Document GRSP-65-21
UN R127: Proposal of Supplements to the 00, 01 and 02 series of amendments
Status: Superseded
Submitted by Germany

Proposal to ensure pedestrian protection across the vehicle height variations that may be produced by an active suspension system.

Discussions and Outcomes
66th GRSP session (10-13 Dec 2019)
65th GRSP session (13-17 May 2019)

8. The expert from Germany introduced GRSP-65-17, explaining that the intention of the pedestrian protection test procedures as described in UN GTR No. 9 and UN Regulation No. 127 was to deliver an adequate level of protection for pedestrians in accidents up to an impact velocity of 40 km/h. International Harmonized Research Agenda research has shown that the cumulative frequency curves versus vehicle impact speed for pedestrian injuries and their respective injury causing parts showed that 58 per cent of the child head abbreviated injury scale (AIS) 2+ injuries were addressed to a vehicle impact speed up to 40 km/h, 40 per cent to adult head AIS2+ injuries and 50 per cent of the adult leg AIS2+ injuries respectively. He added that test procedures described in UN Regulation No. 127 and UN GTR No. 9 were meant to represent worst case scenarios. However, it was agreed that this was not the case for all possible scenarios and that also at lower impact speeds higher injury risk could occur due for example to different heights of the vehicle because of adjustable suspension systems. The representative from OICA reminded that during the type approval process the worst case scenario will be considered. GRSP agreed to keep GRSP-65-17 as an informal document for the December 2019 session of GRSP, awaiting further rationales to develop a proposal of amendments.

33. Referring to agenda item 3(b) (see paragraph 8 above), the expert from Germany suggested postponing discussion on GRSP-65-21 to allow careful consideration of the new provisions of the General Safety Regulation of the European Union, which had proposed an extension of the head impact zone. GRSP agreed to defer discussion of GRSP-65-21 to its December 2019 session and to distribute it with an official symbol.

64th GRSP session (11-14 Dec 2018)

27. The expert from Germany introduced GRSP-64-20, to clarify different interpretations on vehicle configuration testing in the presence of active suspensions, which arose in off-road driving (SUVs mostly) or driving in a car park (sports cars). He concluded that since the vehicle height had an influence on the headform test area and on the test results for legform tests, all possible vehicle heights up to a driving speed of 11.1 m/s (40 km/h) should be considered relevant for impact with a pedestrian. The expert of OICA agreed that the issue raised by Germany was valid and that there was a need to avoid different interpretations, but this needs to be studied carefully, also in relation to the normal procedure of “worst case definition”. He added that this would entail new requirements, therefore needing a series of amendments and transitional provisions. He also added that this issue should be considered in the ongoing WP.29 discussions on the performance of vehicles outside the test boundaries defined in the various UN Regulations. The expert from the Netherlands suggested developing simulation models to check worst case testing. The expert from OICA stressed that testing a vehicle in all potential configurations would be unrealistic and therefore welcomed the statements from the Netherlands. He referred to the work on the certification of automated vehicles whereby an additional 3-pillar approach was considered to address automation:

  1. test track,
  2. road test and
  3. simulation and audit of development process.

28. The Chair of GRSP suggested establishing a group of interested experts to further develop the proposal. GRSP agreed with the proposal of its Chair. The expert from Germany announced a possible meeting before 15 February 2019, to submit a new official proposal. Finally, GRSP requested the secretariat to keep GRSP-64-20 as a reference in the agenda of the May 2019 session.