Submission from France and Germany further explaining why belt guide devices such as that cited by CLEPA in document GRSP-50-09 cannot be approved as a child restraint system. Document GRSP-50-28 provided results of the Latin NCAP crash tests.
27. The expert from EC introduced ECE/TRANS/WP.29/GRSP/2019/28 aimed at clarifying the types of belt-guides and sitting devices that would not be allowed by means of an explanation in the scope of the UN Regulation. The expert from Poland argued that the proposal from EC was restrictive and requested a facts-based discussion on this proposal or a simple rejection in full. He introduced a presentation GRSP-66-19, showing that one of the devices in ECE/TRANS/WP.29/GRSP/2019/28 was fully compliant with UN Regulation No. 44 and safer compared to other type approved CRS. The expert from Spain introduced GRSP-66-30 which provided counter evidence that belt-guide devices would not comply to a number of relevant requirements of UN Regulation No. 44. The expert from Japan introduced a presentation (GRSP-66-38) showing the sled test conducted on Q dummies to check safety-belt penetration according to UN Regulation No 129 requirements. He concluded that the abdominal pressure on the belt-guide device was found to be rather high compared to CRS type approval according to UN Regulation No. 129, but that it satisfied the requirements of the UN Regulation.
28. Finally, the majority of GRSP experts, with the exception of the expert from Poland, adopted ECE/TRANS/WP.29/GRSP/2019/28, not amended. The secretariat was requested to submit the proposal as part of (see para. 26) Supplement 18 to the 04 series of amendments to UN Regulation No. 44, for consideration and vote at the June 2020 sessions of WP.29 and AC.1.
| GRSP/2019/28 |