Background:
- - SDWEE-05 recognized some safety improvement in harmonization of the movement of the emergency exits controls. Industry conceded some costs efforts for the sake of this safety improvement, and the informal group agreed on a mandatory rotary control.
- - SDWEE-05-05 proposes some amendments to the text of the regulation for mandating a power-operated service door control to be operable via a rotary movement in the case of an emergency
- - SDWEE-04-06 proposes draft recommendations on the functionality of door release devices
- - SDWEE-06-02 proposes that all controls be easily operated, keeping some flexibility between three possible movements for their operation.
- - SDWEE-07-03 provides the dimensions of some of the emergency exit controls in the current Alexander-Denis production
- - SDWEE-07-04 provides the dimensions of some of the emergency exit controls in the current VanHool production
Mr. Borros introduced the document SDWEE-06-02 stressing that the rotary movement in case of emergency could be difficult in some circumstances and proposing the choice between 3 movements for the interior control.
Mr. McKenzie recalled the document SDWEE-04-06 coming from the aviation Industry, and pointed out that the rescue teams could find benefits in having a harmonized movement for the exterior emergency control, while some flexibility would be appreciated for the interior control.
Plaxton voiced that the currently proposed value of 2Nm is far too low for mechanical interior emergency controls. Inputs from VanHool indeed indicate that state of the art is at values of about 10Nm (pneumatic valve).
The group reiterated the debate about the key criterion of whether the movement would have to be harmonized. The informal group hesitated to confirm again the decision of SDWEE-05 relative to a harmonized, rotary movement. The experts were well aware that such confirmation could jeopardise the introduction of future better solution. It was mentioned that a lot of the other emergency movements in the society are by a “pushing” movement.
The group faced the situation of choosing again a harmonized movement.
In addition, it was felt beneficial that the mandatory movement be in the “direction” of door opening, making the movement natural, i.e. pulling for external control, and pushing for interior control.
Further debates, and the information from SMMT that handicapped persons would face difficulties in operating a rotary control (result of further consultation held within the time between the previous meetings and the current meeting), led to a new decision such that the interior control should be a “push” movement. This was challenged by Germany which was still in favour of keeping the previous decision of a mandatory rotary control.
The group established a table aiming at summarizing the pros and cons of each technical solution with regard to each parameter (see below). After some debate, it was agreed that interior and exterior emergency controls can be considered equivalent with regard to the parameters and decisions in stake.
|
Interior and exterior emergency control |
Comment and justification |
| Mandatory movement |
decision |
Justification |
Turning to a push button would imply relevant transitional provisions. Operation of the control should anyway be well explained and easy to do.
Mandatory rotary control for exterior is challenged by Mr. Becker because consideration of exterior emergency controls was not the task the group gave to itself. This would provoke unnecessary costs for the manufacturers. MAN committed to provide input on this issue.
It was suggested to let flexibility for both interior and exterior controls. |
| None (movement kept optional to the manufacturer) |
Interior rotary emergency controls may be difficult to be used by disabled people hence should not be mandated. |
| Permitted movement range |
Angular motion: [90°] in total, permitting 2 × 45°
Linear motion: [between 3 and 38 mm] |
To be internally checked 3-38 mm is coming from the aviation. This would prohibit sensitive sensors. |
| Mandatory Colour |
Red or Red with yellow background |
no need for further definition of colour |
| Maximum torque |
Nm |
To be internally checked. Criterion is “control to be easily operated” |
| Maximum force |
N |
To be internally checked. Criterion is “control to be easily operated”. Plaxton current value: 102 N |
| Minimum dimensions |
Rotary: Ø mm
Non rotary:
* – Push button: Ø mm
* – Lever: mm length |
Square-like buttons do also exist. In this case the value applies to the diagonal |
| Misuse prevention |
copy/paste service door provision, i.e.: “The emergency doors shall be prevented from opening if the vehicle moves at a speed higher than 5 km/h” |
Current national interpretations are sometimes contradictory (mandatory vs. prohibited coverage).
7.6.7.5. of Annex 3:
“7.6.7.5. Emergency doors shall be proofed against unintentional operation. However, this requirement shall not apply if the emergency door is locked automatically when the vehicle is moving at a speed exceeding 5 km/h.” (emergency doors)
7.6.5.1.8. The doors shall be prevented from opening if the vehicle moves at a speed higher than 5 km/h” (power-operated service doors)
The experts committed to internally check the relevancy of mandating some coverage above the interior and exterior emergency controls (referring to paragraph 7.6.5.1.6.) |
| Free space around the control |
The form of the device and the size of any apertures or housings shall be capable of allowing easy access and operation of the device by a gloved hand having a closedfist width of [140 mm]. |
The experts committed to internally check the relevancy of the provisions for a free space around the control. |
Mr. McKenzie committed to provide input from the manufacturers within SMMT which raised
the issue of disabled people ability of operating the rotary controls.