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 update previews the 179th session of the UN World Forum for the Harmonization of Vehicle Regulations (WP.29, scheduled during 14-16 November in Geneva). WP.29 gathers regulatory agencies and other stakeholders from around the world to agree on common requirements and test procedures for motor vehicles, systems, and components. The WP.29 session will consider the status of efforts to develop new methods to assess the performance of automated driving systems and vehicles as well as changes to existing regulations.
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The advent of automated driving presents regulators with significant challenges given the diversity of systems and the conditions under which they must operate. Last June, WP.29 hammered out a general Framework Document to guide these efforts. WP.29 has also established technical groups to pursue specific areas of interest, including:
- Definition of functional performance requirements
- Development of validation and assessment methods
- Requirements for event data recorders
- Requirements for data storage systems for automated driving
- Requirements for the type approval of “hands-off” highway lane keeping systems
- Recommendations and type approval procedures for cybersecurity
- Recommendations and type approval procedures for software updates
- Harmonization of AV light-signaling equipment.
In addition to the typical use of direct third-party physical testing, WP.29 expects to design a new framework capable of capturing vehicle performance across the diversity of road conditions. Based upon discussions to date, this new architecture will involve the definition of traffic scenarios that an automated system would be expected to navigate without disrupting traffic or producing a collision. While the mechanics of this new approach have yet to be detailed, the intent is to cover as broad a spectrum as possible of traffic situations through relatively high-level definitions of functional and performance requirements.
Vehicles would be assessed against their demonstrated capacity to navigate all applicable conditions without incident. The evidence to demonstrate this performance would be generated through track and laboratory testing, on-road testing, and simulation tools. Who will conduct the testing remains to be seen, but it seems evident that the bulk of the performance data will need to be generated by the vehicle manufacturers as they internally validate their vehicles and systems. This assumption leads to the concept for a third-party audit of the evidence produced by the OEM. The current thinking is that the audit would cover design aspects of the complex electronic systems (i.e., architecture, fault modes) and an assessment of the manufacturer data. In order to validate the manufacturer data, including that generated via simulation tools, a limited set of third-party track and on-road tests would be conducted to establish independent baseline performance data.
During the November WP.29 session, the stakeholders will review the status of the various activities and the Forum may issue additional guidance to the various technical groups.
Regulation Changes and Updates
As usual, WP.29 will consider and adopt several dozen proposals endorsed previously by its six main technical working parties. The proposals include a UN measure to urge that governments update their fuel-quality requirements in parallel with modifications to their corresponding emissions standards.
WP.29 will also finalize the publication of specifications for the Flexible Pedestrian Lower Leg Form Impactor (Flex-PLI). This test tool has been developed for use under the Pedestrian Safety Global Technical Regulation (GTR 9) and its type-approval counterpart, UN R127. This development may bear upon NHTSA’s recently announced plan to update the U.S. New Car Assessment Programin 2020. The NHTSA NCAP update is expected to include pedestrian protection and crashworthiness elements. Although NHTSA has not yet incorporated the Flex-PLI into the FMVSS, NHTSA evaluations of the new tool were positive and the forthcoming NCAP upgrade could seek to apply the GTR 9 methods.
The proposals on the WP.29 November agenda include:
International Whole Vehicle Type Approval (IWVTA)
UN Regulation 0:
- Supplement 1 to the original series and Supplement 1 to the 01 series to clarify the acceptance of Limited IWVTA approvals.
- New 02 series of amendments to update UN R0 in line with the restructuring of the UN lighting regulations, to introduce use of the UN on-line system for sharing information on acceptance of type approvals, and to amend the annex concerning “Specifications of the IWVTA DoC,” including replacing a reference to the type approval number with the VIN.
General Vehicle Design Safety
UN R43 (safety glazing): Supplement 9 to the 01 series of amendments to delete a reference to abrasion requirements in the assessment of resistance to weathering.
UN R55 (mechanical couplings): Supplement 8 to the 01 series of amendments to improve the type-approval communication document.
UN R58 (rear under-run protection): Supplement 1 to the 03 series of amendments to clarify category G (off-road vehicles) ground clearance requirements, clarify the table of Annex 7 (requirements for different vehicle categories) with regard to requirements for M1G, N1G,M2G, N2G, M3G and N3G, and to clarify provisions on the installation of rear under-run protection devices.
UN R67 (LPG equipment):
- New 03 series of amendments to introduce requirements on the location on the vehicle of the filling unit, marking of the LPG container date of production, and a limitation on the maximum service life of LPG containers to 15 years.
- Supplement 2 to the 02 series of amendments to improve the specifications for LPG multi-valves in order to reduce the risks of blockage of the PRV/PRD due to deterioration of the hose connecting the PRV/PRD of the multi-valve to the gaseous phase.
UN R107 (coach and bus construction): Supplement 8 to the 06 series, Supplement 3 to the 07 series, and Supplement 2 to the 08 series of amendments to lower the minimum mass requirement for an articulated vehicle of Class I having four or more axles of which two are steering axles.
UN R116 (unauthorized use protection): Supplement 7 to clarify that anti-theft-related vehicle components such as keys are not subject to the environmental testing requirements (established for components embedded in the vehicle).
UN R16 (seat-belt systems): Supplement 12 to the 06 series and Supplement 5 to the 07 series of amendments to clarify that modifications need only be notified to the Type Approval Authority when they have an influence on the performance (compliance with technical requirements of UN R16) and/or the documentation required by the UN Regulation. The proposal also updates the Communication Form to add rear belt reminders.
UN R21 (interior fittings): Supplement 4 the 01 series of amendments to clarify rounded-edge requirements for roof-opening roof devices.
UN R29 (commercial vehicle occupant protection): Supplement 5 the 03 series of amendments to introduce a tolerance for the position of the loading test device. The loading device is required to be parallel to the x-y plane of the chassis. This proposal would add a z dimension to the x-y plane and set a tolerance such that the loading device may not deviate by more than 5° along the z-axis.
UN R44 (child restraints): Supplement 17 to the 04 series of amendments to clarify the chest Z axis measurement requirement.
UN R80 (bus and coach seating): New 04 series of amendments to raise requirements for the attachments and fittings of the seat (as a prelude to the eventual deletion of static test methods in favor of dynamic testing).
UN R129 (ISOfix child restraints): Supplement 3 to the 03 series of amendments to add booster cushions without a backrest to the scope of the 03 series.
UN R135 (pole side-impact): Supplement 2 to the original series and Supplement 2 to the 01 series of amendments to introduce objective criteria for evaluating whether a door remains latched following the pole impact test.
Emissions and Efficiency
UN R85 (net power measurement): Supplement 10 to allow an alternative test method (recognized in SAE J1349) in setting the charge air cooler outlet temperature during bench test.
UN R115 (LPG/CNG retrofit systems): Supplement 9 to list conditions, especially regarding retrofit systems, under which indirect and direct injection vehicles may be considered as belonging to the same vehicle family.
UN R79 (steering systems): Supplement 2 to the 03 series of amendments to introduce provisions for the approval of Remote-Controlled Maneuvering (RCM) systems.
UN R48 (installation of lighting): Supplement 13 to the 06 series of amendments to correct and clarify the requirements for daytime running lamps (DRL) used in conjunction with rear position lamps and to introduce requirements for light emitting diode (LED) substitute light sources.
UN R53 (motorcycle lighting):
- Supplement 21 to the 01 series of amendments to align UN R50 and UN R53 regarding the inward geometric visibility requirements for rear position lamps, to allow the use of different stop lamp activation methods for powered two-wheelers as currently applicable for four-wheelers; e.g. by the application of a retarder or a similar device, and to make editorial corrections.
Supplement 3 to the 02 series of amendments to:
- align UN R50 and UN R53 regarding the inward geometric visibility requirements for rear position lamps;
- allow the use of different stop lamp activation methods for powered two-wheelers as currently applicable for four-wheelers; e.g. by the application of a retarder or a similar device;
- restore the definition of “device” (because the definition under UN R53 differs from that under UN R48);
- delete the definitions of “bend lighting”, “H plane”, “sequential activation” and “emergency stop signal” (because they are identical to the definitions in UN R48); and,
- introduce requirements for light emitting diode (LED) substitute light sources.
- New 03 series of amendments to introduce requirements for automatic switching from with daytime running lamps (DRL) to headlamp(s) and to restore the original automatic headlamp ON (AHO) requirement for vehicles not equipped DRL.
UN R74 (moped lighting):
- Supplement 11 to the 01 series of amendments to introduce requirements for light emitting diode (LED) substitute light sources.
- New 02 series of amendments to require installation of direction indicators on mopeds.
UN R86 (tractor lighting): Supplement 2 to the 01 series of amendments to introduce requirements for light emitting diode (LED) substitute light sources.
UN R98 (gas-discharge light sources): Supplement 1 to the 02 series of amendments to ensure explicit reference to the new UN R149 (Road Illumination Devices) in order to enable the continued acceptance of headlamps compliant with UN Regulations under Canada’s CMVSS 108.
UN R112 (asymmetrical passing beam headlamps): Supplement 1 to the 02 series of amendments to ensure explicit reference to the new UN R149 (Road Illumination Devices) in order to enable the continued acceptance of headlamps compliant with UN Regulations under Canada’s CMVSS 108.
UN R113 (symmetrical beam headlamps): Supplement 1 to the 03 series of amendments to ensure explicit reference to the new UN R149 (Road Illumination Devices) in order to enable the continued acceptance of headlamps compliant with UN Regulations under Canada’s CMVSS 108.
UN R123 (adaptive front lighting): Supplement 1 to the 02 series of amendments to ensure explicit reference to the new UN R149 (Road Illumination Devices) in order to enable the continued acceptance of headlamps compliant with UN Regulations under Canada’s CMVSS 108.
UN R148 (light-signaling devices): Supplement 1 to clarify the provisions and intentions of this new regulation recently adopted as part of the effort to simplify lighting regulations. UN R148 supersedes all previous light-signaling regulations.
UN R149 (road illumination devices): Supplement 1 to specify the use of UN R48 definitions unless otherwise explicitly stated in the regulation or in the lighting installation regulations for other vehicle categories (i.e., in UN R53, R74, or R86) and to otherwise clarify the text in Annex 2.
UN R150 (retro-reflecting devices): Supplement 1 to improve the text, adds that the definitions in UN R48 apply unless the regulation or the vehicle-category-specific regulations (UN R53, 78, 86) specify different applicable definitions, to clarify that the construction provision and prohibition on use of paints or varnishes under paragraph 4.1.6 only apply to retro-reflectors, to correct an omission regarding Class F devices, and to add the water-resistance test (from UN R69 and R70) to Annex 7.