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.

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.

4. The expert from Germany reiterated his intention to find a solution (GRSP-65-17) to represent worst case scenarios, due to, for example, different heights of the vehicle from adjustable suspension systems. He also indicated that a concrete proposal had been submitted under agenda item 11 on UN Regulation No. 127. GRSP agreed to defer discussion to its December 2020 session, pending consideration of the Executive Committee of the 1998 Agreement (AC.3) at its November 2020 session.

20. The expert from Germany reiterated his proposal (ECE/TRANS/WP.29/GRSP/2019/18) and referred to agenda item 3(a) (see paragraph 4). The expert from OICA introduced GRSP-67-07 as a counterproposal, aimed at clarifying the issue that vehicle height has an influence on the test results of headform and legform tests, and consequentially all possible vehicle heights up to a driving speed of 11.1 m/s (40 km/h) should be considered to be relevant for impact with a pedestrian. Germany stated its agreement, in general, with the OICA proposal but suggested further clarifications. GRSP agreed to resume discussion at its December 2020 session on the basis of a potentially revised proposal from the experts of Germany, the United Kingdom and OICA.

4. Concerning the issue of different heights of the vehicle from adjustable suspension systems, the expert from Germany requested to resume consideration on this issue (GRSP-65-17) at the May 2021 session of GRSP. GRSP agreed with the request from the expert from Germany and noted that amendment 3 would be completed at the March 2021 session of the Executive Committee of the 1998 Agreement (AC.3) with the incorporation of provisions concerning the revised headform test. Thus, GRSP noted that a possible amendment incorporating the adjustable suspension systems would be a new one following the endorsement of a new request of authorization to develop the work submitted by a Technical Sponsor.

20. The expert from Germany reiterated his proposal (ECE/TRANS/WP.29/GRSP/2019/18) and referred to agenda item 3(a) (see paragraph 4). The expert from OICA introduced GRSP-68-18 as a counterproposal of ECE/TRANS/WP.29/GRSP/2019/18, tabled by the expert from Germany. He explained that the proposal was reflecting the latest stage of discussions aimed at clarifying the issue that vehicle height has an influence on the test results of headform and legform tests. He also suggested to encompass this issue with ECE/TRANS/WP.29/GRSP/2020/9. GRSP recalled that this last proposal was prepared by the experts of the Drafting Task Force to align the UN Regulation with the revised General Safety Regulation of the European Union that would enlarge the head impact zone to include the windscreen area. The expert from Republic of Korea suggested that the impact test speed ratio should be aligned to that one identified by the IWG-DPPS (see para. 5 above). Finally, GRSP agreed to resume discussion to the proposals of amendments to the UN Regulation at its May 2021 session.

5. Concerning the issue of different heights of the vehicle from adjustable suspension systems, the expert from Germany withdrew GRSP-65-17 and informed GRSP that a revised proposal would be submitted at the December 2021 session.

8. The expert from Germany in GRSP-65-17 had indicated a problem to represent worst case scenarios, due for example, to different heights of the vehicle from adjustable suspension systems, GRSP noted that a concrete proposal had been submitted under agenda item 19 on UN Regulation No. 127. GRSP agreed to defer discussion to its May 2020 session.

39. The expert from Germany introduced ECE/TRANS/WP.29/GRSP/2019/18 and referred to agenda item 3(b) (see paragraph 8 above): a clarification was proposed on the issue of pedestrian protection and variable suspensions. He added that since the vehicle height influenced the head-form test impact zone and the legform test, all possible vehicle heights up to a driving speed of 11.1 m/s (40 km/h) should be considered as relevant for impact with a pedestrian. GRSP acknowledged that the proposal affected both UN GTR No. 9 and UN Regulation No. 127 and agreed to defer discussion to its May 2020 session. At the same time, the expert from Germany was requested to devise transitional provisions to implement the proposed requirements.

19. The expert from Germany introduced GRSP-70-17 (superseding ECE/TRANS/WP.29/GRSP/2019/18), concerning new provisions to cope with Adjustable Ride Height Suspension System (ARHSS). GRSP agreed to distribute GRSP-70-17 with an official symbol at its May 2022 session, as draft 04 series of amendments to UN Regulation No. 127.