Comments concerning the clarity and utility of certain provisions in the proposal to amend the annex on complex electronic systems.

Proposal to clarify UN R129. 1. Requirements for car manufacturers (Regulation No. 16, Annex 17, Appendix 1, which allows a certain zone) are NOT compatible with requirements for Child Restraint System (CRS) manufacturers (Regulation No. 129, paragraph 6.1.3.4., asks for a different zone). The adult belt is supposed to run over the angle between adult thighs (that are more “fat” and the adult pelvis (that has a bigger depth). Therefore the required zone for the Child Restraint Systems has been adapted such that the routing of the adult belt over the child restraint has to closer to the intended use and design of the adult belt.

Proposal to correct the definition of “manual valve”, including deletion of the phrase “rigidly fixed to the cylinder or tank”. The definition of the manual valve as part of the accessories fitted to the container or tank (para. 4.16.) is different from the definition specified in paragraph 4.22. The proposed editorial change aims at clarifying the text of these definitions.

Proposal to establish procedures for the approval of non-seamless double and single wall gas tubes provided they can withstand the applicable tests according to Annex 15.

Netherlands proposal in response to the initiative from Germany and Japan to standardize and limit the sound emission from Reversing Alarms (documents 64-05, 64-06, 65-06 and 65-07) to amend the requirements, including the use a “white noise alarm” instead of a “tonal noise alarm”.

Information on work in the Netherlands to implement noise-level labeling for roads (in a format similar to that used in Europe for labeling energy efficiency of household appliances).

Explanation of Netherlands interest in labeling of road surfaces, in particular as a means to encourage reductions in rolling resistance.

Paper presented at a Dutch Infra Congress 2016 held on 23 June 2016 concerning the potential benefits of a road labelling system.

Revision 3 of the 1958 Agreement allows for a Unique Identifier (UI) under the DETA system as an alternative to the current approval mark. In the case of child restraint systems, the approval mark contains important information for users. Therefore, this proposal would prohibit replacement of the approval mark by the UI.

Proposal to clarify the requirements for CRS utilizing the seat belt lap strap in order to ensure correct installation and testing and to avoid possibly dangerous misinterpretation to the test configuration.

Presentation on legal requirements (push) and public education/incentivization (pull) strategies to decrease road noise levels. The presentation especially addresses the Dutch interest in a road labeling system for rating road surface noise levels.

Proposal to add the Q0 infant test dummy to the UN R44 procedures in response to problems encountered in acquiring the currently specified P0 dummy.

The International Whole Vehicle Type Approval will involve granting whole vehicle approvals based upon component-level approvals granted to manufacturers (i.e., OEM suppliers) other than the manufacturer (i.e., vehicle maker) applying for the whole vehicle approval. This document provides comments solicited from EU type approval authorities regarding the management of this system of direct and indirect application of UN Regulation approvals to a whole vehicle.

Table of regulations and pending proposals that would in whole or in part be consolidated into the new UN Regulation on light-signalling devices.

Notice on Netherland’s sponsored research into head protection for pedal-electric bicycle riders and subsequent technical agreement on helmet testing.

Improved explanations for the proposal to clarify the requirements for CRS utilizing the seat belt lap strap in order to ensure correct installation and testing and to avoid possibly dangerous misinterpretation to the test configuration.

Recommendations established by the Open Web Application Security Project.

Proposal presented as an alternative to the previous proposal from Poland (GRSG/2017/10) to require manufacturers to mark the approval extension number on any accessories relevant to the bonfire test (multivalve or, when approved separately, pressure relief valve (discharge valve) and pressure relief device) so that the fitting of any accessory not on the list of approved configurations (Table 3 in the appendix of Annex 2B) will be prevented/forbidden. This solution would imply a new requirement in Annex 2A for the marking of the accessories fitted to the containers.

Proposal to establish procedures for the approval of non-seamless gas tube(s), gas tube(s) made of materials other than copper, stainless steel, and steel with corrosion-resistant coating, and their couplings in Liquefied Petroleum Gas (LPG) vehicles provided they can withstand the applicable tests according to Annex 15.

Netherlands proposal for incorporating the UN Regulation on software systems (under development within the Cybersecurity/OTA task force) into UN Regulation No. 79 on steering. UN R79 is being updated to address the approval of automated steering functions. This document is a version of the regulation with a new paragraph 5.1.11.: “The performance of the steering system shall not be adversely affected by the software present in the system. This shall be demonstrated by compliance with the technical requirements and transitional provisions of Regulation No. X[Software Regulations], series of amendments or any later series of amendments.”

Proposal to increase the stringency of tyre noise limits starting from 1 November 2020.

In line with amendments presented in document GRSP/2017/13 and adopted by GRSP to clarify the seat belt installation procedure for testing integral child restraint systems (in order to ensure proper evaluation of potential injury risks), this proposal recommends corresponding amendments to address non-integral child restraint systems (e.g., booster seats).

Proposal to correct Table 1 by deleting “F1” (this fixture is part of a corresponding ISO Standard but not in UN R16) and to replace “universal” by “i-Size” in the title of Appendix 5, as UN R129 booster seats can be only i-Size or specific.

Proposal to correct paragraph 1.2. by deleting “and Appendix 5” in order to align with the text of Supplement 9 to the 06 series of amendments to UN R16, to correct Table 1 by deleting “F1” (this fixture is part of a corresponding ISO standard not found in UN R16), and to correct Appendix 5 by replacing “universal” with “i-Size” (UN R129 booster seats can be only i-Size or specific).

Proposal for further discussion concerning technical advances in the use of CNG accumulators as an intermediate technology for promoting high, stable pressure in CNG engine injection systems. The CNG accumulator is used to stabilize the gas pressure and to allow engine operation whenever the LNG supply system is not able to deliver fuel. This proposal would define requirements to enable the certification of these components.

Proposal to clarify the test procedure to be applied in assessing compliance with the requirement for “compatibility with heat exchange fluids of non-metallic parts” Annex 5Q is part of UN Regulation No. 110. In Annex 4D, the wording “Compatibility with heat exchange fluids” is used but there is no reference to the applicable tests. The proposal clarifies that the “LNG heat exchanger – vaporizer” falls within Annex 5Q. The proposal correspondingly clarifies the general overview Figure 1-2, with all tests from Annex 5, and Table 5.1 in Annex 5.

Proposal for discussion to enable the certification of CNG compressor components. Due to density and temperature constraints, LNG fuel systems require technologies to warm the LNG fuel to reach temperatures and pressures suitable for the engine. In some configurations, this involves the use of CNG compressors. Therefore, this proposal seeks to enable use of this technology through establishment of requirements to ensure safety.

Proposal to correct the omission of Class VII devices from the communication form described under Annex 3 of the regulation.

Updated proposal to correct the omission of Class VII devices from the communication form described under Annex 3 of the regulation.

Discussion of the possibilities for regulating critical vehicle software systems.

Proposal to require marking of extension numbers on accessories relevant to the UN R67 bonfire test (e.g., multivalve, pressure relief valve, pressure relief device) in order to prevent/prohibit the misuse (in container configurations) of these accessories. The proposal includes provisions for components where such marking is impractical based upon text drawn from UN R46.

Proposal to specify a light general-purpose street motorcycle without fairings or windscreens having an engine capacity between 400 cm³ and 600 cm³ as the approaching vehicle in the testing of automated lane-change systems under UN R79.

Updated and amended proposal based on formal document GRSP/2017/39. This proposal requires the checking of non-integral child restraints (e.g., booster seats) for risk of injuries caused by narrow contact with buckle and safety-belt.