The delegate from J informed that the document is a pilot project for assessing the possibility of OBD for safety systems.
OICA had the following comments:
Misunderstanding in what is OBD: OBD is not necessarily an electronic interface readable by a scan-tool. This is the technical solution chosen for emission systems, where the history and background is different from safety systems. OBD is primarily a system which has the capability of detecting malfunctions and to communicate them off-board. The definition in OBDGTR clarifies what is OBD.
The safety systems currently in the vehicles do fulfil most of the OBD requirements (e.g. the system has the capability of detecting malfunctions and indicating their occurrence by means of an alert system…). Safety regulations have followed a different route compared to emission system regulations (e.g. fault detection and warning to driver is required “since forever” for safety systems. This approach is consolidated by the CEL Annex, which does not exists for emissions).
OBD is a subject wider than LKAS/ACSF, hence should be discussed at another level.
Do not confuse roadworthiness (safety at PTI) vs. repair and maintenance at service station.
e.g. the EBS contains 1100 failure codes
Only the effect of the faiures on the performance of the system is important for safety, not the root cause of the failure.
The root cause of the failure is important only to repair the vehicle.
OBD provisions cannot be copy/pasted from emissions as emissions are one system while safety systems are maybe 15 or 20 systems or functions, with different variants for every manufacturers… Thus the emission approcah is not relevant for safety systems. It would generate huge costs for industry, without clear benefits.
Data are protected by private life data protection as they own to the vehicle driver.
The expert warned about the danger of actuating the equipment for the sake of PTI as this can damage some safety devices.
Anti-tampering: when all codes and protocols are freely available, then hackers have easier access to the manufacturers internal safety systems. From this standpoint, current UNECE requirements are securing the confidentiality of vehicle manufacturers measures to protect against simple unauthorized modification (e.g. 5.5.2.1 in UN R79).
The Chair recalled about the never ending discussions being held with OBD for emissions.
The European Commission
informed that they are looking to the possibility to mandate OBDX for safety systems, in the frame of roadworthiness. The expert from the European Commission was of the opinion that there is no need to check at PTI that the vehicle systems which are optional have to correctly function (example of the wiper).
Was keen that OBD be discussed in depth within this informal group.
J was keen that the driver can maintain the vehicle/system by himself, hence the need to make the data and protocols available. He found unfair that the dealer has access to the data, and not the owner. Yet the owner can buy the necessary equipment.
OICA reminded repair and maintenance is a topic which is separate and not linked to safety or roadworthiness of the vehicle.
The Chair cited the recitals (17) of the EU directive 2014/45. (note: recitals in EU directives are not requirements).
NL stated that OBD should not be used for checking safety system at PTI. The tell-tale should illuminate when there is a direct danger, no need for OBD in this perspective. PTI should remain a simple check.
Conclusion:
- European Commission to provide input on this item for next meeting
- Item to remain in agenda.
- Strong reluctance from Industry.