RID: IMMA comments on the draft new UN Regulation
Document SLR-26-03
19 September 2018
Submitted by IMMA
Download document
Previous Documents, Discussions, and Outcomes
2.1. | Report of the session of the Administrative Committee for the Coordination of Work (WP.29/AC.2)

43. AC.2 recommended postponing the vote on proposed new UN Regulations under agenda items 4.12.1 – 4.12.3 and deferred their consideration as revised proposals to the March 2019 session of WP.29.

4.12. | Consideration of proposals for new UN Regulations submitted by the Working Parties subsidiary to the World Forum

121. The World Forum considered the proposals for new UN Regulations on Light Signalling Devices (LSD), on Road Illumination Devices (RID) and on Retro-Reflective Devices under items 4.12.1 to 4.12.3. The World Forum agreed with the view of AC.2 (see para. 43 above) and recommended postponing the vote and deferring their consideration to the March 2019 session of AC.1.

4.12.2. | Proposal for a new UN Regulation on Road Illumination Devices (RID)
4. | Simplification of lighting and light-signalling Regulations

8. On behalf of the Informal Working Group on Simplification of the Lighting and Light-Signalling Regulations (IWG SLR), the expert from GTB reported on the finalization of stage 1 of SLR (GRE-79-28). He further provided a draft schedule for stage 2 which would include two steps. Step 1 would cover objectives which could be achieved by the end of 2019, such as introducing technology neutral and performance based requirements, as well as objectively testable provisions. Step 2 would start in 2020 with the aim to simplify the installation Regulations Nos. 48, 53, 74 and 86. As an additional task, he suggested harmonization with the applicable standards in China. GRE experts also proposed other issues for stage 2 of SLR.

9. The expert from GTB presented the full package of amendment proposals drafted by IWG SLR under stage 1 of SLR:

a) The three new simplified UN Regulations on Light-Signalling Devices (LSD), Road Illumination Devices (RID) and Retro-Reflective Devices (RRD) (ECE/TRANS/WP.29/GRE/2018/2, ECE/TRANS/WP.29/GRE/2018/3, ECE/TRANS/WP.29/GRE/2018/4, GRE-79-10 and GRE-79-14);

b) Draft amendments to Regulations Nos. 48, 53, 74 and 86 that group the definitions and introduce references to the new simplified Regulations (ECE/TRANS/WP.29/GRE/2018/6, ECE/TRANS/WP.29/GRE/2018/7, ECE/TRANS/WP.29/GRE/2018/8, ECE/TRANS/WP.29/GRE/2018/9, ECE/TRANS/WP.29/GRE/2018/10, ECE/TRANS/WP.29/GRE/2018/12, ECE/TRANS/WP.29/GRE/2018/13, ECE/TRANS/WP.29/GRE/2018/14, ECE/TRANS/WP.29/GRE/2018/15, ECE/TRANS/WP.29/GRE/2018/17, ECE/TRANS/WP.29/GRE/2018/30, GRE-79-08, GRE-79-09 and GRE-79-13);

c) Transitional provisions to “freeze” Regulations Nos. 3, 4, 6, 7, 19, 23, 27, 38, 50, 69, 70, 77, 87, 91, 98, 104, 112, 113, 119 and 123 (ECE/TRANS/WP.29/GRE/2018/11).

10. The expert from EC was not in a position to support the indefinite validity of type approvals granted under the frozen Regulations, as proposed in ECE/TRANS/WP.29/GRE/2018/11, because of the General Safety Regulation of the European Union. He proposed revised transitional provisions for these Regulations (GRE-79-31, part I), together with new transitional provisions for the installation Regulations Nos. 48, 53, 74 and 86 (GRE-79-31, part II). While several experts agreed in principle with part I, they were not in a position to support part II. The experts from Finland and UK made study reservations. The expert from OICA expressed the concern that the revised transitional provisions might be rejected by WP.29.

11. To not delay the submission of the whole package of amendment proposals that had been developed in stage 1 of SLR, GRE decided to provisionally adopt the transitional provisions in ECE/TRANS/WP.29/GRE/2018/11, but to put in square brackets the third transitional provision for each Regulation mentioned in the document. At the same time, GRE recognized the urgency of the issue raised by the expert from EC and requested all GRE experts, as well as IWG SLR, to carefully consider the EC proposals with a view to taking a final position at the next session.

12. The expert from IWG SLR proposed correcting minor errors and inconsistencies identified in the documents mentioned under para. 9 (a) above (GRE-79-14). GRE adopted these corrections, as laid down in Annex II.

13. The expert from IWG SLR also suggested rectifying minor errors and inconsistencies in the documents listed in para. 9 (b) above (GRE-79-13). GRE adopted these corrections, as laid down in Annex III, and decided to opt for the alternative wording (in square brackets) of paragraph 6.3.9. of different series of amendments to Regulation No. 48.

14. The expert from India suggested corrections to ECE/TRANS/WP.29/GRE/2018/2 and ECE/TRANS/WP.29/GRE/2018/3 (GRE-79-17-Rev.1 and GRE-79-18-Rev.1 new text). GRE adopted the corrections, as laid down in Annexes IV and V. The expert from India withdrew GRE-79-19, in order to first present it at the next session of IWG SLR.

15. The expert from IWG SLR recalled that all identical definitions should only be kept in Regulation No. 48. Thus, he proposed to review the definitions in Regulations Nos. 53 and 74 (GRE-79-08 and GRE-79-09, respectively). GRE adopted these modifications, as contained in Annex VI.

16. The expert from IWG SLR presented the concept of “change index” developed for the LSD, RID and RRD Regulations (GRE-79-12-Rev.1). He further introduced amendment proposals on the change index to Regulations Nos. 48, 53, 74 and 86 (ECE/TRANS/WP.29/GRE/2018/16, ECE/TRANS/WP.29/GRE/2018/18 and GRE-79-11). GRE adopted these proposals, as amended by Annex VII). In addition, GRE agreed to include transitional provisions on the change index in the text of the LSD, RID and RRD Regulations (GRE-79-10 and Annex VIII). The expert from India pointed out that he would refer GRE-79-22 to IWG SLR.

17. Subject to the modifications mentioned in paras. 10–16 above, GRE adopted the package of amendment proposals drafted by IWG SLR and listed in para. 9 a) – c). The secretariat was requested to submit the amendments proposals to WP.29 and to the Administrative Committee of the 1958 Agreement (AC.1) for consideration and vote at their November 2018 sessions. GRE noted that any modification of the transitional provisions, mentioned in para. 11 above, that GRE might agree upon at the next GRE session in October 2018, would be submitted to the November 2018 session of WP.29 as corrigenda to the basic SLR package which otherwise would be issued in August 2018.

18. The expert of SAE proposed to keep Regulations Nos. 98, 112, 113 and 123 “alive” for the purpose of the recently updated Canadian Federal Motor Vehicle Safety Standard (CMVSS) No. 108 (GRE-79-32-Rev.1). GRE referred this document to IWG SLR for consideration.

5. | Regulations Nos. 37, 99, 128, and Resolution RE5

20. On behalf of the Task Force on LED retrofits and substitutes (TF SR), the expert from Germany presented their status report (GRE-79-16). GRE supported the proposed two-step approach and mechanical interlock as a solution to avoid misuse of light emitting diode (LED) substitutes.

21. GRE recalled the earlier proposals by GTB to introduce LED substitutes and replaceable light sources into the new LSD and RID Regulations (ECE/TRANS/WP.29/GRE/2017/14, ECE/TRANS/WP.29/GRE/2017/15 and GRE-78-04) and noted that ECE/TRANS/WP.29/GRE/2017/15 had been incorporated in ECE/TRANS/WP.29/GRE/2018/3. GRE invited TF SR to update ECE/TRANS/WP.29/GRE/2017/14 and GRE-78-04.

22. The expert from GTB pointed out that the GTB guidelines for introducing and evaluating LED light source categories that were intended for forward lighting applications (GRE-77-04) should be published as a reference document on the GRE website. GRE agreed to this request.

Related and Previous Documents
WP.29/2018/158
GRE/2018/3
Relates to UN R149 |