International Update – October 2019

Date: October 8, 2019

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 117th session of the UN Working Party of General Safety (GRSG, scheduled this week from October 8-11 in Geneva). GRSG has responsibility for international regulations concerning the general design of motor vehicles regarding safety. The GRSG session will address, among other things, electronic data recorders (EDR), automated driving data recorders, restructuring of anti-theft regulations, and reversing vehicle safety. Proposals concerning couplings, mirrors, wiper systems, and bus construction are also on the agenda.

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.

Event Data Recorders and Data Storage

GRSG has responsibility for event data recorders (EDR), including Data Storage Systems for Automated Driving (DSSAD), which it shares with the UN Working Party on Automated/Autonomous and Connected Vehicles (GRVA). Much of the discussion within a recently formed expert group on EDR and DSSAD has centered on how to differentiate the two. This group, in which the U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) has taken a keen interest, intends to develop two separate sets of requirements. NHTSA was the first safety agency to establish specifications for EDR during the late 1990s, culminating in a 2006 voluntary standard (49 CFR Part 563, click here for more information). China plans to make a presentation during the GRSG session of an overview of its mandatory EDR standard. Broadly, the group views EDR as a device that logs specific vehicle data (speed, brake actuation, airbag deployment, etc.) at the time of a crash event. DSSAD is viewed as a record of human interactions with the automated driving system prior to an event.

Urban Shuttles: A New Vehicle Category

Related to automation, France issued legislation to define “urban shuttles” as distinct from the current European passenger vehicle classifications (i.e., M1-3 categories). France has several technology companies deploying driverless shuttles. A perceived gap in vehicle definitions prompted France to define a new vehicle category (available in its French text). Currently, M1 vehicles exclude standing room, while M2-3 vehicles are defined as having more than eight seating positions plus a driver. The initial legislation does not refer to automated driving (planned for a later step). It does, however, thread a needle by defining an urban shuttle as a vehicle that does not meet the definitions of M1-3 vehicles by providing a total capacity to carry between nine and 16 passengers plus a driver with seating for 4-5 passengers. As a result, by the end of the year, France expects to offer a national type-approval for these vehicles that is outside of the EU type-approval system.

Vehicle Anti-theft Systems

GRSG hopes to resolve the alignment of type-approval requirements for anti-theft, alarm, and immobilizer systems with the needs of the International Whole Vehicle Type Approval (IWVTA) system (established under UN Regulation No. 0 last year). Currently, all three elements for the protection against unauthorized vehicle use are captured in a single regulation, UN R116. However, not all countries require all three measures for vehicle approvals. As a result, the inclusion of UN R116 in the IWVTA system poses a problem.

In order to resolve the differences in national approaches, GRSG is considering proposals to establish separate regulations for the three elements in addition to maintaining UN R116. The International Organization of Vehicle Manufacturers (OICA) has prepared a comprehensive overview of the proposals and their application across the various categories of motor vehicles. The specific proposals are captured in new UN Regulations for devices against unauthorized use, vehicle alarms, and vehicle immobilizers. The technical requirements do not change, but manufacturers may seek type approvals under the consolidated UN Regulation No. 116 (UN R116) and/or the separate regulations depending upon the vehicle applications, markets, and needs for IWVTA approvals. The restructuring would also cover approvals under the earlier UN Regulations on protection against unauthorized use (UN R18) and vehicle alarms (UN R97).

Reversing Warning Sounds

GRSG continues to work on a new type approval regulation to establish specification for sound signals to warn when a vehicle is moving in reverse. The expert group drafting the new requirements has agreed to limit its application to medium and heavy passenger and commercial vehicles (i.e., M2 (3500 kg and above), M3, N2, and N3 category vehicles). The expert group will present a status report on its discussions at the session. The group expects to upload a working draft of the proposed regulation on its UNECE webpage. At the same time, the group is also communicating with experts separately working on possible requirements for the approval of rear obstacle detection systems (including camera systems). Requirements for reversing sound warnings and camera/detection systems are interdependent in several markets.

Other Subjects Under Consideration

In addition to the preceding topics, GRSG will also consider the following proposals for changes in regulatory requirements listed below.

  • The expert group working on management of fire events in buses expects to submit new requirements for buses and coaches (under UN Regulations 107 and 118) for the April 2020 session of GRSG.
  • Spain has proposed to require measure(s) in buses or coaches to prevent vehicle motion while any ramps or lifts are not in their stowed positions.
  • Finland has proposed to clarify Class C50 coupling requirements by specifying that flexible components integrated with an articulation fall outside the definition of a “special joint”.
  • Italy has proposed to enable the approval of optical reflecting mirrors in addition to traditional spherical mirrors to provide wider angles and reduce blinds spots. Italy has provided a supporting explanation of its proposal.
  • France has proposed a new series of amendments to UN R26 on vehicle external projections to clarify its interpretation with regard to “contactable parts” and windshield wipers. Given the implications for approvals, the proposal includes transitional provisions starting 24 months after entry into force. This proposal has been updated based on input from the vehicle manufacturers.
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