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Document Title OICA comments to FEMFM proposal in document GRRF/2013/4
Reference Number GRRF-74-19
Date
13 Feb 2013
Summary Paper prepared by OICA contesting the proposal from FEMFM to apply the “identical disc/drum” philosophy to the definition of identical brake linings.
Source(s) OICA
Rulemaking Area(s) UN R90 Replacement Brake Components
Meeting(s)
Downloads
UNECE server .pdf format
Excerpts from session reports related to this document
GRRF | Session 74 | 19-22 Feb 2013

20. The expert from FEMFM introduced ECE/TRANS/WP.29/GRRF/2013/4 taking into account the remarks received during the previous session of GRRF. He recalled the purpose of the proposal and underlined that so called “chemically and physically identical replacement brake lining assemblies” and “chemically and physically identical drum brake linings” should not have to be retested but should be approved on the basis of the homologation of the original equipment supplier. In that case, the applicants for approval should only demonstrate that they supply the brake lining assemblies or the drum brake linings for the vehicle or brake manufacturer as original equipment for the specific model(s) for which approval is being sought, and that they produce the parts under the same production conditions, quality assurance system, and with the same results of the conformity of production tests as for the original parts. The expert from OICA introduced GRRF-74-19, expressing some concerns with the proposal made by FEMFM. The expert from Spain underlined the need for GRRF to confirm the endorsement of the philosophy behind the proposal made by FEMFM. The expert from the Russian Federation observed that the proposal is consistent with an approach which is already used in other parts of Regulation No. 90. The expert from CLEPA volunteered to organize a meeting with OICA, FEMFM as well as interested Contracting Parties and NGOs interested in this issue. GRRF agreed to resume consideration at its next session.