I have had a very speedy response from DVSA which I have copied in below, together with my reply. However it is clear that DVSA need to see more evidence of 48v/12v system failures so i will ask everyone you has contributed to email
[email protected]
Mr Hayward
Thank you for your email and we note your comments.
I’m not able to discuss the case referenced but can advise DVSA investigates safety defects within the terms of the Code of Practice on Vehicle Safety Defects (the Code), which has the support of the General Product Safety Regulations 2005 (as amended).
This can be accessed at
https://www.gov.uk/government/publications/code-of-practice-on-vehicle-safety-defects-and-recalls/vehicle-safety-defects-and-recalls-code-of-practice
When investigating an allegation of a safety defect DVSA considers any warnings and the immediate impact the defect may have on occupants and the driver’s ability to control the vehicle, bring it to a halt etc.
Whereas DVSA has not yet determined a safety defect as defined by the Code, its Market Surveillance Unit continues to monitor reports to collate any additional evidence, and I have added your report to our investigation file.
I note your comments on warnings displayed and recommendations.
Vehicles sold in the UK must either have European whole vehicle type approval (EWVTA) or certain other recognised approvals. Our understanding is this vehicle fully meets EWVTA and requirements for the UK.
However, vehicle type approval is the responsibility of the Vehicle Certification Agency (VCA) and you may wish to address your concerns on this to them. Their web site address is
Homepage - Vehicle Certification Agency (vehicle-certification-agency.gov.uk)
Thank you
Dear Mr Corcoran,
Thank you for your speedy response.
As much as I understand you are unable to discuss the case I highlighted, it would appear that my experience was a mirror image of that case. From my professional life my understanding is once an electronic system is commissioned its software and firmware will act in exactly the same way for all items so produced, everyone who has Audi cars with this fault will experience the same life threatening failure scenario.
I have looked at the Code of Practice and note that DVSA has responsibilities to monitor and investigate issues that affect automotive product safety. Then it is your responsibility to identify potential safety issues and work with the manufactures to rectify such defects. So far so good you are the organisation to look into the defects highlighted by myself and others.
However from what you say , so far you have been unable to identify my experience and the experience of others as a ‘safety defect’. Could you please explain how being trapped in an inert vehicle, which could become involved in a shunt or catch fire is NOT a safety defect?
If you accept my argument above that once an electronic system has been commissioned then all systems will act in the same way then your being advised of one failure surely will mean that all systems [48v/12 hybrids] will suffer the same failure mode.
I note your action is to add my observations to your file. How many similar observations do your need before you act?
Do you need someone to be killed on a smart motorway, unable to exit their Audi before you take action?
I will try to get all the people I know who have experience the same safety issue as me to write to you.
In the meantime I await your response to my questions.
Rgds
Mark Hayward