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Proposal to update the explanation on reportable occurrences in Annex 1 (GTR) and 3 (UNR). The revision refines language in the requirement describing the manufacturer’s Safety Management System by removing “expected” to avoid implying obligation and clarifying the link between occurrence monitoring, reporting, analysis, system updates, improvements, and continuous improvement processes.
Proposal to clarify EDR provision in Annex on thresholds. For vehicle categories M2, M3, N2, and N3, the revised text clarifies that UN Regulation No. 169 does not include a representative delta V threshold. The manufacturer could determine their own delta-V trigger for a critical occurrence, including one based on a subset of EDR triggers, with no obligation to do so.
(Duplicate of document TFCS-12-20.)