Author Topic: A cautionary tale...aftermarket suspension and the LVVTA  (Read 9510 times)

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Offline le mans

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A cautionary tale...aftermarket suspension and the LVVTA
« on: March 23, 2014, 11:19:10 am »
Some of you may remember me mentioning back in November/December that I was planning to purchase new suspension for my then very recently purchased Audi RS2. I did some research and decided to 'stretch' to the KW V3 adjustable kit as it appeared to be the bees knees (OEM plus quality with full adjustably) and therefore befitting such a special car. It is pretty expensive as you can imagine - it cost me 1400 GBP plus shipping plus tax plus MAF extortion. Here is a link to the product: http://shop.kw-suspensions.eu/index.php?page_id=product_single_view&sort=_&product_id=50951&mg=26&pg=160&page=1 I have previous experience with adjustable suspension with my RS4, so I felt reasonably comfortable going down this path.

Anyway, the suspension duly arrived mid December and after wrestling with Fedex and customs for a few days I even got to take it home. I enjoyed unboxing it!





It was fitted and set up, wheel alignment done and a certifier was there to sign it off. Here is where it went off the rails I'm afraid. The certifier took one look and said 'I can't certify this as it has an an aftermarket welded steering arm' (see the last picture above, which shows a front strut with steering arm). It turns out this certifier did not have the approval to sign off steering modifications but he was doubtful about getting it certified at all. He then referred me to someone who had the required approval to cover steering modifications. I was also referred to this LVVTA article which outlines LVVTA concern with aftermarket welded steering arms: http://www.lvvta.org.nz/documents/infosheets/LVVTA_Info_05-2012_Welded_Aftermarket_Suspension_Struts.pdf

Anyway, here is the car after having the suspension fitted. A bittersweet feeling I can tell you:



Here is the original OEM suspension after removal:


The new certifier sent mixed messages about the possibility of getting the suspension certified. He came and viewed the suspension fitted to the car in January and was quite positive about it at that time. He then took some photos and went away. I was advised that a formal approval would need to be requested from the LVVTA Technical Advisory Committee (TAC). The certifier did this on my behalf at  a cost to him of $95. The TAC requested the TUV certificate which I had supplied to the certifier. It can be viewed here: http://docs.kwsuspension.de/ga-KWGFw-07-2677.pdf

The TAC finally reviewed my case last Tuesday. And this is what they said:
Quote
TAC members viewed the TUV documentation, however the consensus was that there was still concern with the design and construction, and that the documentation was not sufficient to satisfy members that there was no possible chance of potential failure. TAC members all agreed that these can not be approved

So there you have it. This suspension kit, which can be safely and legally fitted to an RS2 in Germany or elsewhere in Europe, and support a car being driven on the autobahn at 260+ kph is not good enough for the LVVTA to sign off. So be warned, if you are considering aftermarket suspension for your B3/B4 you may never get it certified by the LVVTA.

I have nothing against the certifiers who tried to help me. To date I have't been charged a cent by either of them and they were very helpful to deal with. The communication was a bit sporadic, but you get that don't you! It seems that this ideological position of the LVVTA is holding them back. I have some sympathy as they assume some legal responsibility when they certify a 'modification' as safe, but the general lack of consideration for foreign certification is a bit over the top in my opinion, especially when you are dealing with an agency in the some country as where the car is manufactured. KW of course conforms to ISO quality standards too.

I am trying to refrain from more emotional language!




 
« Last Edit: January 11, 2018, 07:05:05 am by le mans »
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Offline 00quattro00

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #1 on: March 23, 2014, 11:38:09 am »
Wtf, some of the crap that they come up with is unbelievable.

A possible solution is to cut the spring perches of a set of original struts, buy the threaded sleeves and just use the springs and hats of the kws, chuck them in and go get a cert and just refit the kws after. Bit of dicking around tho
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Offline beeker

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #2 on: March 23, 2014, 12:27:47 pm »
Can you not go down the track of getting an independent structural engineer to certify it ?
ie like a kit car would be certified from the ground up.

Further, I would take it up with KW, as they would be shocked at such a ruling as it effectively bans their product from sale. They may be able to provide further evidence of it being formerly certified in other countries, especially if anything was done in AU being such a close neighbour who we borrow some regulation from, it might be reason for an appeal.
« Last Edit: March 23, 2014, 12:30:33 pm by beeker »
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Offline ziptie.nz

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #3 on: March 23, 2014, 01:56:15 pm »
I reckon Welded Steering arm would be at the very least twice as strong as the Poxy Cast Iron Factory Item...

Offline spooln

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #4 on: March 23, 2014, 09:26:21 pm »
I had an adjustable HnR kit in my rs2 and it was signed off. Said it was the best suspension they had seen.
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Offline zeitgeist

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #5 on: March 23, 2014, 11:13:44 pm »
KW should have full testing documents etc with all specs and regulation authority details included. Try and get that info off them perhaps?
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Offline le mans

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #6 on: March 24, 2014, 08:09:14 am »
I had an adjustable HnR kit in my rs2 and it was signed off. Said it was the best suspension they had seen.
Do you remember what the front strut looked like? Did it have welded or cast steering arms?
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Offline le mans

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #7 on: March 24, 2014, 08:11:19 am »
Can you not go down the track of getting an independent structural engineer to certify it ?
ie like a kit car would be certified from the ground up.

Further, I would take it up with KW, as they would be shocked at such a ruling as it effectively bans their product from sale. They may be able to provide further evidence of it being formerly certified in other countries, especially if anything was done in AU being such a close neighbour who we borrow some regulation from, it might be reason for an appeal.
I was following the guidance of my certifier and kept asking him if there was anything more I could do to support my case. All he wanted was the TUV certificate and indeed that is all that the TAC asked for. Zeitgeist has kindly given me a contact so will see where that goes.
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Offline le mans

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #8 on: March 24, 2014, 08:14:57 am »
KW should have full testing documents etc with all specs and regulation authority details included. Try and get that info off them perhaps?
Thanks again for the engineering contact. I did email KW's 'technical' team in Germany and received no reply. P*ssed about that but not overly surprised. I am going to email the local KW agent now. I have been avoiding that as I imported this kit myself and so I may not be very popular with them. The volume of KW components likely to be sold here with fabricated steering arms would be extremely low I would think so they may not be very interested. Anyway will see.
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Offline le mans

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #9 on: March 24, 2014, 09:57:11 am »
Can you not go down the track of getting an independent structural engineer to certify it ?
ie like a kit car would be certified from the ground up.

Further, I would take it up with KW, as they would be shocked at such a ruling as it effectively bans their product from sale. They may be able to provide further evidence of it being formerly certified in other countries, especially if anything was done in AU being such a close neighbour who we borrow some regulation from, it might be reason for an appeal.
Thanks Noel. Are you saying there is a way of certifying the car and completely bypass the LVVTA? I was under the impression that the LVVTA was the only agency that could issue certs?

The NZ KW agent has forwarded my email to KW in Germany so hopefully they can supply some more supporting data. All may not be lost just yet!
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Offline HaNs

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #10 on: March 24, 2014, 10:02:43 am »
A few suspension sets ups need to be cut and welded to allow coil overs (mainly BMW e30), they require someone with a current welding cert and a NDT test (usually xray) to verify the welds are fine.

Maybe esquire about what testing they require to pass?

Offline 00quattro00

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #11 on: March 24, 2014, 10:23:29 am »
The bmws dont have the arms welded to the strut like the audis do. Kw move them down and point them inwards slightly to correct steering geometry when its lowered
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Offline le mans

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A cautionary tale...aftermarket suspension and the LVVTA
« Reply #12 on: March 25, 2014, 06:30:43 am »
Engineering contact doesn't do certification work unfortunately so that's a no go at this stage.
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Offline beeker

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #13 on: March 25, 2014, 08:28:42 am »
Thanks Noel. Are you saying there is a way of certifying the car and completely bypass the LVVTA? I was under the impression that the LVVTA was the only agency that could issue certs?

The NZ KW agent has forwarded my email to KW in Germany so hopefully they can supply some more supporting data. All may not be lost just yet!

Try Frasers cars on the north shore. They obviously build their own cars, and their are also a MANZ certifier. They should have some 'custom car' certifying experience.
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Offline le mans

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #14 on: March 27, 2014, 10:19:03 am »
Thanks Noel.

Big ups to Chris Petch at Autoquip, who is the NZ agent for KW. He has been really proactive on getting this sorted since I got in touch with him. Hopefully there will be a good outcome to this eventually. Seeing as Chris is being so helpful I'll plug his company here: http://www.autoquip.co.nz
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Offline Danm

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #15 on: March 28, 2014, 09:39:17 am »
Hi

I am involved in this process so I can shed some light. LVV staff are not the pencil-pushers you might assume, we're a small organisation and each one of us is an enthusiastic petrolhead in one way or another:
http://www.lvvta.org.nz/about.html#about_staff
As well as the old Almac I have an A4 and a V5 Bora.

We have worked closely with the Transport Agency (NZTA) for over 20 years, developing alternative requirements for modified vehicles. We’re a non-profit organisation, not a government agency. We have a responsibility to ensure that vehicles are modified safely and that the modifications can be justified. If we didn't operate this way the ability for us all to make modifications would be under threat.

This KW suspension with the steering arm welded on isn’t of a common construction and so we need to ensure it is fit for purpose – loss of steering from a poor design or construction is clearly a safety risk, not only for the vehicle occupants but other road users.

We have requirements around welding of steering components. A steering component that has been modified or custom manufactured can only be welded if there is no other practical option being available, in which case:
(i) the component must meet all requirements specified in 18.9 ‘critical function welding requirements’ in ‘Chapter 18 - Attachment Systems’ of the NZ Hobby Car Technical Manual; and
(ii) the modification or custom-manufacturing process must be carried out by a person who is professionally engaged in motor vehicle construction, has substantial experience in steering component manufacture, and who is specifically nominated in writing by the Technical Advisory Committee of the LVVTA.

This KW steering arm design has multiple welds, which are all potential fail points, hence the requirement above. We have had recent experience of well-known parts failing and so we don’t take anything for granted. This infosheet covers one such case:
http://www.lvvta.org.nz/documents/infosheets/LVVTA_Info_01-2013_Unsafe_Aftermarket_Steering_Columns.pdf

Another more relevant case we have dealt with is aftermarket suspension struts with cast or forged steering arms welded to the upright. This infosheet provides information: http://www.lvvta.org.nz/documents/infosheets/LVVTA_Info_05-2012_Welded_Aftermarket_Suspension_Struts.pdf

A suspension supplier did go through this process and a strut was cut up and the welds inspected. It failed for poor weld quality. A second part was prepared and subjected to the same test and again failed. We concluded that the manufacturer did not understand how to weld to a casting or was not in control of their weld processes. The part was deemed to be sub-standard and posed a safety risk so it was not accepted.

Regarding the TuV documentation provided, this is the generic information TuV requires for suspension approval and does not make any mention of the steering arm. I suspect that a different TuV document should cover this aspect so we have asked for it.

We are working with KW to get all of the information to prove the suitability of the parts.

Regards
Dan
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Offline VW'n

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #16 on: March 28, 2014, 10:54:12 am »
We'll I found that post very informative, professional and it's good to see the process involved.
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Offline weta.worker

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #17 on: March 28, 2014, 11:31:22 am »
We'll I found that post very informative, professional and it's good to see the process involved.

+ 1

I don't know much about the subject but very nice to see a response from the other side.
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Offline le mans

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A cautionary tale...aftermarket suspension and the LVVTA
« Reply #18 on: March 28, 2014, 11:37:56 am »
Thanks Dan. It's good to get some movement on this now and I appreciate your help liaising with KW. The rejection of the suspension really provided the clarity that this needed to elevated to a different level if any positive outcome was ever to eventuate. I hope KW are able to provide all the necessary data. I imagine some of it will be commercially sensitive so there will need to be a degree of trust on their part.

Looking at these certification issues from further back, would it not be worth doing some work with foreign certifying agencies to understand their standards? It might streamline things down the line for the LVVTA and avoid the need for these lengthy investigations and avoid us 'enthusiasts' from being left hanging in limbo for so long. The irony is not lost on me that if I lived in Germany and owned an RS2 I could fit this KW suspension and legally drive the car all over Europe. I do however understand that in NZ the LVVTA assume the responsibility for ensuring these aftermarket parts are safe and therefore you need to satisfy yourselves of that fact before you sign them off.

Thanks again for your help on sorting this issue. I'm acutely aware that there is still no assurance that this suspension kit will be passed, but at least there is hope!
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Offline Danm

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Re: A cautionary tale...aftermarket suspension and the LVVTA
« Reply #19 on: March 28, 2014, 01:37:21 pm »
We communicate with other regions, mostly Australia and the UK. As part of my work I read a lot of regulations and standards  - the NZ rules are often based on them. The EU system seems very complex with many layers, down to individual country and it takes a long time to figure out where all the details are.

This KW case is a good example where a standard may miss an important aspect - the TuV document would be suitable for the majority of struts but not when there's a steering arm attached. That's not to say TuV hasn't considered it, there's probably another document for it we just need to find it. Along with a few other documents we should be able to 'tick all the boxes' and have enough data to make a robust decision.

We have many examples where a modification has passed in another country, only to find an issue, such as additional seats in the back of a camper van (half of our work is 'commercial', not all performance cars). There's an EU requirement that seatbelts must pass a load test of about 1600kg per occupant, so manufacturers build a frame and get it tested, like this one:
http://www.camperconversions.com/convert-your-van/seating-bed-systems/
The trouble is that on some campers nobody then checked what that frame was attached to. We saw examples of the frame just screwed to plywood, which won't take anywhere the 3200kg load of a twin seat. Fortunately there's usually a solution that can be applied to sort it out.

We've learned that nothing can be taken for granted and often we have to spend a fair bit of time digging up the right compliance documents, as with this RS2.

There you go, an insight into vehicle compliance you never wanted to know about.

Dan
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