Proposal from the GRSG task force on Automated Vehicles Regulation Screening to enable the application of UN R122 to ADS vehicles and to ensure that the requirements minimise the risk of burns across all vehicle occupants.

UN R13 and UN R78 establish different brake system requirements for 4-wheel vehicles. R13H requires split service brake systems with front/rear proportioning; R78 permits split service brake systems, combined brake systems, or two separate service brake systems without proportioning requirements. Type-O dry braking tests differ: R13H requires engine disconnected at 100 km/h with stopping distance 0.1v + 0.0060 v² and MFDD 6.43 m/s²; R78 specifies multiple tests at 40, 60, and 100 km/h with varying requirements. Type-I brake fade tests use different snub protocols and performance thresholds. Secondary braking failure criteria differ at specified speeds. R78 requires wet brake testing, a 30 km/h dynamic park brake test with 18% gradient and 5 minutes hold time; R13H specifies static gradient tests. R78 includes detailed ABS, functional safety, and regenerative braking requirements; R13H does not.

The document addresses consistency issues across multiple UN Regulations (R26, R28, R29, R34, R35, R39, R43, R45, R46, R48, R49, R134, R135, R137, R138, R141, R142, R143, R144) concerning automated driving systems. It proposes improved wording for fuel leakage provisions, foot control applicability for vehicles of category M₁, and speedometer requirements when ADS features are active. The document recommends removing duplicate definitions of ADS, DDT, bi-directional vehicle, and forward direction across regulations. It raises questions regarding application to category Y vehicles, handling of bi-directional traffic equipped vehicles, and whether requirements should apply to vehicle users or only when ADS features are active.