UN R127: Proposal for the 03 series of amendments
Document GRSP-70-17
3 December 2021
Submitted by Germany
Status: Superseded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.

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

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.

2. (a) | GTR 9: Proposal for Amendment 3

4. GRSP Chair, informed GRSP of the discussion held at the March 2021 session of the Executive Committee of the 1998 Agreement (AC.3) (see ECE/TRANS/WP.29/1157, paras. 143 to 148). GRSP Chair recalled GRSP that AC.3 agreed to defer vote under this agenda item to its June 2021 session pending further discussions concerning the proposal for Amendment 3 to UN Global Technical Regulation (UN GTR) No. 9 at the next session of GRSP, scheduled to take place in May 2021. He also reminded that AC.3 requested GRSP to give highest priority to the task and to report back to AC.3 and WP.29 with the greatest urgency on the progress towards a resolution of outstanding matters in this context. He continued that to that end, he had contacted the concerned Contracting Parties including AC.3 Chair and the GRSP Secretary, to meet at the earliest possible date and asked the new expert representing the United States of America to report on the developments since WP.29. The expert of the United States of America informed GRSP about the meeting of the interested experts held virtually on April 23, when especially the experts from the United States of America and Germany, presented on the findings and conclusions of their respective experts. It was agreed that more discussions are warranted and with inclusion of the industry. During that time, United States of America and Germany continued the dialogue and exchanges of views and technical information to find a solution. She also added that experts met on Monday, May 17, just prior to GRSP meeting and agreed to establish as soon as possible a task force to solve the issue between the May and December 2021 GRSP sessions. She assumed that the first meeting of the task Force would be held on June 14 and that most likely a proposal would be ready by the GRSP meeting in December 2021. The experts from Germany, EC, Canada, United Kingdom of Great Britain and Northern Ireland, Japan, the Netherlands, and Republic of Korea, supported the United States of America approach and underlined the relevance of timing. The expert from the United States of America proposed to include other relevant issues in the programme of work of the Task Force. The expert from OICA stressed the importance not to delay the finalisation of the extension of the impact zone, explaining that this is urgently needed due to the European Union requirements of the General Safety Regulation which are already decided in general (including the application dates), but which are currently under development in the framework of UN Regulation N° 127. He feared that, if such topics are referred back to GTR N°9, then the deadlines would not be respected, creating for industry a legal void. The experts from the Netherlands and the United States of America introduced GRSP-69-43-Rev.1 amending the previous authorization to develop Amendment 3 (ECE/TRANS/WP.29/AC.3/31). GRSP recommended on provisional basis ECE/TRANS/WP.29/AC.3/31/Rev.1, as reproduced in Annex II to this report, to provide a revised request of authorization of work to finalize Amendment 3 to UN GTR No. 9 (Pedestrian safety) for consideration to the June 2021 session of AC.3. To ensure the work proceeds in a timely manner, GRSP agreed to establish a Task Force, and it was recommended to withdraw the current proposed Amendment 3 from consideration and vote at the June 2021 session of AC.3. Moreover, GRSP agreed to forward documents under agenda item 11 (ECE/TRANS/WP.29/GRSP/2019/18, ECE/TRANS/WP.29/GRSP/2020/9 and GRSP-69-21-Rev.1) to the TF for consideration (see para. 20 below).

11. | UN Regulation No. 127 (Pedestrian safety)
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-69-21/Rev.1
GRSP/2019/18
GRSP/2022/4
GRSP-71-15/Rev. 3
Relates to UN R127 |