Statement of US concerns with the draft amendment to introduce the Flex PLI test tool into GTR No. 9 (document GRSP/2013/25) in particular with regard to the use of the injury assessment reference values (IARVs). US definition of the IARV will be dependent upon the outcome of a US cost-benefit analysis based upon the characteristics of the American vehicle population. The US cannot accept injury curves that do not fall within what is justifiable according to US traffic conditions.
7. The expert from Germany, co-Chair of the IWG on pedestrian safety introduced the draft UN GTR No. 9 Phase 2 (GRSP-54-33) to incorporate the flexible pedestrian legform impactor (FlexPLI), as a result of the last meeting of the IWG held on 16 and 17 December 2013, prior to the GRSP proper session. He explained that the proposal superseded ECE/TRANS/WP.29/GRSP/2011/13, ECE/TRANS/WP.29/GRSP/2013/25 and GRSP-54-08, leaving pending the issues of the Injury Assessment Reference Values (IARVs) for the flexible lower legform to bumper test (para. 5.1.1) and for the tolerance of the FlexPLI mass (paras. 6.3.1.1. and 6.3.1.1.3.). The proposal received comments from the expert of the United States of America (GRSP-54-32) who questioned the lack of information concerning the above-mentioned IARVs. He stated that the draft UN GTR could not be recommended unless Contracting Parties would be allowed to choose appropriate IARVs when transposing the UN GTR into their national legislations. In response, the expert from Germany introduced GRSP-54-33-Rev.2 addressing this concern. The expert from OICA regretted the lack of agreement on this last issue which would result in a number of options, thus hampering harmonization.