Summary
A product type approval, or certificate of conformity, is granted to a product that meets a set of regulatory and safety requirements prior to its introduction and use on a transport network
From a transport perspective, there are currently varying and inconsistent product type approval processes across modes and jurisdictions in Australia which are complex and costly to both industry and transport agencies.
The current Framework acts as a barrier for the introduction of new technologies and innovation, reducing value creation and resulting in regional disparity.
Transport for NSW has led a national working group, in collaboration with other jurisdictions, for the development of a national framework for product type approval.
The objective was to develop a national harmonised framework and ultimately streamlined business processes to achieve harmonisation and cross-acceptance.
Assessment criteria
Current state
There are inconsistencies in how the type approval process is managed across both Transport for NSW and other jurisdictions. These inconsistencies have created confusion with the process and reluctance by the industry to innovate and introduce new products and technology.
The inconsistency has created inefficiencies across the transport industry with the following implications:
- A barrier for innovation by making it complex to obtain type approval for new products and technologies
- Duplication of effort where suppliers are bearing the cost of duplication of the type approval requirements across jurisdictions
- The evaluation process to be applied is extremely burdensome adding additional cost to projects and the suppliers
Feedback from key stakeholders is that the processis difficult to navigate and does not provide value for money.
The different processes across jurisdictions mean that our industry suppliers must duplicate effort to introduce a product into a similar operating environment in another jurisdiction.
In summary, the current state process for type approvals within Australia results in:
| Confusion and reluctance to innovateBarrier for the introduction of new technology Barrier to value creation | Increased risk profileLower customer outcomesDuplication of effort and inefficiencyTimely and complex processes |
Rail product type approval research
The research conducted by Australasian Railway Association (ARA) and the Rail Industry Safety and Standards Board (RISSB) identified and confirmed that the current approach adds cost and complexity for industry.
The research confirmed that concentrating the type approval process on new solutions would put the focus on assessing products and technologies that can make a material change to rail operations. This would create value and:
- Streamline the number of applications and the costs incurred
- Make it easier for suppliers of new products and technologies to seek type approval
- Lead to better outcomes for industry without compromising safety
Whilst the ARA and RISSB survey report identified key activities and costs associated with the type approval process in rail, it is safe to assume that similar outcomes and recommendations can be expected in other modes of transport, such as roads.
There are numerous approval and certification business processes across the national transport industry and there is minimal consistency across transport modes and jurisdictions.
This means that type approval with one asset class operator does not currently serve as a ‘trust marker’ to other mode operators.
Additionally, research has identified that complexity and inconsistency of the type approval process is a challenge to the industry and is an area requiring the need for further clarity, business process improvement and efficiency.
The current situation creates a barrier for suppliers developing innovative technology and proposing technology across different transport modes and networks.
Product Type Approval Framework
In early 2022 the Product Type Approval Project Team reached out to other jurisdictions to understand how type approval is managed by other organisations.
The outcome of these conversations resulted in agreement to establish a national initiative to work collaboratively on harmonisation of the product type approval process across jurisdictions and modes of transport.
A harmonised National Product Type Approval Framework is a strategic initiative which enables type approvals to be recognised to the extent permitted by each assessing organisation’s performance requirements, network and system differences. This strategic initiative is aligned with other transport harmonisation strategic initiatives – for example the rail standards harmonisation plan and the rail interoperability framework.
When leveraging a type approval certification across networks the product will need to be further assessed. Consideration needs to be made of the differences between network topology, configuration, environmental conditions and the differences in asset management requirements that apply to the respective network.
This is often referred to as the ‘delta’ between networks and covers numerous reasons for variations. This means that a product certified on one network is not necessarily fit for purpose for use on another network without further assessment and acceptance. Moreover, a streamlined national approach and mutual recognition will result in significant gains and value creation.
Each jurisdiction maintains its own list of approved products and may conduct additional assessment before accepting a product for use that has been assessed by another jurisdiction. Importantly, application of the Framework should minimise duplication and streamline the assessment process.
Alignment to asset management
The National Product Type Approval Framework guides national efforts to proactively:
- reduce cost by removing duplication and inefficient mode specific processes
- provide transparency and consistency in risk assessment against safety, technical and regulatory obligations
- improve network performance and outcomes by encouraging innovation and the use of new technology.
The Framework and associated processes are aligned with asset management planning requirement providing a whole of life assessment of the product in support of the strategic outcomes and the organisational requirements.
An efficient and effective product type approval process directly relates to the operations requirement of the asset management framework providing safe and fit for purpose products for operation of the transport network.
The Framework is a transformational approach across the transport sector as it drives asset management outcomes by means of supporting evidence-based decision making to balance cost, risk and performance. Effective leadership across Transport for NSW and the broader national transport industry and partners will be required to implement and embed the Framework.
A pilot of the Framework will be conducted by Transport for NSW. Clear performance metrics, against the Framework’s foundational principles, will be established to assess performance.
The Plan-Do-Check-Act process will be used to identify improvements to the Framework prior to national implementation and then on an ongoing basis.
Value creation
The Framework has been developed to enable harmonisation across transport modes and jurisdictions and deliver value creation by proactively reducing cost and improving efficiency in the product type approval process.
Creating nationally consistent standards for products that are used to maintain the status quo would:
- Save the rail industry $40 million each year
- Improve outcomes and address inconsistencies currently experienced by the industry
- Make it easier to use products that maintain the existing condition of rail assets
Opinion
The Energy Networks & Systems (EN&S) team within the Asset Management Branch of Transport for NSW provide strategic initiative leadership of energy related transport assets and systems. This strategic initiative has been developed in collaboration with all jurisdictions from across all modes of transport.
Broad collaboration, representation from across all transport modes and jurisdictions and consultation with industry bodies has been vital to the establishment and support of the framework.
Three industry engagement workshops have been facilitated allowing all stakeholders with an opportunity to provide input into the development of the core principles and the framework.
There are nearly 50 members on the governing working group representing different modes, industry bodies and jurisdictions across Australia and more recently New Zealand.
The national multi-modal Product Type Approval Framework has been drafted in collaboration with the following organisations:
The industry and regulatory bodies Framework endorsement scheduled is:
| Feb / Mar 2023 | Transport for NSW Asset Management Steering Committee |
| Secretary for Transport for NSW | |
| Rail Industry Safety Standards Board | |
| Australasian Railways Association | |
| National Transport Commission | |
| Apr 2023 | Infrastructure Transport Senior Officers Committee – Apr 2023 |
| Jun 2023 | Infrastructure Transport Ministers Meeting – Jun 2023 |
As one of the largest multi-modal transport organisations in Australia, Transport for NSW will conduct a pilot of the Framework. To support the pilot, Transport for NSW will initially be responsible for management and governance of the Framework.
A national body will be established with representation from across jurisdictions and organisations to provide oversight of the governing body. The national body will have the following accountability:
- Management and governance of the Framework
- Consultation with industry partners
- Drive and monitor Framework and process improvements
- Establish an example model process and application guide (reflecting the framework)
- Monitor the benefits from and support continuous review and improvement to framework
- Establish a communication portal that provides access to the Framework, example processes and individual jurisdictions processes
- Publication of the product type approval registers
The National Committee will coordinate regular reporting on the effectiveness of both implementation and application of the Framework. Indicators to assess the success of the Framework implementation and its level of adoption will consider both short and longer term success factors.
| Short term Pilot outcomesBaseline process durationEffective governance structureIndustry / supply chain engagement | Longer term Adoption by jurisdiction / modeImproved process durationDemonstrated value creationIndustry / supply chain satisfaction |
Indicators to assess effective application of the Framework will consider the following KPIs as an example:
| Number of assessments | Coverage across modes | Tier Coverage | Process Duration | Assessment Outcome |
General comments
The Framework consists of a nationally agreed set of core principles that will strengthen knowledge sharing, value creation and mutual recognition.
There are ten core principles which are used as the foundation for development of the Framework.
The Framework provides a scalable and consistent approach and a common language across jurisdictions delivering multimodal outcomes. In addition, it will ensure products, systems and sub-systems are safe, reliable, and consistently perform the way they were intended for the duration of their life cycle.
The level of governance and assurance applied to a product type assessment is based on a tiered approach which takes into consideration the level of risk allocation, change impact, complexity and novelty assessment.
| Principle | Description |
| Leads to fit for purpose products | Products meet the expectations for their intended use. Assessors shall consider relevant standards, specifications and regulatory / legislative requirements taking into account risks and non-compliances pursuant to organisational procedures. |
| Scalable based on risk change and complexity | Approval process shall take into account inherent risk, level of change, complexity, criticality and priority of products in each category and adjust the rigor, effort and time of initial assessment and/or ongoing surveillance accordingly. The risk categories shall be nationally agreed and applicable across all transport modes and jurisdictions. |
| Well documented and auditable | The process shall be communicated clearly and unambiguously. All assessments, including communication between SMEs and suppliers, shall be documented and archived in accordance with a clear and transparent document management policy, suitable for audit and assurance. |
| Transparent and fair | All assessments shall be conducted in accordance with the product approval process. When published standards and specifications are not sufficient to assess the product, the criteria used shall be impartial, consistent and communicated early in the process. |
| Minimising duplication of effort | Assessments should be reviewed by other jurisdictions and used where possible to minimise duplication of effort. Additional assessment may be required to ensure ‘fit for purpose’. Decision making processes and outcomes between jurisdictions should be shared, including information regarding product performance. |
| Enable innovation | The process shall consider innovative or alternative products that achieve the necessary outcomes while balancing cost, risk and performance outcomes. |
| Independent assessments | The assessment process may leverage third party assessment schemes and testing facilities. Assessments shall clearly state the assumptions and limits of the assessment. The operator/jurisdiction shall assess further for application of use. |
| Reasonable timeframes | All endeavours shall be taken to ensure that timeframes for the assessment and validation of the evidence of compliance are reasonable through the adoption of these principles. |
| Consistency | Commitment to embed principles and follow agreed criteria and risk category process. Assessments shall be objective as far as possible. Agencies, Service Providers and SMEs shall collaborate to ensure that assessments are equivalent wherever they are undertaken, assuming similarity of specification. |
| Ongoing governance | Any jurisdiction agreeing to adopt this process shall include provision for ongoing resourcing and maintenance of the TA process to ensure it remains relevant, practical and adaptable to emerging needs. |