Comments from the United States on the draft Amendment 2 to GTR No. 9
Document GRSP-55-36
21 May 2014

The draft Amendment 2 to GTR No. 9 proposes to establish the new FlexPLI impactor as the single harmonized tool for lower leg impact tests. The amendment also proposes injury assessment reference values (IARV) to go with the FlexPLI. The US, however, has consistently expressed concerns that the proposed injury thresholds and IARV have not been validated as appropriate for the American car fleet. Therefore, the US proposes to have ‘recommended’ IARV included in the preamble to Amendment 2 while allowing governments the freedom to use whatever IARV/performance thresholds they deem appropriate until such criteria can be fully validated.

Submitted by USA
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Previous Documents, Discussions, and Outcomes
3. (a) | Proposal for Phase 2 of the global technical regulation

6. GRSP noted that the Administrative Committee of the 1998 Agreement (AC.3) at its March 2014 referred WP.29-162-03 to GRSP, concerning the Injury Assessment References Values (IARVs) for the flexible lower legform (FlexPLI) to bumper test, of the proposal for amendments to the UN GTR. It was also noted that referring this document back to GRSP, the establishment of the UN GTR would be delayed until an agreement on the IARVs would be reached by GRSP (ECE/TRANS/WP.29/1108, paras. 91 and 92). Therefore, the expert of the United States of America introduced GRSP-55-36, suggesting to amend the preamble of the draft UN GTR to allow Contracting Parties to choose appropriate values based on their cost and benefit studies and the existing injury risk curves. He concluded that establishing premature values, without the research results would introduce risks of dis-harmonization. The expert from Germany, supported by the expert from OICA, argued that this approach would not be, however, the most favourable one for harmonization. He suggested to put the development of UN GTR No. 9 – Phase 2 on hold until the expert from the United States of America completed his research and to concentrate the work on the corresponding UN Regulation No. 127.

7. Finally, GRSP agreed to resume discussion at its December 2014 session, based on further research results and requested the secretariat to distribute GRSP-55-40, GRSP-54-33-Rev.2 (draft UN GTR) and GRSP-54-34-Rev.1 (draft final report of the IWG) with official symbols.

3. (a) | Phase 2 of the global technical regulation

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.

8. GRSP recommended ECE/TRANS/WP.29/GRSP/2013/25, as amended by Annex II to the session report and adopted the final progress report of the IWG (GRSP-54-34-Rev.1), as reproduced in Annex II. GRSP agreed to seek guidance of the Executive Committee of the 1998 Agreement (AC.3) at its March 2014 session concerning IARVs of para. 5.1.1. and seek endorsement of AC.3 to extend the mandate of the IWG until November 2014 to complete the addendum to M.R.1 to incorporate the FlexPLI. Finally, GRSP requested the secretariat to submit the proposal as draft Amendment 2 to UN GTR No. 9 and its final progress report to AC.3 for consideration and vote at its June 2014 session.

3. (b) | Proposal for Amendment 1
Related and Previous Documents
GRSP/2013/25
Relates to GTR No. 9 |