Alternative solution from OICA to the German proposal GRSG/2017/16 regarding visibility/access requirements for PRV/PRD-related components in order to improve maintenance and reduce the risk of critical failures of pressure relief devices. The proposal also proposes amending provisions of the ageing test in Annex 15 in response to concerns over failures of rubber hoses.

In the absence of complete harmonization with ISO 11439, this proposal recommends that Table 6.4 of UN R110 should be amended by the following for CNG-1 designs:

1. Delete A.17, A.25, and A.7 since they do not match the tests specified in paragraph 7.5 on Cylinder design qualification tests
2. Add A.15 and A.6 since they do match the tests specified in paragraph 7.5 on Cylinder design qualification tests
3. Add A.24 because paragraph 6.9 on Fire protection requires all PRDs on all cylinder types to comply with A.24.

Proposal to clarify the test requirements in alignment with the French text of the regulation by amending paragraph 5.10 to read “Tanks shall be installed in such a way as to be protected from the consequences of a collision to the front or the rear of the vehicle; there shall be no protruding parts, sharp edges, etc. near nearby all around the tank tanks.” The proposal aims to clarify the inspection of potentially protruding parts around the tanks in order to ensure their integrity in the event of a collision.

Proposal to amend geometrical criteria (dimensions and distances between lateral protection devices) and installation provisions for lateral protection barriers in order to improve their performance with regard to vulnerable road users. The proposal would

1. increase the maximum distance between lateral rails from 300 mm to 400 mm
2. redefine the limits for the lower edge from “550 mm above the ground” to definition via an isosceles triangle formed by lines drawn at 8° from the ground contact points of the vehicle tires intersecting at point “I” above the road surface where the maximum limit “I” is between 350-450 mm
3. define the upper edge as from 450 mm rather than 300 mm maximum from the vehicle structure or maximum height of the upper edge above the ground from 950 mm to 850 mm
4. update the horizontal static force requirement for lateral protection devices to 3 kN and the deflection under load criteria to 90 mm over the rearmost 250 mm of the device and 450 mm over the remainder of the device.

Proposal pursuant to discussions on the application of footnote ¹⁸ under Table 1 concerning tell-tale symbols and the use of colours to convey different meanings. ISO standard 2575-2004, para. 5.1. allows for the use of different colours to convey a change in the operating condition. This proposal would remove the current footnote ¹⁸ text and application of the footnote to telltales 2, 9-12, and 19 pending a decision on the proposal to apply a revised footnote to the master lighting switch (tell-tale 1). Paragraph 5.4.1.1. of UN R121 references ISO 2575-2004 which was developed to simplify the application of UN R121 when colour changes are adopted in other UN Regulations; however, OICA submits that the footnote which references ISO 2575-2004 in relation to specific lighting devices or systems creates a degree of confusion. (If approved, this proposal would likely impact Supplement 3 to the 01 series rather than Supplement 2 given that WP.29 at its November 2017 session adopted the proposal to add a telltale and symbols for “Accident Emergency Call System (AECS)” and to align UN R121 with the 07 series of amendments to UN Regulation No. 16 as Supplement 2 to the 01 series.)

Proposal to amend Annex 7 (laminated-glass panes), inserting a new paragraph 6. to allow optional 2,260 g ball test and headform test for laminated-glass panes. The proposal aims to amend UN R43 to enable the approval of the laminated-glass panes with improved mechanical properties, especially as designed for front, exterior, forward-facing glazing of the upper deck of a double-deck vehicle.

Proposal to clarify that overlays may only be used to convey “safety-related rearward vision information.” The proposal addresses confusion regarding circumstances under which the provision of information through overlays is permissible. The proposal also amends the French text. The overall proposal aims to make clear that overlays may convey safety information regarding the rearward environment of the vehicle and are not necessarily limited only to when the vehicle is moving in reverse. The proposal also aims to restrict the information to rear-vision safety. Other information, not related to the rear view, should never appear within the defined field of view.