Netherlands comments on the conceptual framework and principles for functional performance requirements for automated vehicles.

Dutch Safety Board report on ADs-equipped vehicle safety performance issues.

Proposal by the expert from the Netherlands, aiming to achieve an identification of hydrogen-fuelled buses and trucks which is consistent with already existing regulated identification for Liquified Petroleum Gas (LPG), Compressed Natural Gas (CNG) and Liquid Natural Gas (LNG) fuelled buses. The background for the additional labelling would help emergency services to determine how to approach these vehicles in case of a fire. This proposal extends the scope to N2/N3 vehicles due to the wider use and introduces consistency for the installation of labels

24. GRSP resumed consideration on a proposal (ECE/TRANS/WP.29/GRSP/2020/10 and amendment GRSP-67-12) tabled by the expert from the Netherlands aimed at identifying hydrogen-fuelled buses which would be consistent with already existing regulated identification for Liquid Petroleum Gas, Compressed Natural Gas and Liquid Natural Gas fuelled buses. The expert from OICA introduced GRSP-67-29 amending, among others, the proposed transitional provisions. GRSP agreed to resume discussion of this subject at its December 2020 session based on a revised proposal tabled by the expert from the Netherlands in cooperation with the expert from OICA.

Netherlands comments on the working draft GTR on EDR.

During the Task Force meeting on Tyre Pressure Monitoring Systems, which was held on February 17th, 2020, there was a discussion on the proposed definition “Twin wheel”. This document provides the references to the terms ‘Dual’, ‘Twin’, ‘Twinned’ and ‘Twinning’ in the different directives and regulations.

VMAD co-chairs’ orientation presentation for the 7th session teleconference.

30. The expert from Poland requested deferral of discussion on the belt-guide, that was type approved by the authority of her country, to the December 2020 session of GRSP due to the research test results on the belt-guide, which had not yet been made available by the expert of EC. The experts from the Netherlands and ANEC/CI argued that discussion was needed on this subject since they considered this type of CRS as dangerous. The expert from the Netherlands introduced GRSP-67-05 explaining that the belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn. Finally, with reference to the procedure of the 1958 Agreement, Revision 3, Articles 4.2., 10.4 and Schedule 6 (paragraphs 2 and 3), he stated that through GRSP-67-05 he sought support from other contracting parties and cooperation from the expert of Poland to avoid starting the arbitration process – according to Schedule 6 of the 1958 Agreement. The expert from ANEC/CI, introduced GRSP-67-10 and GRSP-67-36 showing the high risk of abdominal injuries in both cases due to severe submarining. In anticipation of the above-mentioned test results, the expert from Poland introduced GRSP-67-32, showing some results of tests demonstrating the performance of this belt-guide type under laboratory conditions. She also clarified that the belt-guide was type approved according to Supplement 10 to the 04 series of amendments. However, she added that according to some stakeholder opinions, this belt-guide type should had been tested according to Supplement 11, thus making the device subject to different criteria. However, she stated that in her opinion there was a clear legal basis which demonstrated that the type approval granted under Supplement 10 was the correct one. The expert of the Netherlands responded by stating that, apart from the fact that this device does not comply with several requirements of UN Regulation No. 44, a supplement only clarifies existing requirements or test procedures and does not introduce new requirements. Even when Supplement 10 was in force, it was evident that a belt guide could not be approved as a child restraint.

31. The expert from EC recalled to GRSP, that the group had agreed to his former proposal (ECE/TRANS/WP.29/GRSP/2019/28) to amend the scope of UN Regulation No 44 (Child Restraint Systems) with clarification that a belt-guide cannot be approved under Regulation 44 without being part of a child restraint system (see ECE/TRANS/WP.29/GRSP/66, paragraphs 27 and 28). However, he explained that EC had reconsidered the document submission to WP.29, since the interpretation that a “guide strap” and similar devices cannot be separately approved as a child restraint system, had already been endorsed by WP.29 at its March 2012 session (see ECE/TRANS/WP.29/1095, paragraph 35). Therefore, he introduced GRSP-67-31, that was only on the phase out of UN Regulation No. 44.

32. The Chair of GRSP referred to Schedule 6 of the 1958 Agreement, and stressed full consideration of the different opinions of the Type Approval Authorities of the concerned contracting parties, and of contracting parties applying UN Regulation No. 44. Therefore, the experts from France, Germany, Italy, Russian Federation, Spain, Switzerland and United Kingdom explicitly endorsed the request of the expert from the Netherlands to withdraw the type approval granted by Poland on the belt-guide, while none of the other present delegates indicated abstention or disagreement. The experts also noted that the Chair encouraged the expert of the Netherlands to continue discussions with the Type Approval Authority of Poland to seek cooperation with Poland in the aim to avoid the arbitration process according to Schedule 6 of the 1958 Agreement, which would start in the November 2020 session of WP.29.

33. GRSP also considered GRSP-67-14, tabled by the expert from France to correct a date in transitional provisions. Finally, GRSP adopted GRSP-67-14 and GRSP-67-31, as reproduced in Annex V to the session report. The secretariat was requested to submit the two proposals as draft Supplement 18 to the 04 series of amendment to UN Regulation No. 44, for consideration and vote at the November 2020 sessions of WP.29 and AC.1.

14. Referring to the request made by the Administrative Committee for the Coordination of Work of WP.29 (WP.29/AC.2) (see ECE/TRANS/WP.29/1155, para. 30), GRSP resumed discussion on the belt-guide device type approved as Child Restraint System (CRS) according to UN Regulation No. 44 by the Type Approval Authority of Poland. The expert from the Netherlands introduced a presentation (GRSP-68-24), showing additional test results performed on the belt-guide. He added that the tests confirmed the conclusion laid out in document GRSP-67-05, introduced at the July 2020 session of GRSP and in addition showed that the device does not conform to the dynamic test requirements when tested with the P10 dummy. Therefore, he stated:

1. The belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn.
2. The device did not meet several requirements, both technical and with regard to instructions for users and therefore approval should not have been granted.
3. The car design determines the level of protection for a great deal of cases and may result in submarining and/or in injuries in the abdominal area, since the device sold as a child restraint does not offer adequate protection or guidance in this respect.
4. The device could offer better protection than the adult belt itself but lacks the additional protection of a CRS.
5. Since approval of this device was issued erroneously, it shall be withdrawn, and Market Surveillance Authorities should be informed.

1. During last year there had been numerous different unsubstantiated allegations against the belt guide, e.g.: submarining (GRSP-50-09 and GRSP-50-25), vertical component (GRSP-65-20), risk of abdominal injury. However, he added these allegations were not demonstrated.
2. Type-approval tests according to the UN Regulation requirements were conducted by Polish technical service – PIMOT in 2017, which conducted more than 160 tests by using dummies required by the UN regulation (P3, P6 and P10 type), showing satisfactory results.

He concluded that in December 2019, after comparative tests with other CRS showed problems with other type-approved CRS, the discussion in GRSP should be broadened to focus on other CRS as well. The expert from Spain, stated that the focus should be on the interpretation that a belt-guide and similar devices cannot be separately approved as a CRS.

Proposal to update the draft 01 series proposal (GRSP/2020/10) to include recommendations with regard to place and dimensions of the labels on vehicles.

24. GRSP resumed consideration on a proposal (ECE/TRANS/WP.29/GRSP/2020/10 and amendment GRSP-67-12) tabled by the expert from the Netherlands aimed at identifying hydrogen-fuelled buses which would be consistent with already existing regulated identification for Liquid Petroleum Gas, Compressed Natural Gas and Liquid Natural Gas fuelled buses. The expert from OICA introduced GRSP-67-29 amending, among others, the proposed transitional provisions. GRSP agreed to resume discussion of this subject at its December 2020 session based on a revised proposal tabled by the expert from the Netherlands in cooperation with the expert from OICA.

Proposal to align UN R134 with UN R67 and UN R110 with regard to labelling requirements and to assist emergency services in determining appropriate responses in case of fire.

25. GRSP resumed consideration on a proposal (ECE/TRANS/WP.29/GRSP/2020/17) tabled by the expert from the Netherlands aimed at identifying hydrogen-fuelled buses which would be consistent with already existing regulated identification for Liquid Petroleum Gas, Compressed Natural Gas and Liquid Natural Gas fuelled buses. GRSP adopted the proposal not amended and requested the secretariat to submit ECE/TRANS/WP.29/GRSP/2020/17 as draft 01 series of amendments to UN Regulation No. 134, for consideration and vote at the June 2021 sessions of WP.29 and AC.1.

26. The expert from OICA also noted that further discussions on the UN Regulation would be needed to solve a number of inconsistencies concerning heavy-duty vehicles (trucks and buses). GRSP agreed to resume discussion on this subject at its May 2021 session on the basis of a proposal tabled by the expert from OICA.

Proposal to align UN R58 with EU Regulation 1230/2012 with regard to access ramps.

35. The expert from the Netherlands presented a proposal for an amendment of Part II and III of a type of rear underrun protective device (RUPD) pursuant to UN Regulation No. 58 (GRSG-119-15), addressing platform lift systems and access ramps in M, N1, N2 category vehicles.

36. GRSG decided to continue consideration of document GRSG-119-15 at the April 2021 meeting of the group, based on a revised version pending further consultations on its content.

Proposal to adapt to technological progress and align UN R110 with ISO 15500 and NGV 3.1.

44. The expert from the Netherlands introduced document GRSG-119-16, containing a proposal for amendments to UN Regulation No. 110, proposing the introduction of requirements related to the state-of-the-art test requirements and harmonization with ISO 15500 and NGV 3.1 components used in LNG/CNG systems.

45. GRSG considered document GRSG-119-16 and requested its submission as an official document for consideration at the April 2021 session of GRSG.

Proposal to clarify the requirements for the location of ISOFIX systems in case the vehicle type is equipped with rearward facing seats.

47. The expert from the Netherlands introduced GRSP-68-16 to clarify the issue of ISOFIX anchorages on seats that are permanently rearward facing. The expert from OICA asked more discussion to develop the proposal. GRSP agreed to resume discussion on this subject, at its May 2021 session, on the basis of the outcome of a group of interested parties involving the experts from Germany, Sweden, CLEPA and OICA.

14. Referring to the request made by the Administrative Committee for the Coordination of Work of WP.29 (WP.29/AC.2) (see ECE/TRANS/WP.29/1155, para. 30), GRSP resumed discussion on the belt-guide device type approved as Child Restraint System (CRS) according to UN Regulation No. 44 by the Type Approval Authority of Poland. The expert from the Netherlands introduced a presentation (GRSP-68-24), showing additional test results performed on the belt-guide. He added that the tests confirmed the conclusion laid out in document GRSP-67-05, introduced at the July 2020 session of GRSP and in addition showed that the device does not conform to the dynamic test requirements when tested with the P10 dummy. Therefore, he stated:

1. The belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn.
2. The device did not meet several requirements, both technical and with regard to instructions for users and therefore approval should not have been granted.
3. The car design determines the level of protection for a great deal of cases and may result in submarining and/or in injuries in the abdominal area, since the device sold as a child restraint does not offer adequate protection or guidance in this respect.
4. The device could offer better protection than the adult belt itself but lacks the additional protection of a CRS.
5. Since approval of this device was issued erroneously, it shall be withdrawn, and Market Surveillance Authorities should be informed.

1. During last year there had been numerous different unsubstantiated allegations against the belt guide, e.g.: submarining (GRSP-50-09 and GRSP-50-25), vertical component (GRSP-65-20), risk of abdominal injury. However, he added these allegations were not demonstrated.
2. Type-approval tests according to the UN Regulation requirements were conducted by Polish technical service – PIMOT in 2017, which conducted more than 160 tests by using dummies required by the UN regulation (P3, P6 and P10 type), showing satisfactory results.

He concluded that in December 2019, after comparative tests with other CRS showed problems with other type-approved CRS, the discussion in GRSP should be broadened to focus on other CRS as well. The expert from Spain, stated that the focus should be on the interpretation that a belt-guide and similar devices cannot be separately approved as a CRS.

14. Referring to the request made by the Administrative Committee for the Coordination of Work of WP.29 (WP.29/AC.2) (see ECE/TRANS/WP.29/1155, para. 30), GRSP resumed discussion on the belt-guide device type approved as Child Restraint System (CRS) according to UN Regulation No. 44 by the Type Approval Authority of Poland. The expert from the Netherlands introduced a presentation (GRSP-68-24), showing additional test results performed on the belt-guide. He added that the tests confirmed the conclusion laid out in document GRSP-67-05, introduced at the July 2020 session of GRSP and in addition showed that the device does not conform to the dynamic test requirements when tested with the P10 dummy. Therefore, he stated:

1. The belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn.
2. The device did not meet several requirements, both technical and with regard to instructions for users and therefore approval should not have been granted.
3. The car design determines the level of protection for a great deal of cases and may result in submarining and/or in injuries in the abdominal area, since the device sold as a child restraint does not offer adequate protection or guidance in this respect.
4. The device could offer better protection than the adult belt itself but lacks the additional protection of a CRS.
5. Since approval of this device was issued erroneously, it shall be withdrawn, and Market Surveillance Authorities should be informed.

1. During last year there had been numerous different unsubstantiated allegations against the belt guide, e.g.: submarining (GRSP-50-09 and GRSP-50-25), vertical component (GRSP-65-20), risk of abdominal injury. However, he added these allegations were not demonstrated.
2. Type-approval tests according to the UN Regulation requirements were conducted by Polish technical service – PIMOT in 2017, which conducted more than 160 tests by using dummies required by the UN regulation (P3, P6 and P10 type), showing satisfactory results.

He concluded that in December 2019, after comparative tests with other CRS showed problems with other type-approved CRS, the discussion in GRSP should be broadened to focus on other CRS as well. The expert from Spain, stated that the focus should be on the interpretation that a belt-guide and similar devices cannot be separately approved as a CRS.