UN R44: Request for guidance
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Request for guidance in order to resolve conflicting interpretations of paragraph 7.1.4.2.2. The paragraphs reads, " The vertical component of the acceleration from the abdomen towards the head shall not exceed 30 g except during periods whose sum does not exceed 3 ms.” However, an explanatory note for Technical Services on performing the tests under Annex 15 adds, "The wording of this paragraph [7.1.4.2.2.] refers to accelerations representing tensile loads in the spine of the dummy.” Differing interpretations have resulted in a CRS being approved but then rejected during Conformity of Production review by a separate Technical Service.

Reference Number: GRSP-65-20
Origin: Germany
Date: 10 May 2019
Related Documents:
GRSP-65-28 | UN R44: Supplement 17 to the 04 series of amendments
Discussion(s):
Working Party on Passive Safety | Session 65 | 13-17 May 2019

14. Referring to the request made by the Administrative Committee for the Coordination of Work of WP.29 (WP.29/AC.2) (see ECE/TRANS/WP.29/1155, para. 30), GRSP resumed discussion on the belt-guide device type approved as Child Restraint System (CRS) according to UN Regulation No. 44 by the Type Approval Authority of Poland. The expert from the Netherlands introduced a presentation (GRSP-68-24), showing additional test results performed on the belt-guide. He added that the tests confirmed the conclusion laid out in document GRSP-67-05, introduced at the July 2020 session of GRSP and in addition showed that the device does not conform to the dynamic test requirements when tested with the P10 dummy. Therefore, he stated:

  1. The belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn.
  2. The device did not meet several requirements, both technical and with regard to instructions for users and therefore approval should not have been granted.
  3. The car design determines the level of protection for a great deal of cases and may result in submarining and/or in injuries in the abdominal area, since the device sold as a child restraint does not offer adequate protection or guidance in this respect.
  4. The device could offer better protection than the adult belt itself but lacks the additional protection of a CRS.
  5. Since approval of this device was issued erroneously, it shall be withdrawn, and Market Surveillance Authorities should be informed.

The expert of the Netherlands further added that for the time being he was not requesting an arbitration process according to Schedule 6 of the 1958 Agreement, because a parallel investigation is being conducted at the European Commission level. The expert from Poland introduced GRSP-68-27 arguing against the conclusions of GRSP-68-24 and providing clarifications on the belt-guide dynamic test performances. He stated:

  1. During last year there had been numerous different unsubstantiated allegations against the belt guide, e.g.: submarining (GRSP-50-09 and GRSP-50-25), vertical component (GRSP-65-20), risk of abdominal injury. However, he added these allegations were not demonstrated.
  2. Type-approval tests according to the UN Regulation requirements were conducted by Polish technical service – PIMOT in 2017, which conducted more than 160 tests by using dummies required by the UN regulation (P3, P6 and P10 type), showing satisfactory results.

He concluded that in December 2019, after comparative tests with other CRS showed problems with other type-approved CRS, the discussion in GRSP should be broadened to focus on other CRS as well. The expert from Spain, stated that the focus should be on the interpretation that a belt-guide and similar devices cannot be separately approved as a CRS.

25. The expert from Germany introduced GRSP-65-20 aimed at introducing clarifications on the direction of the vertical component of the chest acceleration, to provide consistency on the test performed by different Technical Services on Child Restraint Systems in accordance to paragraph 7.1.4.2.2. of the UN Regulation. The expert from CLEPA introduced GRSP-65-28 which superseded GRSP-65-20. Finally, GRSP adopted GRSP-65-28 as reproduced in Annex III of the session report. The secretariat was requested to submit GRSP-65-28 as Supplement 17 to the 04 series of amendments to UN Regulation No. 44, for consideration and vote at the November 2019 sessions of WP.29 and AC.1.

Working Party on Passive Safety | Session 68 | 7-11 Dec 2020

14. Referring to the request made by the Administrative Committee for the Coordination of Work of WP.29 (WP.29/AC.2) (see ECE/TRANS/WP.29/1155, para. 30), GRSP resumed discussion on the belt-guide device type approved as Child Restraint System (CRS) according to UN Regulation No. 44 by the Type Approval Authority of Poland. The expert from the Netherlands introduced a presentation (GRSP-68-24), showing additional test results performed on the belt-guide. He added that the tests confirmed the conclusion laid out in document GRSP-67-05, introduced at the July 2020 session of GRSP and in addition showed that the device does not conform to the dynamic test requirements when tested with the P10 dummy. Therefore, he stated:

  1. The belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn.
  2. The device did not meet several requirements, both technical and with regard to instructions for users and therefore approval should not have been granted.
  3. The car design determines the level of protection for a great deal of cases and may result in submarining and/or in injuries in the abdominal area, since the device sold as a child restraint does not offer adequate protection or guidance in this respect.
  4. The device could offer better protection than the adult belt itself but lacks the additional protection of a CRS.
  5. Since approval of this device was issued erroneously, it shall be withdrawn, and Market Surveillance Authorities should be informed.

The expert of the Netherlands further added that for the time being he was not requesting an arbitration process according to Schedule 6 of the 1958 Agreement, because a parallel investigation is being conducted at the European Commission level. The expert from Poland introduced GRSP-68-27 arguing against the conclusions of GRSP-68-24 and providing clarifications on the belt-guide dynamic test performances. He stated:

  1. During last year there had been numerous different unsubstantiated allegations against the belt guide, e.g.: submarining (GRSP-50-09 and GRSP-50-25), vertical component (GRSP-65-20), risk of abdominal injury. However, he added these allegations were not demonstrated.
  2. Type-approval tests according to the UN Regulation requirements were conducted by Polish technical service – PIMOT in 2017, which conducted more than 160 tests by using dummies required by the UN regulation (P3, P6 and P10 type), showing satisfactory results.

He concluded that in December 2019, after comparative tests with other CRS showed problems with other type-approved CRS, the discussion in GRSP should be broadened to focus on other CRS as well. The expert from Spain, stated that the focus should be on the interpretation that a belt-guide and similar devices cannot be separately approved as a CRS.

25. The expert from Germany introduced GRSP-65-20 aimed at introducing clarifications on the direction of the vertical component of the chest acceleration, to provide consistency on the test performed by different Technical Services on Child Restraint Systems in accordance to paragraph 7.1.4.2.2. of the UN Regulation. The expert from CLEPA introduced GRSP-65-28 which superseded GRSP-65-20. Finally, GRSP adopted GRSP-65-28 as reproduced in Annex III of the session report. The secretariat was requested to submit GRSP-65-28 as Supplement 17 to the 04 series of amendments to UN Regulation No. 44, for consideration and vote at the November 2019 sessions of WP.29 and AC.1.