Comments submitted by Israel on behalf of an association of motorcycle helmet communications equipment manufacturers.
17. The expert from Italy, Chair of the ad-hoc group on safety helmets introduced ECE/TRANS/WP.29/GRSP/2021/13, through a presentation (GRSP-69-19) to address the need of a text that can be enforced in a practical manner until specific requirements for the type approval of helmet accessories would be defined. GRSP adopted ECE/TRANS/WP.29/GRSP/2021/13, as amended by (GRSP-69-17) Annex IV of the session report. The secretariat was requested to submit the proposal, as draft Supplement 1 to the 06 series of amendment to UN Regulation No. 22 (Protective helmets), for consideration and vote at the November 2021 session of WP.29 and to AC.1.
13. The expert from Israel, explaining the point of view of the “motorcycle helmet communication”, introduced ECE/TRANS/WP.29/GRSP/2020/19 through a presentation (GRSP-68-15), proposing a temporary solution to the 06 series of amendments to the UN Regulation. He also proposed at the same time a revised definition of accessories allowed to be fitted in type approved helmets. He clarified that this temporary solution should be followed by a new proposal delivered by the IWG and asked that IWG consider some examples for communication accessories requirements as well as for helmets in his presentation. The expert from Sweden introduced GRSP-68-09, amending ECE/TRANS/WP.29/GRSP/2020/19. She expressed concerns that the issue was affecting the validity of type approval originally granted and she questioned who would bear this responsibility. The expert from the Netherland argued that the Israeli proposal was not acceptable because it was opened to any kind of accessories to be implemented on the helmet. The expert from Republic of Korea supported the proposal tabled by the expert from Israel. The expert from Germany stated that the proposal was a good basis to start discussion, but it was premature to draw specific conclusions. He explained that current requirements of the UN Regulation were aimed at limiting the use of aftermarket products, whose liability was not in the purview of helmet manufacturers. He suggested that GRSP experts engage in their discussions stakeholders from the helmet aftermarket industry (e.g: camera industry). The expert from Spain clarified that accessories should be intended to integrate the securing functionalities of the helmet (e.g.: tear-off films of inner visors, electronic devices and their support. The expert from Italy clarified that the IWG activities were suspended due to the lack of research results that would allow Phase 2 of the UN Regulation to begin and that this issue was not included in the scope of the IWG. Therefore, GRSP agreed to establish an ad hoc group of interested experts to discuss and devise at the earliest convenience a solution on this issue. The experts from France, Republic of Korea, The Netherlands, Israel, Italy, Germany, Spain and from the European Association of Automotive Suppliers (CLEPA) stated their availability to participate to the activities of the ad-hoc group. GRSP, also agreed to resume discussion on this agenda item on the basis of the outcome of the ad-hoc group.
14. The expert from Israel introduced a presentation (GRSP-67-09-Rev.1) explaining the point of view of the “motorcycle helmet communication” industry on the 06 series of amendments to the UN Regulation adopted by WP.29 at its June 2020 session. He clarified that the industry supports a UN Regulation which ensures motorbike rider safety. However, he argued that it should be implemented in a practical manner since the revised paragraph 7.3.1.3.5. of the UN Regulation requires that only accessories tested during the type approval procedure of the helmet could keep the type approval validity. He clarified that this requirement would create major trade barriers for the motorcycle helmet communication systems commonly used by motorbike riders. He therefore asked that the motorcycle helmet communication industry be included in the process of developing type approval requirements to overcome the trade barrier issue by: (a) specific tests for helmets ready for accessories, b) particular tests for communication accessories. Finally, he offered his expertise to develop amendments to consider aftermarket accessories. The expert from Italy, Chair of the IWG on Protective Helmets (IWG-PH), clarified in a presentation (GRSP-67-25) that the activities of the group were open to all stakeholders. Moreover, he added that UN Regulation No. 22 refers specifically to type approval of helmets and that the helmet manufacturer (type approval holder of a type protective helmet) is responsible for the conformity of the product and for the maintenance of the safety requirements tested during the type approval. He explained that the possible non-conformity of helmets, caused by installation of untested aftermarket products, would introduce liability issues.
15. GRSP noted that the IWG activities were suspended due to the lack of research results that would allow Phase 2 of the UN Regulation to begin. Therefore, GRSP endorsed the recommendation of the Chair of the IWG to provide a proposal of amendments addressing aftermarket accessories by the December 2020 session of GRSP. Finally, GRSP noted the offer of the expert of the United States of America to provide research results from NHTSA to the IWG once NHTSA had resumed its activities.
GRSP/2020/19 | |
GRSP-69-19 |