11. GRRF noted the outcome of the discussion in WP.29 on dynamic/static references to other UN Regulations and private standards (see report ECE/TRANS/WP.29/1093, paras. 48 and 49). GRRF endorsed the recommendation to proceed on a case by case approach awaiting a final decision by WP.29 at one of its next sessions.

12. The expert from CLEPA introduced ECE/TRANS/WP.29/GRRF/2011/35/Rev.1 clarifying the levels of braking performance of vehicles in relation with different positions of the ignition key. GRRF noted a number of comments. Following the discussion, CLEPA presented GRRF-72-27 amending ECE/TRANS/WP.29/GRRF/2011/35/Rev.1. GRRF adopted the proposal, as reproduced in Annex II, and requested the secretariat to submit it to WP.29 and AC.1, for consideration at their June 2012 sessions, as Supplement 14 to Regulation No. 13-H.

13. Recalling the purpose of WP.29-155-19, the expert from EC withdrew ECE/TRANS/WP.29/GRRF/2012/9. As a consequence, the expert from CLEPA withdrew ECE/TRANS/WP.29/GRRF/2012/7. Nevertheless, the experts from Germany, Japan and OICA expressed their support for ECE/TRANS/WP.29/GRRF/2012/9 and their preference to keep it on the agenda. The Chair concluded that the item should be revisited, together with the related document from CLEPA (GRRF-72-17), at the next GRRF session on the basis of a new proposal, if available.

14. The expert from Belgium reported on the progress (GRRF-72-08) made by the informal group on Alternative Method Electronic Vehicle Stability Control (AMEVSC). On behalf of informal group, the expert from CLEPA proposed to use simulation tools to prove compliance of the vehicle stability function (ECE/TRANS/WP.29/GRRF/2012/2). The expert from OICA introduced GRRF-72-22 on some weaknesses in the current simulation tool. GRRF noted a number of comments and agreed to refer the proposal back to the informal group. GRRF agreed to resume consideration on this subject at its next session on the basis of a revised proposal to be submitted by the informal group, taking into account GRRF-72-17, GRRF-72-22 and the comments received. GRRF noted that the informal meeting was scheduled to be held in Brussels (at CLEPA offices) on 10-11 May 2012.

15. The expert from Germany introduced ECE/TRANS/WP.29/GRRF/2012/11 and GRRF-72-28 on the introduction of an electro-hydraulic transmission for electrical brake systems. GRRF noted some concerns and agreed to resume the discussion on this subject to the next session of GRRF on the basis a revised proposal, if available.

There was insufficient time to discuss the various documents and, as a result, come to a conclusion. However, it was clear that there are still widely differing views on the responsibilities and implications in the use of test reports within a type-approval.

While it was agreed that only the vehicle manufacturer can obtain a braking system type-approval and in the case of a problem related to the type-approval it is the vehicle manufacturer who is responsible for the consequences, there was disagreement as to whether this was clearly the case in the actual use of a test report.

• ► Paragraph 3.3. specifies that “a vehicle, representative of the vehicle type to be approved, shall be submitted to the Technical Service conducting the approval tests.”
  • o Does this mean, for example, that:
    • a) the vehicle referred to in paragraph 3.3. and a vehicle in the test report shall be the same with regard to type, i.e. the same type from the same manufacturer, or
    • b) the vehicle referred to in paragraph 3.3. shall contain the same item that is the subject of the test report and the “approval tests” referred to in paragraph 3.3. are the tests to be carried-out at the time of type-approval for which there are no test reports.
• ► Regarding paragraph 3.4. is the need for the vehicle manufacturer to show conformity of production sufficient for the vehicle manufacturer to be aware of their responsibilities when using test reports.

As a means to resolve the issues surrounding the use of test reports, OICA suggested the replacement of the test report with a component or system type-approval and indicated that this was under investigation by a Germany Industry (VDA) special working group.

After a long discussion there remained widely differing views, with the consensus being that none of the proposals being considered provided a clear way forward in resolving these differences.

Therefore, it was agreed that no specific amendment proposal would be made to GRRF and the chairman would report on the various points that had been discussed with a view to GRRF deciding:

• - Is there a problem that requires resolution?
  • o Annex 21 specific, ECE R13 specific or ’58 Agreement specific?

In the event of a yes decision, the recommendation would be the establishment of a new informal working group.

• - Before the introduction of test reports within the type-approval process it was appropriate that the Technical Service conducting the type approval was provided with a vehicle on which to conduct the tests as required by the regulation, hence paragraph 3.3. – “a vehicle, representative of the vehicle type to be approved, shall be submitted to the Technical Service conducting the approval tests.” With the addition of test reports within the type-approval process, and no change to paragraph 3.3. does this mean, for example, that:
  • a) the vehicle referred to in paragraph 3.3. and a vehicle in the test report shall be the same with regard to type, i.e. the same type from the same manufacturer, or
  • b) the vehicle referred to in paragraph 3.3. shall contain the same item that is the subject of the test report and the “approval tests” referred to in paragraph 3.3. are the tests to be carried-out at the time of type-approval for which there are no test reports.

• - Should an Approval Authority only grant an approval when all the Technical Services providing test reports used in a braking system type-approval are designated by them for that specific work? Is there a difference in the case of a system type-approval and in the case of a vehicle type-approval?

Discussion points:

• - Is there a difference in responsibility when a Technical Service sub-contracts type-approval test work (with or without an Approval Authority approved test report) or when they receive an Approval Authority approved test report from another Technical Service that they then use in a type-approval? Is there a difference between a system type-approval and a vehicle type-approval?

• - Although it is only the vehicle manufacturer who can obtain a braking system type-approval and, as a result, it is the vehicle manufacturer who is responsible in the first instance for any resulting consequences, is it clear that this responsibility goes not go away when a provided test report is used in the type approval?

• - Is the need for the vehicle manufacturer to show satisfactory arrangements at the time of type-approval with regard to conformity of production, as required by paragraph 3.4., sufficient for the vehicle manufacturers to be aware of their responsibilities when using test reports?