Copy of the proposal to establish a compendium of the test tools used in Global Technical Regulations (and UN Regulations) to permit such regulations test tools according to a single source rather than having to revise each regulation with each change in tool specifications.

US NHTSA initial observations on the proposal from the EC to amend GTR No. 9 with regard to the measuring points of the headform and lower legform test procedures pending ongoing research in the United States.

Presentation of US concerns regarding proposed definitions for locating the point of measurement (i.e. measuring point, target point, and first contact point definitions) within the test zone, changes to the test zone boundaries to clarify the adult and child Head Injury Criterion (HIC) zones, and to amend the leg form test procedure to align the leg form center plane with its measuring point.

[Note: the reference to document GRSP/2011/12 does not appear to correspond with the content of the US statement. Rather, the remarks align more closely with document GRSP-54-07/Rev.1 proposing changes to the draft amendment as presented in document GRSP/2013/25).]

Statement of US concerns with the draft amendment to introduce the Flex PLI test tool into GTR No. 9 (document GRSP/2013/25) in particular with regard to the use of the injury assessment reference values (IARVs). US definition of the IARV will be dependent upon the outcome of a US cost-benefit analysis based upon the characteristics of the American vehicle population. The US cannot accept injury curves that do not fall within what is justifiable according to US traffic conditions.

The draft Amendment 2 to GTR No. 9 proposes to establish the new FlexPLI impactor as the single harmonized tool for lower leg impact tests. The amendment also proposes injury assessment reference values (IARV) to go with the FlexPLI. The US, however, has consistently expressed concerns that the proposed injury thresholds and IARV have not been validated as appropriate for the American car fleet. Therefore, the US proposes to have ‘recommended’ IARV included in the preamble to Amendment 2 while allowing governments the freedom to use whatever IARV/performance thresholds they deem appropriate until such criteria can be fully validated.

Phase 2 proposes to amend the UN Global Technical Regulation No. 9 on pedestrian safety by introducing the flexible pedestrian legform impactor (FlexPLI) as a single harmonized test tool in order to enhance the level of protection for pedestrian lower legs. NHTSA has expressed concern that the injury assessment reference values (IARVs) for this GTR may not meet the needs for injury mitigation in the U.S. In order to enable the proposed Phase 2 amendment to move forward with US support, the US proposes additions to the GTR preamble to make clear its position and intentions regarding assessment of the IARV and to allow the brackets to be removed from the IARV in the draft amendment.

Proposal to modify document GRSP/2014/15 presenting Amendment 2 to GTR No. 9. Amendment 2 would introduce the flexible pedestrian legform impactor (FlexPLI) as a single harmonized test tool. The National Highway Traffic Safety Administration (NHTSA) has expressed concern whether the injury assessment reference values (IARV) proposed in Amendment 2 will be able to meet the needs for injury mitigation in the United States of America. In order to allow the amendment to move forward, the United States proposes to accept the IARV while noting in the statement of technical rationale and justification its continuing research into the IARVs and the possibility of a future proposal to amend the values should this prove warranted.

This document contains a proposal to continue to develop amendments to UN GTR No. 9 on pedestrian safety in order to clarify the test procedures. It is based on ECE/TRANS/WP.29/AC.3/31 from the March 2012 session of the Executive Committee (AC.3) of the 1998 Agreement. It is distributed to the World Forum for Harmonization of Vehicle Regulations (WP.29) and to AC.3 for consideration. This document shall be appended to the amendment to the UN GTR once adopted.