GRE, at its 64th session, agreed to establish an informal group to develop a horizontal reference document (HRD) that would contain common provisions currently duplicated in each of the lighting and light signalling regulations. This decision is based upon an original proposal from France (ECE/TRANS/WP.29/GRE/2008/32) and a presentation from the GRE chairman at the 63rd GRE session (GRE-63-27).
GRE accepted the offer from France to chair the informal group and elected Mr. Christian Pichon (France) as chairman with the secretarial duties being managed by GTB (Mr. Geoffrey Draper).
The official GRE64 meeting completed its agenda ahead of time and the opportunity was taken to hold this first (ad-hoc) meeting open to all GRE participants in order to have an initial exchange of views.
The basis for the work is the proposal for the light- signalling regulations submitted by France in ECE/TRANS/WP.29/GRE/2008/32) which will require updating. The potential benefits are described in the introductory document (GRE-63-27) presented to GRE at its 63rd session by the GRE Chairman. The chairman, Mr. Pichon, explained his intention to divide the task and share the work amongst the members of the informal group.
Mr Gorzkowski, GRE Chairman, advised that the establishment of a “reference document” instead of a regulation will avoid problems associated with managing series of amendments and their adoption by the contracting parties. A “Horizontal Reference Document” (HRD) will be managed through a formal amendment procedure but this would be the responsibility of GRE.
Mr Goldbach (OICA) expressed concerns relating to how the type approval system will work when both a Regulation and an associated HRD will be involved. Mr Gorzkowski explained that all the technical requirements will remain in the regulation and it would only be the common test and administrative requirements that would be moved to the HRD. The important question will relate to how the amendments to the HRD will be managed.
Responding to a further question from Mr Goldbach, Mr Gorzkowski explained that no requirements relating to the type approval will be contained in the HRD, as is the case for RE3. Mr Matthes (Germany) added that the Component Regulation will contain a reference to the appropriate section in the HRD but emphasised that the group will need to pay particular attention to ensure that the provisions in the HRD will apply to all the associated regulations.
Dr Manz (Germany) reminded the group that a precedent has been established by the GRE decision to move all the requirements concerning colour from the device regulations into Regulation 48. Mr Gorzkowski (GRE Chairman) emphasised that the HRD is not a regulation; it will not have series of amendments; there will be no requirement for voting at WP29. He also reminded the group that currently there is a problem created by moving the colour requirements into Regulation 48 because a change to the colour provisions will normally provoke a new series of amendments. By moving the colour provisions into the HRD this is avoided. Any change to the common requirements in the HRD would provoke a change in the series of amendments of the component regulations. Mr Goldbach (OICA) supported this approach and foresees significant benefits.
Mr Matthes (Germany) questioned how changes to the HRD will be approved as nothing may change in the regulation because the reference to the HRD will remain the same. Mr Gorzkowski (GRE Chairman) proposed that the HRD is treated in the same way as RE3 and approved at WP29-AC1.
Mr Pichon (Chairman) questioned how a change to the test methods will impact upon the type approvals. Mr Gorzkowski explained that in the case of serious changes to the HRD, the communication document will refer to a modification level of the HRD. This will require a document control system. In the case of a small change, this can be managed by a reference in the component regulation “as amended from time to time”. Dr Manz (Germany) considered that this approach is sufficient as the HRD will be part of the legal framework and will be managed by GRE. Mr Gorzkowski (Canada) explained that based upon his experience with the Canadian Standards the use of the expression “as amended from time to time” will be satisfactory as GRE will be in control.
Mr Schmidt (CLEPA) asked whether the HRD would impede the introduction of new technologies. Mr Gorzkowski (Canada) considered that there may be a risk but attention will be required to maintain the HRD in line with the new technologies. The chairman emphasised that the HRD is not intended to impede the introduction of new technologies. In response Mr Schmidt (CLEPA) asked for an assurance that it will still be possible to introduce new technologies into existing regulations. Mr Gorzkowski (GRE Chairman) emphasised that nothing changes and the device regulations will always be the basis for type approval and will continue to be amended as is current practice.
Mr Dutrieux (IMMA) asked how the group foresees the impact on Regulations 53, 74 and 86 relating to installation requirements of two wheeled vehicles and forestry vehicles to understand how this will impact upon the workload of IMMA. Mr Gorzkowski (GRE Chairman) commented that the first phase of the work will focus on the component regulations but longer term the installation regulations will also be included as part of the scope of the group.
26. The expert from France, Chair of the informal group on Horizontal Reference Document informed GRE about its work progress in revisioning ECE/TRANS/WP.29/GRE/2008/32. He urged GRE experts to contribute to finalizing the proposal. The expert from Italy suggested removing of paragraph 6 from the proposal because it is too specific for each Regulation and thus cannot have a common reference. GRE considered including of the Horizontal Reference Document into an Annex to Consolidated Resolution (R.E.3). GRE agreed to resume discussion on this agenda item at its October 2011 session.
34. The Chair of the informal group on a draft Horizontal Reference Document for lightsignalling devices introduced GRE-67-35 as draft report of the work of his group. GRE agreed with the suggestion of the Chair of the informal group to suspend the work of this group due to the lack of progress made and to keep this item on the agenda of its October 2012 session.
36. GRE took note of the outcome of the first session of the Special Interest Group (SIG) which had taken place in Brussels on 12 February 2014 and had been attended by 20 experts (GRE-71-16). In particular, SIG was of the view that priority should be given to reducing the administrative burden presented by the numerous collective amendments. To achieve this, SIG proposed to reactivate the GRE Horizontal Reference Document (HRD) Informal Group and to update its Terms of Reference (ToR).
37. On behalf of SIG, the expert from EC presented draft ToR of a new informal working group (IWG) (GRE-71-22) and stated that EC would be prepared to act as Co-Chair of IWG. Regarding the position of Chair, he suggested that an EU member State or another Contracting Party assume this role. Before IWG becomes operational, SIG would continue its activities. In this respect, the expert from EC informed GRE that the second meeting of SIG would take place in Brussels during the week 9-13 June 2014.
38. GRE had a first exchange of views on the proposed ToR with a particular focus on paras. 2, 3 and 4 of GRE-71-22.
39. GRE addressed the issue of the legal implications of placing the common requirements into a horizontal reference document, such as R.E.3 managed by WP.29. The expert from EC and the secretariat pointed out that, if needed, they would seek legal advice from, respectively, EU and United Nations legal services. The secretariat informed GRE that R.E.3 had proved to be very instrumental for all UN Regulations, in particular, with regard to common definitions. In this context, the secretariat also drew the attention of GRE to the work undertaken by the secretariat to harmonize the definitions in lighting and light-signalling UN Regulations (GRE-71-23). GRE requested the SIG to consider this document and consolidate harmonized definitions into the horizontal document.
40. The Chair invited experts to consider the underlying issues, in particular the draft ToR of IWG in GRE-71-22 to be discussed at the next SIG session, and to report back to GRE at its next session. He also suggested that the newly proposed IWG take into due consideration ECE/TRANS/WP.29/GRE/2008/32, GRE-59-01, GRE 63-27, GRE-66-13 and GRE-66-14.