IVA and a short description of any changes. It’s not comprehensive, but will hopefully cover the fundamentals...

NOISE

aspects of its design and build are assessed. If your car passes the test, then you can move onto getting it registered, which will result in you being issued with a Q-plate, age-related plate or brand new plate, depending on the kit and the components used in its construction. If you fail SVA you can always retake it and we’ve found SVA inspectors to be fair and helpful. Your kit manufacturer should also be able to provide you with guidance and the kit itself should be manufactured in such a way that it complies with the regulations. SVA is a good safety net for the kit car industry, ensuring a base standard is maintained. Above all, don’t let the bureaucracy get in the way of enjoying your kit car.

REAR REGISTRATION PLATE SPACE

EMC (RADIO INTERFERENCE SUPPRESSION) The requirements are the same as SVA.

DIESEL SMOKE The requirements are the same as SVA. (Note: this is covered by the general emissions section).

INTERIOR FITTINGS The requirements are the same as SVA except that a seat for a disabled person is not exempt. Also the standards now apply to all areas of the interior passenger compartment and not just the specified zone as was the case with SVA before.

ANTI-THEFT (ALARM OR IMMOBILISER OPTIONAL) The requirements for an anti-theft device are the same as SVA. If an optional alarm system or immobiliser is fitted it must comply with the relevant EC directive.

PROTECTIVE STEERING

This requires sufficient space to mount a plate that meets legal requirements, which include provisions for smaller plates on imported vehicles.

STEERING EFFORT For conventional manual or power assisted steering systems this item requires only basic safety checks for function and effort. EC Directive requirements apply for technologically advanced (Steer by wire) systems that can’t be checked by inspection alone.

DOOR LATCHES AND HINGES The requirements are the same as SVA.

AUDIBLE WARNING DEVICE (HORN)

The technical requirements are the same as SVA.

This item requires an adequate audible warning device to be fitted but it must not be a bell, gong or siren.

EMISSIONS

INDIRECT VISION (MIRRORS)

The technical requirements are the same as SVA, apart from the fact that the visual emissions criteria now only applies to rotary engines built prior to 1987, with date related metered emissions now being applied to all other engines fitted.

The technical provisions are based on EC directive requirements which have different fitting and field of view requirements to SVA. The main changes are the mandatory requirement for a nearside exterior mirror and field of view requirements covering a larger area. As a result of the larger field of view requirement, special provision is made for certain narrow bodied vehicles where the field of view is modified to allow for rear wheels and bodywork which may obstruct the view.

The requirements are the same as SVA but with changes to the permitted exemptions and modifications. For example where a disabled vehicle is fitted with controls that can easily be removed the vehicle is assessed as if the controls are not fitted.

SEAT STRENGTH Adjustable or folding seats shall have a locking mechanism, which for folding seats shall be easily accessible to a passenger sat immediately behind the seat concerned if necessary to exit the vehicle. Head restraints are a mandatory fitment on outboard front seats. Their minimum height is specified. For M1 vehicles, the strength of the seat back and its locking systems shall be assessed by inspection. The head restraint shall be energy absorbing.

EXTERIOR PROJECTIONS

FUEL TANKS This item incorporates fuel input and general construction requirements for fuel tanks the same as or equivalent to SVA. For plastic fuel tanks and fuel tanks for gaseous fuels (eg LPG) the fuel tanks must be Type Approved. In addition a vehicle must be designed to avoid excessive evaporative emissions eg with a tethered fuel cap to avoid the cap being lost and evaporation via the open fuel filler.

BRAKING The technical requirements are the same as SVA with the added requirement of a braking reaction time. JANUARY 2009

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Some requirements the same as SVA and some of the old SVA requirements have been replaced by reference to equivalent paragraphs of the EC Directive. The overall effect is much the same as SVA by ensuring that projections are suitably radiused, blunted, protected or designed so as not to be a hazard. Special provisions are included for original equipment badges and press stud fittings used on convertible vehicles. There are significant changes for open top vehicles where the interpretation of the interior/exterior boundry has been relaxed and any contactable items must meet the radius criteria irrespective of whether they are situated within the interior passenger compartment or on the exterior of the vehicle.


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IVA UPDATE April 29th 2009 SPEEDOMETER AND REVERSE GEAR

SEAT BELTS Seat belts are required to comply with the technical requirements of the relevant EC directive, which has the same effect as SVA. Provision is made for BS marked harness belts and for disabled persons’ belts.

Must be an automotive type speedometer. A speedometer accuracy check is required which is the same as SVA. Other requirements are specified by reference to the relevant EC directive and having the same requirements as SVA except for an additional graduation marking requirement on the speedometer and a check that an operational means of reversing the vehicle is provided. Markings will continue to be required in mph.

FORWARD VISION This item requires adequate view of the road ahead which is already part of SVA under the general construction requirements.

IDENTIFICATION OF CONTROLS PLATES (STATUTORY)

This requires controls to be marked in accordance with the relevant EC directive or at least to be clearly identified to avoid confusion.

This item requires a manufacturer’s plate and marking of the vehicle identification number based on the relevant EC directive.

DEMIST/DEFROST SEAT BELT ANCHORAGES

An adequate system is required. The details will be specified in the inspection manual but will be much the same as SVA.

This requires compliance with the technical provisions of the relevant EC directive in a later version to that specified in SVA. For cars the installation requirements are much the same as SVA and will be verified in the same way.

WASH/WIPE An adequate system is required. The details will be specified in the inspection manual but will be much the same as SVA.

INSTALLATION OF LIGHTING AND LIGHT SIGNALLING DEVICES The technical requirements are those of the relevant directive with some exceptions. The requirements are comparable to current regulations. Individual lighting devices are specified and, like SVA, Type Approved lamps are not required as long as they are of sufficient intensity (brightness). If gas discharge headlamps are fitted then automatic levelling and headlamp wash/wipe is required.

HEATING SYSTEMS (OPTIONAL)

Front seats must have a head restraint for IVA. One of the few more significant changes in the regulations which

This is an optional item but if fitted compliance with the technical requirements of the relevant EC directive is required. It is primarily intended for combustion heaters and heating systems that may pose a risk. Tests will not be required where water is used as the heat transfer system.

will particularly affect cars such as Cobra replicas, where lowback seats are the norm.

WHEEL GUARDS (MUDGUARDS) The vehicle must be provided with wheel guards, which may be part of the bodywork. The wheel guards must be

JARGON BUSTER... It’s easy to get confused by all the different terminology and the different agencies involved with SVA. Here’s our jargon-busting guide... DfT – Department for Transport. Deals with air, sea, road and rail needs in the UK. VOSA – Vehicle & Operator Services Agency. An executive agency within the DfT. VOSA provides a range of licensing, testing and enforcement services. DVLA – Driver and Vehicle Licensing Authority. Another executive agency of the DfT. Deals with vehicle registration and collection of road tax. SVA categories – Category A is for amateur built cars built at home. Cat C and L are for those kit cars built by commercial businesses. DfT categories – You will sometimes hear the term Category M vehicles. This is the DfT category for vehicles with four wheels and designed to carry passengers. There are then sub categories such as M1 (for vehicles with no more than 8 seats). RFD – Recast Framework Directive. The latest document by the European Parliament and Council on the approval of cars etc. It’s this document that sets out EC Whole Vehicle Type Approval and which allows for member states to implement their own Individual Approval schemes – SVA in the UK.

designed so as to protect other road users from thrown up stones, mud, ice and water, and to reduce for those users the potential dangers due to contact with the moving wheel. The technical requirements are those of the relevant EC directive except that provision for snow chains is not required. This involves a measurement to be taken, some existing designs may not be adequate – details available in the manual.

HEAD RESTRAINTS For those seats where a head restraint must be fitted the head restraint must be energy absorbing. The technical provisions are those of the relevant EC directive. This section has now been moved into ‘Seat Strength’ in the manual.

ENGINE POWER This is required under SVA for noise testing and is now specified as a separate item. Manufacturer’s declaration will be accepted (this can be supplied by the builder).

MASSES & DIMENSIONS (M1 VEHICLES) All vehicles must conform with the following: Max length 12m, max width 2.5m (except motor caravans 2.6m). The manufacturer must determine the maximum technically permissible mass (known as Gross Vehicle Weight – GVW), and maximum axle weights similar to the design weight requirements under SVA. 64 www.completekitcar.co.uk

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Bike engine kits must now be fitted with some form of reverse gear.

(even using our own Murtaya as a test vehicle), and hopes this figure may come down (it does not expect it to go up). The reality is that you must build the cost of getting a kit car onto the road into your budgeting from the outset. By the time you add in road tax, first registration fee and others, the overall ‘paperwork’ cost is significant.

THE MEETING

SAFETY GLASS

GENERAL CONSTRUCTION

The windscreen and windows to the side of the driver must be of safety glass and bear an appropriate approval mark. Other windows may be fitted with safety glazing eg plastic.

The general construction requirements are the same as SVA.

TYRES The requirements are for approved tyres fitted in accordance with the technical requirements of the relevant EC directive. Tyres must be appropriate for the vehicle in terms of load capacity, speed rating, and type of tyre.

FRONTAL PROTECTION SYSTEMS (BULL BARS)(OPTIONAL) If a bull bar is fitted the device must be E-marked. This requirement is added in the interests of pedestrian safety.

USEFUL CONTACTS You will find most information is now pooled on the following government website... www.direct.gov.uk

When I went over to VOSA’s head office in Bristol I met Mark Greedy and Darren Mason, both technical advisors on the implementation of EC Whole Vehicle Type Approval. These are the guys who interpret the regulations, make them into simple to follow methods of inspection and required standards for VOSA examiners and the general public to better understand and, in the case of the kit car scene, try to apply them to the amateur builder at home. I was extremely heartened by their knowledge and understanding of our scene. Considerable effort has been put into accommodating the amateur builder within the official framework that is IVA. Time, resources and money have been invested in drawing up a set of National Technical Requirements aimed squarely at allowing us to continue building cars for use in the UK while also operating within an official framework. I found it an encouraging meeting.

COST If the news has all been rosy to this point, then here’s the rub. The cost of a test has gone up... a lot. Where an SVA test currently costs £190, the new IVA test looks likely to set you back an eye-watering £540. This is obviously a huge increase, but before anyone suggests it’s an attempt to stop kit cars getting on the road (or any other similarly alarmist notion), there is a very simple explanation. Importers have long felt that the cost of Enhanced SVA (£240) is unfairly high, when the test takes considerably less time than the cheaper Standard SVA test applied to kit cars. VOSA has responded by doing a number of time trials for kit cars and imports going through SVA and, as we already know, kit cars typically take anything up to 4-5 hours. The new fees reflect this disparity. That said, VOSA is doing more time trials as we go to press

SUMMARY Stent meets Darren Mason and Mark Greedy from VOSA – both responsible for implementing IVA for kit cars within the framework of the new European documentation. We were impressed with their balanced approach.

To download an IVA inspection manual http://tinyurl.com/65usew For registration http://tinyurl.com/5oopx5 For DVLA Local Office directory http://tinyurl.com/2n6zes For SVA testing stations http://tinyurl.com/2v7vwn For VOSA head office Berkeley House, Croydon Street, Bristol BS5 0DA. T: 0870 606 0440 W: www.vosa.gov.uk E: enquiries@vosa.gov.uk

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I cannot emphasise enough that the implications of IVA for private enthusiasts building cars at home are minor, to the point of almost being inconsequential. There is certainly nothing within the regulations that should cause any modern kit car to permanently fail the test. And if you don’t believe me, you now have the chance to go online and read the inspection manual for yourself! Happy kit car building! 


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IVA – This Time It’s For Real With IVA coming into force while this issue is on sale, CKC is one of the first in the UK to present a car to be put through the new test. recently joined the technical team from VOSA, along with an experienced SVA test inspector who has completed the organisation’s conversion course for IVA, to see how a typical kit car will fare when put through the new regulations. Absolute Horsepower is a company which specialises in the assembly of Cobra replicas for private individuals, and the company’s Anthony Hale was happy to supply a recently completed car for the assessment. For Anthony it was a unique opportunity to see, first hand, what the future regulations will mean for the cars he assembles from now on. The AK 427 he brought with him had passed SVA just a month previously. While a few minor items had subsequently been changed by the customer (such as wing mirrors), the car was effectively in its SVA approved state, making the comparison with IVA all the more relevant.

THE TIME FOR talking is over. As this issue hits the shelves on April 17th, there will be fewer than two weeks before the Individual Vehicle Approval scheme is rolled out across the country’s 22 testing centres. As of the close of business on Tuesday 28th April, SVA will be no more for amateur built and production cars – if your kit car has been through and failed an SVA test before this date, you have just six months from the date of your test to get your car retested. For anyone about to complete a car, then you will be going through IVA. CKC has looked at the potential differences between the outgoing SVA and IVA on a number of occasions in the past, but there can be no substitute for presenting a car at an inspection centre and watching the test happen... for real. Having been working closely with the Vehicle and Operator Services Agency (VOSA – the agency within the Department For Transport responsible for implementing IVA) we suggested it would be valuable to see a car go through a test procedure in advance of the test becoming compulsory. As a result, we

IVA – THE TEST

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01 IVA inspector David Wilby began the assessment by

Manufacturer’s plate must display all the required

04 Anthony Hale, from Absolute Horsepower brought along the AK, and watched proceedings carefully.

The initial stages of the test are largely to confirm details you will have submitted on your IVA application form, which means checking the vehicle’s VIN plate, chassis number, engine block number and so on. These are all the same as for SVA, but with a few minor differences. Odd smaller changes include the position of the chassis number on the chassis. This must now be on the right side (offside) of the car, where previously the position wasn’t specified. Anthony’s AK has the chassis stamped on a left-hand-side chassis rail, visible from the engine bay. For IVA a duplicate of the number would need to

Chassis number must also be displayed on the right-handside of the car. This was on the left.

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information.

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checking the manufacturer’s plate and chassis number.

PAPERWORK

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If you’ve read our previous IVA related features, then you may already be aware that many of the test procedures are

either identical to, or very similar to, the existing SVA test, so we don’t propose to cover all of those here. What we mean to highlight are the areas where there are new features to be dealt with. Experienced SVA inspector David Wilby was on hand to undertake the assessment under the watchful eye of the VOSA team which has spent much of the last year writing up the test procedures and overseeing the current retraining program. This was a useful exercise for everyone involved and, with no time constraints, copious reference to the new regulations meant the assessment was as thorough and correct as possible.

There must be clear identification, including the correct symbol, to show what sort of brake fluid is used in the system.

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Horn was never assessed for SVA, but it must now produce an even sound.


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Certain warning lights are now mandatory and must

These Savage buttons already had the necessary

be stamped on the correct side (which could be done by the private individual). Pretty obviously, it won’t take long for manufacturers to supply kits with the stamp in the new position. After confirming these details, we’re into the test itself.

ENGINE BAY Our inspector gives the engine bay of the AK a thorough check to look for stray wiring, poorly fitted brake lines, plumbing or anything else that might be a cause for concern under the general Design and Construction guidelines of the test. These remain the same as for SVA, and Anthony’s AK’s has clearly been beautifully assembled. No problems here. The brake reservoir does come in for special scrutiny. A low fluid warning light on the dash has long been an SVA requirement, but now there must be clear identification at or near (within 100mm) the reservoir itself to show what specification of fluid is used. This must include the approved yellow symbol found on all production cars. This isn’t on Anthony’s car, but the picture here shows what’s on my own Peugeot, where the identification marks are usually on the cap itself. If your system has no obvious identification, then some form of identification plate or sticker, located within the defined zone, would be fine. Previously not an SVA requirement, now the horn itself will be checked and must produce a uniform sound (so none of those stupid cow horns!).

...although Anthony had fitted a main beam switch where it should have been a dipped beam switch.

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10 Column stalk controls must clearly identify their intended use. These don’t, but could be easily updated to comply.

markings to pass the test...

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display the correct symbols. Easily sourced from suppliers.

The required symbols are all outlined in the Inspection Manual, which is free to download online.

This suckered-on rear view mirror passed SVA, but would fail IVA. It must be more permanently located.

INTERIOR On the dash there are a number of mandatory warning lights you need, and each must either have a recognised symbol on it or some form of written identification on or near it. The vital wording within the new IVA Inspection Manual states that either the lights themselves or the associated signage ‘should not cause confusion to the driver’. In other words, if a complete stranger was to jump into your car, would they know what all the switches and lights are for? This is covered under ‘Identification of Controls’ within the manual. On the AK all the warning lights are perfect (having the correct symbols) while the natty Savage buttons also have the correct symbols, although Anthony has a button with the full beam symbol being used to switch on the lights for dipped beam – this would need to be changed. Another area where this car falls down is with its lovely aluminium handled column stalk controls. Neither have any identification, which would be an IVA fail. Either the original stalks need to go on, or the aluminium ones need some form of engraved (and clearly visible) indications on them. Many of the tests in the interior are the same as for SVA, but there are some changes. The centrally mounted rear view mirror on Anthony’s car which passed SVA is fixed via a sucker, which would fail IVA (a more permanent fixing method is required, as you would find on a normal type approved car). Also in this area, the centrally mounted support rod for the MAY 2009

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Cobra screen came in for close scrutiny and the test procedure has been subsequently adapted to allow for a windscreen support bar of up to 10mm diameter. While demist requirements are the same as before, the heater itself is now assessed, where it wasn’t previously. In particular, the way the heater draws air into the blower is checked. If this is drawn from the engine bay (perhaps through the front bulkhead), then there’s a risk of drawing in fuel or exhaust vapours. Our Adrenaline Murtaya would fail on this item, although an easy fix is to run flexible hosing from the heater inlet, forward to the front grille where it will draw in clean air. The heater system in Anthony’s AK simply draws air from the cockpit, which is fine. There are three other significant changes (as well as some more minor ones) of the test for the interior. The first relates to the lower floor area. Having established the seat base point by using the same tool as used in SVA, any area up to 150mm above this baseline was previously exempt from projection testing. This now changes for IVA, where a 100mm test sphere is now used to assess for sharp edges, but only when the sphere is used in a forward motion (to reflect the potential dangers to an occupant being flung forward in an accident). Exemptions to this test include the pedals and any seat adjusters. In reality, we don’t see this as a major problem. The second new test involves anti theft


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The correct field of view is established with the same

Support bar on this Cobra screen must be no more then

requirements. For most kits, that will mean the inclusion of the donor’s steering lock mechanism, which is used when retaining the upper column (typically from a Ford Sierra). This is also sufficient for IVA, but if your car does not use the donor column and therefore has no steering lock mechanism, you will need some form of permanently installed immobilisation. Where previously a simple battery kill switch would have been fine, this is no longer acceptable. The mechanism must be an integral part of the car which cannot be removed. It’s expected that this will most usually be achieved by the installation of an electronic immobiliser. However, this cannot be retro installed by the amateur, but must either be professionally installed (and therefore come with certification) or must be an inclusive part of the manufacturer’s wiring loom (and also supplied with some form of certification from the manufacturer). At the moment, we feel this will have most impact of Lotus Seven style cars which don’t feature a steering lock. It could be a potentially expensive fix. Another solution could be an aftermarket mechanical transmission or steering lock, but it must be permanently fixed. The following link may provide an affordable solution… www.afssecuritysystems.com/Mul-T-lock-GearLock.php The third main change for the interior of your car relates to headrests. All cars must have a headrest on all outboard front seats which is either integral with the seat (where the seat is

Establishing the correct position for any headrest is done using the standard SVA tools.

17 Any headrest must be above a certain point, established

Running Reports

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10mm in diameter.

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SVA testing tool as used before.

using this tool.

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052-057 IVA test:CKC Jan 09

Wheelarch coverage being assessed using the new IVA inspection tool for guidance.

Flip top filler cap will pass IVA, but aero style catches, where the cap can be removed from the car, will fail.

on runners) or, if the seat is fixed, can be located separately from the seat (for instance, located on the roll bar). The location of any headrest is found by using a special tool which takes a measurement 753mm up from the established seat base, following an angle adjacent to the seat back, and then plotting a position 90deg off this line. The top of the headrest must be above this line. Our view is that this can be quite simply addressed and we are already seeing some seat manufacturers offering IVA specification seats.

EXTERIOR TESTS Most of this will be the same or similar to SVA, with one or two changes. For instance, a completely new system of assessment is in place for the wheelarches (wheels guards) to ensure the tyres are sufficiently covered. You can see a clear Perspex tool being used in the pictures here (pic 17). After the centre point of the wheel is established, the tool is levelled with the ground and a forward angle of 30deg and rearward angle or 50deg (from the vertical) is noted. Looking down on the car from above, if any part of the tyre is visible within this sector, the car will fail the test. Furthermore, the wheelarch must continue back and down behind the wheel to reach a horizontal plain which is 150mm above the wheel centre line. What does this mean? Most full-bodied cars will easily comply with the second half of this test, but cycle-winged cars will need to be careful. Of more significance 54 www.completekitcar.co.uk

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is the test looking down on the car to assess visible tyre within the test area. One front wheel on Anthony’s AK was very close to a fail and we can see it being an issue on other kits. Careful wheel and tyre choice will be critical here, along with correct alignment of the bodyshell onto the chassis. Rather strangely, Anthony’s car failed on its rear numberplate provision. While his car is already registered and has a numberplate in place, a car being tested would obviously not have a plate in place.

USEFUL CONTACTS You will find most information is now pooled on the following government website... www.direct.gov.uk To download an IVA inspection manual http://tinyurl.com/65usew For registration http://tinyurl.com/5oopx5 For DVLA Local Office directory http://tinyurl.com/2n6zes For SVA testing stations http://tinyurl.com/2v7vwn For VOSA head office Berkeley House, Croydon Street, Bristol BS5 0DA. T: 0300 123 9000 W: www.vosa.gov.uk E: enquiries@vosa.gov.uk


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where the cap is removed from the car. Additionally, the filler cap (and any breather system that may be installed) must not be located within the cockpit, luggage space or engine bay. Finally, if you are using a plastic or fibreglass fuel tank, it must come with some form of certification, have a visible (when fitted) approval marking, come from a type approved vehicle or have supporting evidence from a reputable supplier’s catalogue to prove that it has been made to the correct specifications.

Not sure what we’re

If you’re new to kit cars... read on IF YOU’VE NEVER heard of IVA before and have no idea what it is, here’s our beginners’ guide... Before the likes of Ford and Vauxhall can launch a new car, they have to put it through EC Whole Vehicle Type Approval. This is a hugely complex and monstrously expensive exercise, so the European Parliament has said that EU countries can also establish lesser forms of Type Approval for smaller runs of car. In the UK we therefore have Low Volume Type Approval and Single Vehicle Approval (SVA). It’s SVA that’s most relevant to us as it is now being replaced by IVA. So you’ve built your kit car and it’s ready to go. First, the car must be presented for an IVA test, where various

brief summary of what SVA is.

Sticking with the outside of the vehicle, the lighting regulations are largely the same as before, once again with some minor tweaks. A reversing light is now mandatory (optional before) and must either operate when reverse gear is selected or, if switched on manually via a dash-mounted switch, must have a telltale warning light on the dash. The rear fog light must now only work with either dipped or main beam, so will need to be powered via the lighting circuit. The light unit itself must also be E-marked. There are also positional requirements for both lamps. Contrary to something we wrote in a recent issue of CKC, Daylight Running Lights (lights which are on all the time) are only an optional requirement. One anomaly of the test we discovered on our day was the positional requirements for front headlights. The minimum height for measuring a dipped beam used to be a measurement taken from the visible trace made by the dipped beam on the glass of

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You can clearly see where Anthony has had to trim his numberplate to clear the bootlid release lever.

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22 Headlight height measured. IVA rules have now been

Rear fog light now mandatory, and must only come on with dipped or main beam headlights.

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19 Assessing the available space provided for a numberplate. Surprisingly, the AK failed this test, but it’s an easy fix.

changed because of this assessment.

LIGHTING

also an easy fix, perhaps by locating the plate below the bootlid. Another area on the outside of the car to be examined for IVA will include the filler cap. While SVA required that it must meet projection requirements, the cap itself must now be either released by the ignition key or be tethered to the car in some way that makes it impossible to drive away and leave the cap at the filling station. The reason for this requirement is to reduce the chances of fuel vaporisation to the atmosphere or diesel spills onto the road. On the AK, the large flip top filler is fine, but the same would not be acceptable for any typical aero-style filler,

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However, it must still provide suitable space for a plate to be fixed. For IVA, a new test tool has been made which establishes a minimum space requirement (relevant for the rear plate). For a Cobra replica the number plate is typically mounted on the bootlid, above the boot release and below a numberplate light (which on the AK mounts on a dedicated plinth moulded into the panel). Neither the plinth, not the fixing position for the boot release can be moved and, on the AK, the space is too tight (as witnessed by Anthony having to cut out a section of the plate he’s used. This would be cause for a fail in IVA). Of course, it’s

aspects of its design and build are assessed. If your car passes the test, then you can move onto getting it registered, which will result in you being issued with a Q-plate, age-related plate or brand new plate, depending on the kit and the components used in its construction. If you fail IVA you can always re-take it and we’ve found IVA inspectors to be fair and helpful. Your kit manufacturer should also be able to provide you with guidance and the kit itself should be manufactured in such a way that it complies with the regulations. IVA is a good safety net for the kit car industry, ensuring a base standard is maintained. Above all, don’t let the bureaucracy get in the way of enjoying your kit car.

talking about? Here’s a

Windscreen glass must be E-marked. BS Kite mark is no longer acceptable. MAY 2009

David counts the cycles of the windscreen wipers. A twospeed system is now mandatory.

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describe these requirements, and the best we could manage was... Of the two different speeds, the slowest must be between 10 and 55 cycles per minute, the second (faster) speed must be over 45 cycles and at least 15 cycles different to the slower speed. The test is done with the screen being sprayed with the windscreen washer. Anthony’s AK already has a two-speed system which, when assessed, passed the test.

the headlight. Because this has become increasingly difficult to see on modern lamp units, the IVA regulations had been changed to read a minimum height of 500mm to the bottom of the headlight. In the case of Anthony’s AK (and probably every other Cobra replica on the market) this would have meant trying to jack up the suspension by about 3in! Almost impossible. As a direct result of our day, VOSA has managed to get the regulations amended and the final production version of the IVA Inspection Manual will now require the old measurement of 500mm to the visible trace line on a headlight or, where there is no visible trace line, 500mm to the bottom of the headlight. In the case of most Cobra replicas there should usually be a visible trace line on the headlight and, as such, the existing headlight positions should be OK.

BRAKES The braking test itself remains almost exactly the same as before, but with two potentially significant changes... For cars with adjustable brake balance, the SVA requirement was for the system to be locked with roll pins to ensure it couldn’t move. This has now been tightened to ensure that the system cannot be adjusted after the test... ever. The requirement is now for the balance bar to be permanently rendered unadjustable so that once the braking system is approved under IVA, it shall not be tampered with. What this means in practice is that you may need to set the brake balance up at an MoT garage prior to the IVA and then get the bar rendered un-adjustable. This may also have a bearing on the second aspect of the test which has changed... There is now an assessment for what is called secondary braking. In a conventional dual master cylinder, if one part of the system fails, the other half

WINDSCREEN, GLASS AND WIPERS

Checking the tint of the windscreen does not breach the

A tinted windscreen must allow at least 70% of the light

28 Anthony moves the AK onto the ramp. The test is nearly

should still provide adequate braking force to the bring the car to a halt. The system is often split transversely across the car – for example, the front left and back right on one system, the front right and back left on the other. With a twin master cylinder system operating a balance bar, one master cylinder operates the front, and one the back, allowing the owner to set the braking balance of the car, front and rear. The secondary braking test assumes that one half of a split system has failed, and requires the other half to provide a braking force of at least 30 per cent of the Design Gross Vehicle Weight DGVW or Calculated Gross Vehicle Weight CGVW (whichever is greater). In a conventional dual master cylinder system, where the split is diagonal, this should be quite possible. However, on a twin master cylinder set-up, where the split is front and back, this may be difficult to achieve on lightweight cars, where the rear brakes are often backed off quite considerably. Setting them correctly, may also increase the potential for the rear wheels to lock under braking. We are NOT saying that twin master cylinder braking systems using a balance bar arrangement will fail an IVA test, merely that they will require careful setting up prior to the test, presumably using an MoT garage’s rollers to get the balance correct.

UNDER THE CAR At some point during your IVA test, the car is put on ramps and the inspector will

Brake assessment is now more onerous, and the balance bar on a twin master cylinder system must be welded.

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through. This screen is fine.

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requirements for transparency.

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With the demise of British Standard Kite marks, all windscreens must now display the relevant E-mark. Another change for IVA is the assessment of the windscreen wiper speed. Previously the wipers had only to demonstrate a single speed which had a minimum of 45 cycles (one complete sweep and return of the wiper arm) per minute. For IVA there is now a requirement for two different wiper speeds, dictated by two different cycle rates. When testing the AK there was much debate as to how to

over and the AK has passed most of the assessment easily.

Back Issues

David checks around the fuel tank to make sure there is no likelihood of it being punctured in an accident.

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Checking the decibel output of the side pipes. Maximum noise has now been reduced to 99db.


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IVA CHECKLIST

NOISE

We’d suggest that on a car which was supplied prior to the onset of IVA you should check the following areas (in addition to downloading the IVA Inspection Manual), which may need adjustment...

We’re nearly finished with the areas of the test that witness changes compared to SVA. The noise test on the exhaust has been tweaked, such that the acceptable decibel level has been reduced from 101db to 99db. The method of testing is the same as before. Anthony’s car was close to 100db and may have passed SVA but failed IVA. .

B Chassis number location E-marked windscreen Brake master cylinder identifications Mandatory dash warning lights and identification of all controls Headrests Tethered fuel filler cap Exhaust noise Anti-theft device, if no steering lock Rear fog and reversing light operatio Brake bias controls locked off permanently Correct brake performance split

look closely at the underside of the car, once again checking for anything loose and also the operation of the steering and braking components. Nothing has really changed here from SVA, except for a new inspection of the fuel tank. The inspector will look around the tank to see that nothing can puncture the tank in the event of a crash. David pointed out that he’d seen cars going through SVA where there was potential for the tank to be ruptured in this way. On Anthony’s car it wasn’t a problem.

free download on the Transport Office website (see useful contacts panel) there’s no excuse for not printing it off and working through the relevant areas as you build your own car. And finally, it’s vitally important that you don’t forget that IVA should not get in the way of enjoying your build project. Use it as a benchmark for ensuring your future car will be safe when it hits the road, and IVA should be viewed as a safety net, rather than an obstacle placed in your way. 

OVERALL It’s extremely important to stress that for many areas of the new IVA inspection, the test is essentially the same as for SVA. In this article we’ve only concentrated on those areas where there is a noticeable change. Significantly, looking around the AK there were not many areas of the new test where changes were required and, for the most part, the AK already met the new standards – very encouraging. We were impressed with Anthony Hale’s existing knowledge of the SVA test and, having watched the new IVA test, he seemed quite pleased with the result and happy that he could produce a car which would meet the new regulations. That said, this is not to underestimate the impact of IVA. Like SVA before it, the new inspection will require you to think about how you build your car and what materials you use in its construction. With the new IVA Inspection Manual now available as a

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THANKS CKC would like to thank Anthony Hale of Absolute Horsepower for bringing along the superbly assembled AK 427 used in this assessment. If you fancy having your dream car built for you, contact Anthony on 0796 8394 396.

CKC would also like to thank Mark Greedy and Daren Mason from VOSA for their continued help and support. Also David Wilby for coming along to undertake the actual test.

Anthony Hale of Absolute Horsepower. He’s happy he can still build cars to meet our new regs.

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SVA to IVA