The document presents OICA data on rear direction indicator (DI) and stop signal visibility compliance. It evaluates various lamp configurations against UN R48 and UN R148 requirements, examining criteria including photometry areas outside 25mm from stop lamps, DI apparent surface size, separation distances, and intensity ratios. OICA proposes that compliance requirements are met when DI apparent surface equals or exceeds stop lamp surface, intensity exceeds stop lamp by 25% minimum, separation distance reaches 20mm minimum, or DI apparent surface equals or exceeds 30cm.

Proposal to amend UN R48 and UN R148 regarding direction indicator visibility when grouped with stop lamps. OICA proposes replacing Germany’s masking-based approach with objective, installation-level acceptance criteria: apparent surface area comparison, luminous intensity ratio at HV of at least 25% higher, or absolute apparent surface of 30 cm². Physical masking eliminates measurement uncertainty and improves test repeatability. Three alternative compliance routes provide flexibility without constraining designs.

OICA opposes proposed amendments to UN R48 paragraph 5 that would prohibit lighting devices not explicitly listed in paragraph 6. OICA contends the prohibition creates unnecessary manufacturer burden without safety benefits, conflicts with nationally permitted lamps, and falls outside the 1958 Agreement’s harmonization scope. OICA argues national enforcement, not type-approval restrictions, should manage device installation.

OICA presents research findings on direction indicator perceptibility when stop lamps activate simultaneously. Key findings indicate that spatial separation between functions, increased direction indicator intensity, and relative signal dominance improve perception. Research shows stop lamp luminance can reduce direction indicator recognition, particularly in near-field viewing. OICA concludes that minimum size requirements proposed in the German proposal exceed available evidence and may create unintended consequences without demonstrated safety benefits.

Comparison of the behaviour from FlexPLI and Human Model THUMS in the outer area of the bumper.

Comparison of the behaviour from FlexPLI and Human Model THUMS in the outer area of the bumper. This is an expanded version of the original presentation.

Review of EEVC and Flex-PLI legform behavior in tests along the bumper test area and bumper corner.

Review of test results applying the Flex PLI and EEVC legs outside the regulatory bumper test area.

Copy of document GRSG/2020/12.