65. The expert from NGV Global presented document, GRSG-122-28, a proposal for amendment to UN Regulation No. 110. He recognized contributions from the expert from Hexagon agility and the expert from the Netherlands as they were both elemental in the preparation of this report. He stated the purpose of this proposal is to add a new “Annex 5R” to the test requirements, to demonstrate that the pressure relief device (PRD) will continually activate throughout its designed life.

66. GRSG adopted GRG-122-28 and requested its submission as formal document in the 123rd session of GRSG in March 2022. The Chair of GRSG suggested that it will be beneficial to have a consolidated version of the gas vehicle Regulations which are UN Regulations Nos. 67 and 110 as soon as possible as they have undergone several amendments. The secretariat of GRSG confirmed that these Regulations are in the process of being consolidated.

Updated proposal to clarify provisions for periodic testing and periodic requalification of Compressed Natural Gas (CNG) cylinders and Liquefied Natural Gas (LNG) tanks.

46. The expert from NGV Global introduced GRSG-117-18 amending ECE/TRANS/WP.29/GRSG/2019/26 introducing amendments to Annex 3A of the Regulation clarifying issues associated with periodical technical inspection (PTI) and periodic requalification of CNG cylinders.

47. GRSG adopted GRSG-117-18-Rev.1 amending ECE/TRANS/WP.29/GRSG/2019/26 and requested the secretariat to submit it to WP.29 and AC.1 as proposal for Supplement 1 of 04 series of amendments to UN Regulation No. 110 for consideration at their March 2020 sessions.

Proposal based on the outcomes of discussions by the GRSG task force on gas-fuelled vehicle regulations to clarify provisions for periodic testing and periodic requalification of Compressed Natural Gas (CNG) cylinders and Liquefied Natural Gas (LNG) tanks.

46. The expert from NGV Global introduced GRSG-117-18 amending ECE/TRANS/WP.29/GRSG/2019/26 introducing amendments to Annex 3A of the Regulation clarifying issues associated with periodical technical inspection (PTI) and periodic requalification of CNG cylinders.

47. GRSG adopted GRSG-117-18-Rev.1 amending ECE/TRANS/WP.29/GRSG/2019/26 and requested the secretariat to submit it to WP.29 and AC.1 as proposal for Supplement 1 of 04 series of amendments to UN Regulation No. 110 for consideration at their March 2020 sessions.

Proposal to introduce changes/additions in the Change of Design Table to better specify appropriate test requirements for CNG cylinders with composite materials and, in some cases, to harmonize with International Standard Organisation (ISO) standard 11439.

48. The expert from NGV Global introduced ECE/TRANS/WP.29/GRSG/2019/28 proposing certain change of design criteria in Annex 3 of UN Regulation No. 110. The expert from OICA supported the document and suggested some amendments (GRSG-117-28).

49. GRSG adopted ECE/TRANS/WP.29/GRSG/2019/28 as amended by GRSG -117-28 and requested the secretariat to submit it to WP.29 and AC.1 as proposal for Supplement 2 of 04 series of amendments to UN Regulation No. 110 for consideration at their March 2020 sessions.

Proposal to introduce changes and additions to the Change of Design Table to better specify appropriate test requirements for CNG cylinders with composite materials and, in some cases, to harmonize with ISO 11439.

40. The expert from NGV Global introduced GRSG-116-21 to amend Annex 3A of the Regulation on the design criteria and specifications for Compressed Natural Gas (CNG) cylinders with composite materials in line with standard ISO 11439. The proposal received general support. GRSG agreed to resume consideration of this subject at its next session and requested the secretariat to circulate GRSG-116-21 with an official symbol.

Proposal to address issues associated with periodic testing and periodic requalification of CNG cylinders.

Proposal for clarifications and editorial improvements to the draft amendment to require, in instances where that ogive covers be removed before conducting the impact damage (drop) test.

37. Recalling the discussion of GRSG at its previous session, the expert from Italy introduced ECE/TRANS/WP.29/GRSG/2018/16 to amend Annex 3A of the Regulation on the test requirements for Compressed Natural Gas (CNG) cylinders to avoid structural failures during their service life. The expert from NGV Global proposed some further clarifications (GRSG-115-06) and a new definition on “certified cylinder”. The proposals received general support.

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.

43. The expert from the NGV Global proposed to correct Table 6.4. on the cylinder design qualification tests (GRSG-113-06). GRSG noted general support on the proposal and agreed to take a final position on this subject at its next session. The secretariat was requested to circulate GRSG-113-06 with an official symbol.

Comments from NGV Global on the proposals from Italy (GRSG-112-28) and Germany (GRSG-112-33) regarding the testing and inspection of CNG cylinders.

39. The expert from Germany introduced ECE/TRANS/WP.29/GRSG/2017/17 to improve the specifications for the installation and inspection of Compressed Natural Gas (CNG) cylinders or of Liquefied Natural Gas (LNG) tanks and their accessories. GRSG welcomed the proposal and noted that WP.29 and the Administrative Committee of the 1997 Agreement were expected to consider and adopt ECE/TRANS/WP.29/2017/134 on a new UN Rule on Periodical Technical Inspections of motor vehicles using CNG and/or LNG in their propulsion system. The proposal from Germany received a number of comments, especially on the need to align the recommendations for the periodical technical inspections of such vehicles with the specifications for the re-qualification of the CNG cylinders or LNG tanks. GRSG noted the comments received by the experts from NGV Global (GRSG-113-03) and OICA (GRSG-113-20).

Proposal to include the liquefied natural gas (LNG) fuel connector provisions as specified in ISO 12617:2015.

37. The expert from the Netherlands presented ECE/TRANS/WP.29/GRSG/2016/9 aimed at correcting a typographical error and clarifying the current provisions of the Regulation. He also introduced ECE/TRANS/WP.29/GRSG/2016/10 proposing to insert provisions for LNG fuel connector as specified in ISO 12617:2015. Both documents received a number of comments. The expert from France raised a study reservation on the reference to the ISO standard in paragraph 2.2. of Annex 4J. Following the discussion, GRSG adopted both proposal as reproduced below and requested the secretariat to submit it to WP.29 and AC.1 for consideration at their November 2016 sessions, as part (see paras. 32 and 36 above) of draft Supplement 5 to the 01 series of amendments to UN Regulation No. 110:

Paragraph 7.1., correct “paragraphs 8.12. to 8.21.” to read “paragraphs 8.12. to 8.22.”.

Annex 4A, paragraph 4.2.4., correct “of Class 1 and Class 2” to read “of Class 2”.

Annex 4H, paragraph 2.2., correct “than 5 seconds” to read “than 2 seconds”.

Annex 4J
Paragraph 2.2., shall be deleted.

Paragraph 3.1.6., correct “shall be not be” to read “shall not be”.

Insert new paragraphs 4. and 4.1., to read:
“4. LNG filling receptacle dimensions
4.1. Figure 1 shows the dimensions of the LNG filling receptacle.

Figure 1
Dimensions of the receptacle
[Figure provided in the session report.]
"

38. GRSG agreed to resume consideration at the next session of GRSG on the ISO reference on the basis of a revised proposal jointly prepared by the Netherlands and NGV Global, taking into account the comments received.

Proposal to establish an informal working group to consolidate existing amendments to UN Regulation No. 110 in light of technical progress of other gaseous fuel regulations and standards and, where necessary, amend the Regulation to promote improved clarity and harmonization.

45. The expert from NGV Global introduced GRSG-108-02-Rev.1 justifying to withdraw from consideration at this time his initial proposal (GRSG-108-02) for the terms of reference to establish a IWG on Natural Gas Vehicles (NGV) to develop an amendment to UN Regulation No.110. GRSG agreed to resume consideration of this subject at one of its next sessions on the basis of a new proposal taking into account new input from the NGV stakeholders.

Proposal to add a definition for “CNG Accumulator” and to revise a related decision tree flow chart.

22. GRSG considered ECE/TRANS/WP.29/GRSG/2014/27 on introducing a new class of compressed natural gas (CNG) components (Class 6). The proposal received a number of comments from GRSG. The expert from IANGV introduced GRSG-107-38 (superseding GRSG-107-03), for the follow-up discussion. Finally, GRSG adopted ECE/TRANS/WP.29/GRSG/2014/27 as amended by Annex III of the GRSG-107 session report. The secretariat was requested to submit the proposal to the March 2015 sessions of WP.29 and AC.1 as draft Supplement 3 to the 01 series of amendments to UN Regulation No. 110.

Request to postpone consideration of the Dutch proposal concerning the discharge of natural gases from a pressure relief device (PRD) in anticipation of conclusions and best practices on the location and venting of PRD from a research program underway in the US.

24. The expert from the Netherlands introduced ECE/TRANS/WP.29/GRSG/2014/29 to regulate the direction of discharging the pressure relief devices of CNG containers. He explained that the proposal addressed the safety of not only the vehicle occupants but also the surrounding area. The expert from IANGV introduced GRSG-107-35, which suggests that the discussion should be deferred until after the outcome of the ongoing research conducted in the United States of America on this matter. The experts from France, Germany, Sweden and OICA questioned the impact of this proposal on design of vehicle categories M1 and N1. GRSG agreed to resume discussion on this subject at its May 2015 session on the basis of a revised document.

Proposal to establish an expert working group to review and update the provisions of UN Regulation No. 110 in order to produce a new consolidated, harmonized version of the regulation.

26. Recalling its request at the previous session, GRSG noted the availability of ISO STD 11439:2013 and ISO 6722 (GRSG-107-28) with a condition of limited use by GRSG experts. The expert from NGV Global introduced the terms of references (ToR) for the proposed IWG to revise the provisions of the UN Regulation (GRSG-107-02), including the harmonization of provisions related to private standards. The expert from Germany suggested that the proposed ToR needed improvement and added that he did not support the establishment of an IWG that would revise the UN Regulation without a clear description of tasks. The expert from France made similar comments and raised concerns on the availability of ISO standards. The Chair of GRSG suggested the possible solution of reproducing the part concerned with ISO STD 11439:2013 into Annex 3 of the UN Regulation rather than to reference it. GRSG agreed to resume discussion at its May 2015 session on the basis of a revised proposal tabled by the expert from NGV Global. Interested experts were invited to contact the expert from NGV to complete the revised draft ToR.

Text prepared by the Netherlands and the International Association for Natural Gas Vehicles (IANGV/NGV Global) to clarify the provisions of Chapter 18 following the introduction of automatic valves (see report GRSG/84, para. 38).

25. The experts from the Netherlands and IANGV introduced ECE/TRANS/WP.29/GRSG/2014/30 and its amendment GRSG-107-36 amending it. The expert from France raised a study reservation on the proposal and GRSG agreed to resume discussion on this subject at its May 2015 session on the basis of a revised official proposal by the Netherlands.

40. The expert from Belgium withdrew ECE/TRANS/WP.29/GRSG/2014/28. Recalling the discussion at the previous session of GRSG, the expert from the Netherlands presented ECE/TRANS/WP.29/GRSG/2015/5 (superseding ECE/TRANS/WP.29/GRSG/2014/30) clarifying the provisions of Chapter 18 of the Regulation following the introduction of provisions for the mandatory installation of manual and automatic valves. GRSG noted a number of comments. Following the discussion, GRSG adopted ECE/TRANS/WP.29/GRSG/2015/5, as amended below, and requested the secretariat to submit the adopted proposal to WP.29 and AC.1 for consideration at their November 2015 sessions, as draft Supplement 4 to the 01 series of amendments to UN Regulation No. 110.

Paragraph 18.3.4.8., amend “LNG valve (automatic)” to read “Automatic valve”.

Proposal to introduce a new class of CNG components (Class 6) operating at a higher pressure.

22. GRSG considered ECE/TRANS/WP.29/GRSG/2014/27 on introducing a new class of compressed natural gas (CNG) components (Class 6). The proposal received a number of comments from GRSG. The expert from IANGV introduced GRSG-107-38 (superseding GRSG-107-03), for the follow-up discussion. Finally, GRSG adopted ECE/TRANS/WP.29/GRSG/2014/27 as amended by Annex III of the GRSG-107 session report. The secretariat was requested to submit the proposal to the March 2015 sessions of WP.29 and AC.1 as draft Supplement 3 to the 01 series of amendments to UN Regulation No. 110.

Presentation on efforts to prevent natural gas powered vehicles from being certified as “dangerous goods vehicles” (ADR) through education of the UN ADR working party (WP.15) on liquefied and natural gas fuel systems and development of regulatory language to address WP.15 concerns.

40. Mr. Seisler updated the group on the ADR provisions that have been created with leadership of the Dutch delegation. (Please refer to Document GFV 30-03.)

LNG Task Force update, including review of issues concerning dangerous-goods transport vehicles (ADR vehicles).

Presentation to the 95th session of the Working Party on the Transport of Dangerous Goods (WP.15)

UN WP.15 (Carriage of Dangerous Goods) and ADR regulatory issues regarding CNG and LNG safety on ADR-regulated trucks

42. Mr. Seisler presented the problems associated with language in the ADR that says if the fuel leaks from the tank (on the vehicle) [it] should go to the ground, which is not necessarily the case with gaseous fuels (although LNG and LPG initially are heavier than air until they vaporize). He presents the results to date of the LNG TF discussions and the proposed language for an amendment.

Comments on the presentation:
43. If the text includes the phrase ‘above the auto ignition temperature of the fuel’ LNG dilution should be mentioned.

44. The language might include the flammability range of diesel and LNG, particularly if it is raised in the amendment.

45. Focusing on the word ‘leakage’ only without looking at the practical results that might not result in a fire.

46. Where are the ‘hot parts’ of the truck? Turbo charger; exhaust pipe; other engine components. But the chance of leakage near hot parts of the engine and the dispersion of LNG at that point suggests that the LNG is likely out of the flammability range. But there also could be a spark from an electrical component (i.e. in a garage).

47. A more scientific approach could/might be taken to study where the fuel goes and if it can come into contact with hot parts of the engine or hot parts of the load.

48. Mr. Piccolo knows someone who has some ADR expertise who might be able to assist with the amendment.

US EPA presentation at the Clean Cities Summit held in Indianapolis on June 28, 2011, transmitted to GFV courtesy of Jeff Seisler representing NGV Global and Clean Fuels Consulting.

• The US Environmental Protection Administration (EPA) has issued rules related to conversions of petrol vehicles to CNG that are intended to (and will) make conversions easier and less expensive than full compliance requirements that have been in place for retrofit system suppliers since about 1994.
• Prior to 1994 gasoline vehicles were allowed by unofficial ‘administrative exemption’ to be converted without being considered to be ‘tampering’ by EPA. In 1994 regulations changed (at the request of the NGV advocates) and EPA began using a more serious certification process, which was in place since 1994 and became one reason NGV conversions were so expensive in the US.
• A three tier, aged-based system was established that was more flexible for NGV conversions of cars more than 2 years old yet still requires monitoring and compliance with EPA ‘relaxed’ requirements.
• Vehicles are classified as: new (less than 2 years olds); Intermediate age (two years up to ‘useful life’; and out of useful life (OUL) (not specified in years, but presumably 5-7 years)
• Requirements are to check on functionality of OBD system when operating on the alternative fuel instead of certification like OBD demonstration.

25. Mr. Rijnders introduced the concept of the discussion of THC emissions level that was brought to the GFV by the Commission for input.

26. Jeff Seisler presented on Overview & Status of Retrofit and OEM NGVs: Focus on Europe, in part requested by the European Commission staff working on the THC amendments (GFV-22-07).

27. A survey of European retrofit industry on methane limits and natural gas catalysts by NGV Global was presented by Jeff Seisler. Little hard data has been provided by the retrofitters, however, a number of aftermarket system suppliers indicted that a target THC of 150 mg/km could be something that is more easily justified in order to convert an existing gasoline car to natural gas without the use of a methane catalyst.

28. Commission Proposal on CH4 limit in Euro 5/6 (Bernardo Martinez, DG Enterprise). GFV-20-08

• - Current limit values for Euro 5/6 are: NMHC 68mg/km and 100 mg/km THC.
• - Limits are relevant only for CNG, normally bi-fuel of a vehicle population of less than 1% Europe-wide.
• - Technical consequences: The THC requires that methane catalysts are needed for retrofitting vehicles to NGVs if they are to achieve Euro 6, 100 mg/km THC.
• - The proposal is to give a choice to the OEMs between: THC emission value of 100 mg/km (using a methane catalyst) OR a THC emission limit of 220 mg/km. In this second case the Global Warming Potential of CH4 would be taken into account as a CO2 equivalent.
• - Reg.115 would be amended with a THC limit of 220 mg/km.
• - Advantages for OEMs: 1) no negative effect for OEMs as CO2 penalty when below 100 mg/km; and 2) manufacturer could use the same emission limits as retrofitters.

29. Discussion & questions:

• - NGVA Europe: Current NMHC limit value would remain unchanged? Yes. And the retrofitters likely would not have a problem with the 220 mg/km limit.
• - AEGPL. It might be good to introduce the same type of approach in R.83 to calculate the same CO2 equivalent.
• - ACEA/VW: This is a new approach and they had not seen the proposal earlier. Ms. Leifheit indicated that they need time to discuss this internally within ACEA. At the first glance the first option is not an advantage because the OEMs still would have to pay for a methane catalyst; for the second option the OEMs would have to pay for a CO2 penalty, so the second option also could be costly.
• - For some vehicles it may not be an advantage to have a methane catalyst so it could be an advantage to have the second option.
• - The only reason the OEMs are now investing in NGVs is to save CO2.
• - NGVA Europe position. They believe the suggestion made from the Commission is a positive contribution to the debate and they will have to go back to their members – OEMs and retrofitters – and determine if this is an acceptable solution for the stakeholders.
• - Mr. Rijnders concludes that the proposal from the Commission looks very promising because it is balanced between OEM and Retrofit. It eliminates the possible negative CO2 impact on OEM NG vehicles. Further discussion between the Commission and stakeholders will continue.

Progress report of the LNG Task Force created to develop technical specifications for LNG (Liquefied Natural Gas) cryogenic components to be installed on-board road vehicles.

Mr. D’Alamo, at the GRSG meeting in April discussed the LNG amendments with the European Commission representative. (Mr. Rijnders had requested that the LNG Task Force co-secretaries contact the European Commission staff responsible to the GRSG about the LNG amendments to R.110, Antony Lagrange Legislative Officer Industrie Automobile. NGVAe and NGV Global agree that they should meet together with the European Commission staff person responsible to the GRSG to keep him apprised of the final amendments.

Mr. Seisler presented the report on the LNG Task Force activities (GFV-20-06, also presented by Mr. Del Alamo at the GRSG meeting in April). He adds that the development of the LNG amendments has been a very smooth consensus process. These regulations should achieve a timely confluence with the HDDF regulations and that will lead to an opening of the market for L-NGVs. Furthermore, the R110 regulations could provide a foundation for the development of regulations for marine applications.

Mr. Renaudin reminds the group of the schedule for ultimate approval by WP29 could be in June 2013 (maybe March 2013?) since the documentation would not be in time to be considered by the November WP29 meeting.

Mr. Rijnders indicated that if R.110 is adopted with the amendments it would be applicable for type approval for all European countries.

Progress report of the task force of the Gaseous fueled vehicles (GFV) informal group working on the introduction of liquefied natural gas provisions into UN R110.

25. The expert from AEGPL reported on the outcome of the most recent expert meetings of the task force on Liquefied Natural Gas vehicles (LNG), held in Brussels in November 2011, February and March 2012. GRSG welcome the information presented in GRSG-102-25 and noted that the next LNG meeting was scheduled to be held in Geneva, on 6 June 2012. The expert from AEGPL announced the intention of the LNG task force to prepare a concrete proposal for amendments to UN Regulation No. 110, for consideration at the next GRSG session in October 2012. He added that more detailed informal documents were made available at LNG informal group session 4 web page.

Jeff Seisler, Co-Secretariat of the LNG Task force made a brief report to the group that is a shortened version of the last report to the GFV (see document (GFV16-05 (NGV Global LNG TF-2 Report)

Genesis of the group: Follows the need created by the GFV/HDDF TF work on dual-fuel systems, which includes the use of LNG. While GFV deals with R.115 and the new LNG regulations are within R.110 (under Group of Experts on General Safety – GRSG), the LNG TF is following ‘the line’ upward within the GFV umbrella yet recognizing that all reports, decisions, amendments etc. must go through the GRSG.

Main activities: Doing a line-by-line review of R.110 to include LNG language, loosely falling into three ‘categories’: Simple changes (low hanging fruit); more complex issues needing more consideration and analysis; completely new and different elements unique to LNG that will be put into a separate ‘LNG Annex.”

Key Issues: 1) Components versus systems (detailed specifications needed for some regulatory bodies); 2) venting and boil-off, both related to additional methane fraction into the atmosphere (likely not to be a big problem); 3) vehicle labeling; and, 4) a procedural issue: whether R.110 should be amended to incorporate LNG provisions or if an entirely new LNG ‘companion’ to R.110 should be created.

On this issue the pros and cons are: 1) amended R.110 may be faster and all the existing R.110 language would not have to be copied/duplicated into a new LNG regulation; and 2) in favor of creating a new regulation it would be a ‘stand-alone’ LNG document that might be more easily dealt with by GRSG but the regulation would be subject to a co-decision process within the European Union and that could add two years to the adoption of the new regulation. Increasing the time for adoption of new regulations is less desirable to the industry. The LNG TF is on track to amend the existing regulation but the issue will be more closely debated at the next LNG TF meeting on 8 February 2012 in Brussels.

On the issue of amendments versus a new LNG regulation Mr. Rijnders indicates that Contracting Parties must be prepared to consider these new changes to ensure that they are appropriate for both CNG and LNG.

Discussion regarding the regulatory strategy to develop a completely new L-NGV regulation or create amendments to R.110: The group tends to be in favor of amending R.110 with the aspects specific to LNG become another ‘part’ of R.110, for LNG only. Having done that, moving to a Global Technical Regulation (GTR) would be easier. There cannot be an annex but could be done in a separate part. One part would have a common branch with CNG and another part would be LNG-specific.

Timing becomes one of the key issues. A new regulation would take an additional two years to create due to the fact that it would have to be approved by the European Union. From the equipment suppliers’ view the timing of a final regulation into 2015 is ‘not acceptable’ (or preferable). It might be better to have something that moves toward worldwide harmonization through R.110. This also could lead later to the development of a Global Technical Regulation (GTR) if this would help in the marketplace.

Discussion about boil-off versus venting, and concerns about vehicles parked inactive for days without driving, particularly if they are in a closed garage. From a presentation by Westport at the LNG Task Force the distinction was made that, “The vapours created due to the ambient heat input (while maintaining constant pressure in the storage vessel) are called “boil-off”.“ The discharge of these vapours out of the storage container is called venting. The question of how or if to regulate the boil-off in R.110 is discussed at length:

• - Clearly venting is a safety concern but boil-off is an operational consideration and, as such, might not be appropriate to regulate in R.110.
• - Should the ‘holding time’ be specified in the regulation since this relates to the ‘performance’ of the LNG tank?
• - Could specify a ‘not-to-exceed’ pressure in a tank, although venting is the technical measure designed to prevent excessive pressure and does not need to be regulated.
• - A question is raised about the effects of ambient temperature on the tanks, which is a factor, however, the heavily insulated cryogenic tanks are designed to mitigate and diminish the effects of ambient temperatures. Such effects would need to be verified.
• - ‘Educated management’ of the cryogenic systems is more important sometimes in determining ‘holding-time.’ Different volumes of fuel in the tank also will affect holding time.
• - It is suggested that R.110 could specify that the manufacturers provide guidance through a user manual on holding-time, boil-off, and venting.
• - Carriage of LNG trucks on ferries becomes a challenge in light of venting considerations.
• - Since vehicle owners see venting as money going (literally) into the air, there is an automatic motivation to limit venting as well as boil-off.
• - Mr. Renaudin will attend the next meeting of the LNG TF where this issue will be discussed again.

Vehicle Labeling

Labeling of vehicles was an issue discussed at the LNG TF, noting that car manufacturers do not like labels on their vehicles but trucks already are labeled so it is not a problem for HDVs. It is noted that, for regulatory purposes, amendment language has been set already dealing with engine labels and that is deemed enough.