IRU comments on the German proposal to improve accessibility for passengers with reduced mobility
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IRU believes that the revised proposal by Germany (ECE/TRANS/WP.29/GRSG/2016/20 and its Corr.1) to insert new amendments might create an additional burden on road transport operators without increasing road safety. IRU cannot support the German proposal and thinks that it would be more appropriate to address the issue with a cost benefit analysis, where the safety benefit can be justified.

Reference Number: GRSG-111-16
Origin: IRU
Date: 7 October 2016
Related Documents:
GRSG/2016/20 | Proposal for amendments to Regulation No. 107
GRSG/2016/20/Corr.1 | Proposal for amendments to Regulation No. 107
Discussion(s):
Working Party on General Safety | Session 111 | 11-14 Oct 2016

8. The expert from Germany proposed amendments to UN Regulation No. 107 to improve the accommodation and accessibility for passengers with reduced mobility (ECE/TRANS/WP.29/GRSG/2016/20 and Corr.1) including new testing provisions to ensure visual contrast of some safety elements and the installation of loudspeakers. The expert from Japan introduced GRSG-111-28 on the efforts in his country to set up legal conditions for barrier-free public transport systems. He presented GRSG-111-36 which outlines the specifications for non-step buses. The expert from UITP welcomed all these efforts, but reminded GRSG of the necessity to avoid design restrictions and to limit such provisions only for certain vehicles of category M3. The expert from the United Kingdom endorsed the position. A number of experts were of the opinion that all aspects linked to the environment and health (such as hygienic conditions, colour specifications, visibility and contrast issues) should be regulated on a national/regional level. The expert from Belgium preferred to insert such provisions, if necessary, as only optional requirements.

9. GRSG noted the observations by IRU that the new amendments proposed by Germany might create an additional burden on road transport operators without increasing road safety (GRSG-111-16). The experts from CLCCR and OICA shared these concerns. The Chair invited all experts to send their written comments to the expert from Germany. GRSG agreed to resume consideration, at its next session in April 2017, of ECE/TRANS/WP.29/GRSG/2016/20 as reflected in GRSG-111-35 on the basis of a revised document to be submitted by Germany.