UN R127: Proposal for the 03 series of amendments
Document GRSP-67-07
9 July 2020

Counter-proposal to document GRSP/2019/18 to address pedestrian safety and active suspensions (a system which could change the vehicle height while driving (up to a defined driving speed, e.g. up to 39 km/h)). Since the vehicle height has an influence on the headform test area (WAD) 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 to be relevant for impact with a pedestrian.

Submitted by OICA
Status: Superseded
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Previous Documents, Discussions, and Outcomes
9. | UN Regulation No. 127 (Pedestrian safety)

22. The expert from Germany introduced ECE/TRANS/WP.29/GRSP/2022/24, on new provisions to cope with the Adjustable Ride Height Suspension System (ARHSS). GRSP also considered GRSP-71-15-Rev.3 amending ECE/TRANS/WP.29/GRSP/2022/24. GRSP adopted ECE/TRANS/WP.29/GRSP/2022/4 as amended by annex II (GRSP-71-15-Rev.3) to the report. The secretariat was requested to submit the proposal as the draft 04 series of amendments to UN Regulation No. 127 (Pedestrian Safety) for consideration and vote at the November 2022 sessions of WP.29 and AC.1. Moreover, GRSP agreed that the GRSP Chair would seek guidance at the WP.29 June 2022 session, highlighting the May 2022 session of GRSP, concerning the interpretation of the acceptance of type approvals to the preceding series of amendments (singular or plural) to be mentioned in transitional provisions of UN Regulations in general. In the meantime, GRSP agreed that the expert of Japan (Ambassador of IWVTA to GRSP) would inform the meeting of IWVTA IWG about this issue prior to the June 2022 session of WP.29.

11. | UN Regulation No. 127 (Pedestrian safety)

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.

11. | UN Regulation No. 127 (Pedestrian safety)

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.

19. | UN Regulation No. 127 (Pedestrian safety)

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.

Related and Previous Documents
GRSP/2019/18
GRSP-68-18
GRSP-71-15/Rev. 3
Relates to UN R127 |