Welcome to the latest installment of “International Update” – a monthly feature of the Washington Insider from John Creamer, MEMA’s advisor on international regulatory affairs. This month's installment reviews regulatory changes coming out of the UN Working Party on Passive Safety (GRSP), including frontal crash, head restraint, and pedestrian safety initiatives. GRSP is a technical body under the UN World Forum for the Harmonization of Vehicle Regulations (WP.29). If there are topics you would like to see addressed in future “International Update” columns or if you have questions about this installment, please contact Leigh Merino. Please click through to read the whole column.
Crash Impact Protection
Pursuant to the update of European Union safety regulations (see the May 2019 update: “Political agreement on new EU safety requirements”), GRSP has established a task force led by the European Commission (EC) to consider light trucks, SUVs, and heavy vans under UN Regulation No. 94 (frontal impact), No. 95 (lateral impact), and No. 137 (full-width rigid barrier impact). The new European Union (EU) legislation would require expanding the scope of UN R94 to include N1 category vehicles up to 2,500 kg and M1 passenger vehicles up to 3,500 kg. Proposals from the EC would also add new requirements for occupant-evacuation solutions (doors, automatic seat displacement) in the event of a crash under both UN R94, UN R95, and UN R137. Given the pending transposition of crash provisions from GTR 20 on electric vehicle safety, the task force has been directed to prepare a formal proposal by early September for consideration at the December GRSP session.
Buses and Child Restraints
A proposal to work on safety requirements for children traveling on buses and coaches has received broad support. Germany, Japan, Korea, Russia, and Sweden endorsed setting up an expert group to develop solutions and recommendations, supported by the U.S. efforts on school bus safety. At the June WP.29 session, safety authorities approved the program. Details for the group’s objectives and timeline will likely be ironed out during the December GRSP session.
The GRSP continues to consider amendments to GTR No. 7 on head restraints to introduce:
- Neck Injury Criteria (NIC) covering upper and lower neck flexion and extension;
- Option to use of the BioRID in place of the Hybrid III dummy; and,
- New headrest height measurement procedure based on the point of head contact rather than the headrest absolute height.
GRSP hopes to conclude this work, including publication of the BioRID specifications in Mutual Resolution 1 on test devices, next December. Stakeholders were requested to provide any final comments by 13 September.
Once finalized, GTR 7 provisions will be integrated into UN R17 on seat strength. This alignment activity may also be impacted by a German proposal to amend the definitions of integrated, detachable and separate head restraints.
The drawings and specifications for the FlexPLI lower leg-form impactor have been prepared and should be formally added to Mutual Resolution 1 on test devices following the November 2019 session of the World Forum. The FlexPLI is the new test tool for use under GTR No. 9 and UN Regulation No. 127 on pedestrian safety.
Separately, Germany has proposed to amend GTR 9 and R127 to address vehicles with active suspensions. Germany wants to ensure that height variations across such suspensions do not impair the effectiveness of the requirements of the pedestrian collision regulations.
GRSP will discuss this proposal, expansion of the head-impact area definition (pursuant to the EU safety updates), and the status of work on assessment methods for deployable pedestrian protection systems (DPPS such as active hood releases) at its December 2019 session.
Hydrogen Fuel Cell Safety
GTR No. 13 on hydrogen fuel-cell vehicle (HFCV) safety is likely to include a new section devoted to heavy-duty vehicles. Work sponsored by the United States, Japan, Korea, and the European Union has targeted amendments to the GTR to address:
- Technical requirements for heavy trucks and buses;
- Fueling receptable and system requirements, especially related to materials compatibility and high-pressure system durability;
- Fire resistance; and,
- Integrating outcomes from the ISO hydrogen technologies technical committee (ISO/TC 197) work on international standards.
Rear-Seat Airbag Safety
The International Organization of Motor-Vehicle Manufacturers (OICA) has requested safety authorities to consider a version of the U.S. “low-risk deployment” approach to rear airbags and child restraint systems (CRS). The OICA proposal would allow manufacturers to demonstrate that a rear-seat position frontal airbag design does not pose risks to CRS occupants, alleviating the obligation for manual or automatic deactivation functions.
OICA received GRSP endorsement for its proposal to clarify UN R16 with regard to type-approval authority (TAA) notifications. The change adds a stipulation that only modifications impacting technical performance and/or approval documentation need require TAA notification. The proposal should be adopted by the World Forum next November.
GRSP Proposals for the November WP.29 Session
The following proposals were approved by the Working Party on Passive Safety for consideration by the full World Forum next November. In general, proposals endorsed by the Working Parties are subsequently adopted by WP.29.
- GRSP approved a proposal to add a Z dimension to the X-Y plane of the loading device used under UN R29 on truck cab strength. The proposal further sets the tolerance such that the loading device may not deviate by more than 5 degrees along the Z-axis.
- GRSP approved a proposal to increase requirements for bus and coach seat attachments and fixations under UN R80. The proposal was accepted as an interim compromise pending efforts to delete static test procedures from the regulation (in favor of dynamic testing). Also, proposed was a compromise to completely deleting the static test, as the static test will provide the basis for a simpler testing of small projects or Class I vehicles
.A two-step approach was offered: (a) the first step was presented with GRSP-65-29 Rev.1 with more stringent requirement for the attachments and fittings of the seat, and (b) the second step would be a revision of the static and dynamic test.
- GRSP agreed with a proposal to establish objective criteria for evaluating whether a door remains latched following the pole impact test under UN R135. This proposal, sent for adoption by WP.29 next November, aligns UN R135 with a similar change made to UN R95 on lateral impact protection.