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Child safety in buses: Comments on document GRSG-121-02
Document STCBC-06-03
22 April 2021
Submitted by CLEPA
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2. (a) | UN Regulation No. 107 (M2 and M3 vehicles)

15. The expert from Spain, Chair of the IWG on Safer Transport of Children and Busses and Coaches (IWG-STCBC) that is working under the mandate of the Group of Experts on Passive Safety (GRSP), presented the latest activities of the IWG (GRSP-68-03). He explained that the group was examining different configurations of testing (e.g.: seating position, Q-dummies with or without CRS, types of CRS) considering bus requirements (UN Regulations No. 80 and 107). He stated that the progress of the work in terms of the initially envisaged timeline had been delayed due to COVID-19 circumstances.

16. The secretary of GRSP thanked the Chair of the IWG on STCBC on introducing the topic. He informed GRSG about discussions that took place at GRSP upon presentation of the report of the activities of the IWG on STCBC at the December 2020 session of GRSP (ECE/TRANS/WP.29/GRSP/68, para. 33).

17. The expert from OICA presented the position paper of OICA regarding the activities of the IWG on STCBC (GRSG-121-02). He recapped the activities of the IWG that had been in progress, introduced OICAs observations concerning the work of the IWG and presented a list of questions in this respect that OICA had drafted for GRSG consideration. The expert from OICA also introduced a presentation (GRSG-121-03), which expanded the observations of her organization regarding the activities of the IWG on STCBC and arguing on the consequences of considering UN Regulation No. 129 (Enhanced Child Restraint Systems (ECRS) provisions for installation of ECRS on buses (e.g. seat spacing and further loss of seats in the vehicle) that in her opinion were not compatible with bus interior arrangements.

18. GRSG took note of the information presented by the expert from OICA. The Chair of GRSG thanked OICA for providing the organizations views on the activities and possible outcomes of the work of the IWG on STCBC. He invited GRSP to provide GRSG with their conclusions and recommendations in this respect, prior to moving forward in addressing the observations and questions put forward by OICA. He also suggested to consider the possibilities of built-in (incorporated into bus seats) child restraint systems to cope to some of the issues indicated by the expert from OICA.

19. The expert from CLEPA, secretary of the IWG on STCBC, presented document GRSG-121-33, which contained CLEPA’s comments to the OICA position paper (GRSG-121-02). He also confirmed that the IWG on STCBC would consider the above-mentioned suggestion of the Chair of GRSG.

20. The expert from Germany called on, given the activities and responsibilities of GRSG in the context of regulating the construction of buses and coaches, a strong exchange and cooperation between the IWG on STCBC and GRSG, also in investigating the extent of the impact of the work of the IWG on STCBC in the context of UN Regulation No. 107. He also recalled GRSG that the issue of securing children on buses was a longstanding discussion held in GRSP. He added that experts of this Working Group agreed to resume discussion on this issue once that UN Regulation No. 129 had been finalized.

21. The expert from OICA called on the participation of GRSG experts in the work of the IWG on STCBC, underlining the relevance of UN Regulations under the purview of GRSG to the work of the IWG on STCBC and the expertise of GRSG experts in terms of the construction of buses and coaches.

22. Upon a further technical discussion, with comments from experts representing France, Germany, CLEPA and OICA, the Chair of GRSG invited experts of GRSG to actively participate in the work of the IWG on STCBC, and for the coordination of activities in this respect between GRSG and GRSP, in order to ensure the safest possible transport of children in buses and coaches, while simultaneously finding solutions to avoid major consequential impacts on the structure of buses and coaches. He invited the IWG on STCBC to update GRSG on the progress of its work at the next session of GRSG in October 2021.

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