International Update – March 2019
Welcome to the latest installment of “International Update” featuring the outcomes of the UN Working Party on Passive Safety (GRSP) session held during 11-14 December 2018. Topics include head restraints, pedestrian safety, safety of hydrogen fuel cell and electric vehicles, child occupants.
This is a monthly feature of the Washington Insider from John Creamer, MEMA’s advisor on international regulatory affairs. If there are topics you would like to see addressed in future installment or if you have questions, please contact Leigh Merino. Please click through to read the article.
Head Restraints GTR
Amendment 2 to Global Technical Regulation (GTR) No. 7 may be finalized by the May 2019 session of the UN Working Party on Passive Safety (GRSP). The effort has long suffered under the inability to objectively define whiplash injuries and develop quantitative performance criteria applied to the Biomechanical Rear Impact Dummy (BioRID). Having abandoned short-term hopes to define injury assessment reference values based upon bio-mechanical research results, the amendment will rely upon other “empirical data” to define the injury criteria. By mid-February, stakeholders in the work hope to resolve the remaining issues, including concerns over repeatability and reproducibility of the BioRID test procedure. The amendment proposes the following changes:
Procedure for establishing the height of the head restraint based on the head contact point rather than on its absolute height,
Height measurement test procedure,
Deletion of the backset measurement test procedure using the H-point machine method,
Introduction of the backset measurement test procedure using the R-point method, and
Introduction of a dynamic performance test procedure using the BioRID.
Despite the near completion, the absence of bio-mechanical research data to underpin the injury criteria put in doubt the United States’ acceptance of the new requirements.
GTR 7 is closely linked with UN Regulation No. 17 on seat strength. Therefore, Japan and the European Commission have proposed amendments (GRSP-64-37) to bring UN R17 into alignment with the proposals for GTR 7. Changes to UN R17 would impact the type approval of seats and headrests. Manufacturers have submitted proposals (GRSP-64-25) to enlarge certain tolerances and clarify provisions.
The United States confirmed the cancellation of plans to issue a Notice of Proposed Rulemaking (NPRM) to integrate GTR No. 9 into the U.S. Federal Motor Vehicle Safety Standards (FMVSS). NHTSA does not expect any action for the foreseeable future due to other priorities.
Separately, the technical drawings for the Flexible Pedestrian Legform Impactor (Flex-PLI), as stipulated under the pending Amendment 2 to GTR 9, should be finalized by the May 2019 GRSP session. The drawings would be incorporated into the UN Mutual Resolution on Test Devices (MR 1).
Work on Deployable Pedestrian Protection Systems (DPPS) also continues (e.g. automated hood release systems or external airbags). This initiative aims to develop new and detailed requirements to ensure that deployable systems activate/deploy as intended to protect pedestrians and other vulnerable road users. A major focus involves validation of the Head Impact Time (HIT) determination procedure. The expert group drafting the requirements is considering numerical simulation and physical dummy testing.
Hydrogen Fuel Cell Vehicle Safety
Global Technical Regulation No. 13 was established in 2013 to address hydrogen fuel-cell vehicle (HFCV) safety. Under a “Phase 2” program, GRSP is pursuing requirements for heavy vehicles and buses, material compatibility, tank stress rupture, fire test parameters and clarification of existing UN GTR test procedures. Five task forces have been established:
Task Force 1 on heavy-duty vehicles and buses has been addressing the fuel system given differences with the light vehicle systems addressed by the original GTR.
Task Force 2 on fueling receptacle requirements expect to submit a draft proposal next March.
Task Force 3 on recommendations for test procedures expects to complete its work by the summer of 2019.
Task Force 4 on fire testing plans to complete its work before the end of 2019.
Task Force 5 on recommendations from ISO TC197 is developing technical guidance on fuel-cell vehicle/fueling station interface topics.
Electric Vehicle Safety
Work on the second phase development of GTR No. 20 on electric vehicle safety should be complete by 2021. The effort includes work on thermal propagation, water immersion, toxicity and gas management, and 3D vibration. Under thermal propagation, a key focus has been on the development of a reliable, repeatable, and reproducible method to initiate a thermal event. The expert group working on the regulation has identified fundamental concerns with water immersion and battery pack vibration testing. Questions have been raised over the need for water immersion testing given a lack of field data to justify requirements. Vibration may set aside as more germane to durability than vehicle safety.
Japan also expects to propose a draft series of amendments to UN Regulation No. 100, which provides type approval requirements for battery electric vehicles, to align this regulation with the current provisions of GTR 20. Together with the European Commission and the vehicle makers, Japan expects to provide its proposal for the May 2019 GRSP session.
Separately, a proposal is under consideration to extend the functional safety requirements of UN R100 to medium-duty vehicles (M2 and N2 category) and to heavy passenger vehicles (M3).
Child Restraint Systems
GRSP approved a proposal to phase out the type approval of belted child restraint systems under UN Regulation No. 44. The proposal now moves to the June session of the World Forum for the Harmonization of Vehicle Regulations (WP.29). If the change is adopted (as is likely), this would complete the replacement of UN R44 certification with approvals under UN R129 for all CRS except Group III forward-facing non-integral CRS.
Child Seating in Buses
France, Germany, Spain, and Sweden expressed interest in a Russian proposal to consider improvements to child safety on buses. Possible approaches include requirements for adapted three- or four-point seat belt systems or use of child restraint systems such as prescribed by UN R129. The United States representatives from NHTSA offered to share the agency’s research on this subject at the May GRSP session.
GRSP will meet next in Geneva during 13-17 May 2019. In addition to the items noted above, the gathering of passive safety regulators is expected to consider the inclusion of full width rigid barrier (UN R137) and pole side impact (UN R135) crash testing in the International Whole Vehicle Type Approval (IWVTA) system. Child restraint (UN R44 and R129) and HFCV safety (UN R134) regulations are also candidates for inclusion in this vehicle trading arrangement.