OICA-CLEPA proposals for amendments to the draft corrective steering/ACSF B1 amendments to UN R79 (revisions to GRRF-82-12/Rev.3 approved at GRRF-82 and subsequently submitted for the March 2017 WP.29 session as WP.29/2017/10).

Proposal for category C automated steering requirements.

Proposal to ensure that all replacement pollution control devices conform with the intent of UN R49 and to align UN R49 in this regard with Regulation (EU) 2016/1718. CLEPA proposes the establishment of a new annex under UN R49-05 R.49-05 to restrict the approval of a replacement device to one that “enables the engine and vehicle to comply with the rules with which it was originally in compliance”.

Review of the discussions and supporting data towards the further development of CRS requirements under UN R129.

CLEPA proposals including changes discussed during the meeting.

UN R13 allows for the exemption of certain vehicles from the requirement for electronic stability controls (footnote 12). This proposal (following proposals GRRF/2016/27 and GRRF-82-03) seeks to clarify the scope of the exemptions to include any special purpose vehicle with a non-standard chassis. The change was prompted by a modified vehicle where use of ESC was not feasible, but where the current UN R13 language left doubt as to whether the ESC requirement was applicable.

Proposal to amend Figure 2a of Annex 21 to better reflect the meaning of paragraph 2.4.2.2. of Annex 21, mainly to clarify the lateral limits of any opaque obscuration in this area.

Proposal to clarify the testing of seats with and without head restraints. This proposal would allow alternatives at the request of the manufacturer by clarifying that under testing of a bench seat with three seating positions and two head restraints, a moment of 3 × 373Nm shall be applied to the back of seats and of 2 × 373Nm to the head restraints:
(a) If the manufacturer wants to comply with the test requirements of paragraph 6.2. (strength of the seat-back), by the test of head restraint performance of paragraph 6.4., they choose to apply 53 daNm to each seat back without head restraint and 89 daN to each head restraint. In this case only one test shall be performed.
(b) If the manufacturer chooses not to apply 53 daNm, during the test of paragraph 6.4., the seat back strength test of paragraph 6.2. has to be performed in addition to the test of paragraph 6.4.

In particular to account for CRS that can be used with more than one base.

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

Proposal to eliminate divergent interpretations of paragraph 6.4. with regard to the testing for head restraint performance of a bench seat with three seating positions and two head restraints. Under this condition, the proposal would require application of a moment of 3 × 373 Nm to the back of the seats and of 2 × 373 Nm to the head restraints. The manufacturer may request to apply 53 daNm to each seat back without head restraint and 89 daNm to each head restraint in order to comply with the requirements of paragraph 6.2. on the strength of the seat back during this test. If the manufacturer does not opt to apply these forces, then the test procedure specified in paragraph 6.2. must be carried out in addition to the head restraint testing under paragraph 6.4.

Presentation on the concerns addressed by the proposal to clarify the correct use of the seat-belt strap in the installation of a CRS in order to ensure proper testing for approvals (document GRSP/2017/13).

CLEPA response to the presentation on the phase 1, 2, and 3 amendments to UN R126 (document GRSP-61-28) regarding the proposals for amendments to the 01 and 02 series of amendments and for the 03 series of amendments. CLEPA expresses concern that certain restrictions and requirements have been proposed without adequate research and discussion, often related to concerns raised under UN R44, that would imposed unwarranted burdens on manufacturers.

Proposal to address non-integral CRS shield systems and booster cushions remaining under the phase 2 development of UN R129.

Proposal for a method to assess the external dimensions of a child restraint system.

Proposal first presented to the ACSF informal group for a type-approval mechanism to control for updates to software dependent systems.

Revised proposal based upon document ACSF-12-11.

Proposal based on document ACSF-12-12.

OICA-CLEPA perspectives on the definition and use of Category C lane-change systems, especially emphasizing the need for human supervision (SAE Level 2 automation).

Child restraint fixture fitment proposal for the 03 series of amendments (Phase 3) of Regulation No. 129 in order to introduce a repeatable and reproducible procedure to assess the external dimensions of a child restraint system.

UN R13 allows for the exemption of certain vehicles from the requirement for electronic stability controls (footnote 12). This proposal (following proposals GRRF/2016/27 as amended by GRRF-82-03 and proposal GRRF-83-31) seeks to clarify the scope of the exemptions to include any special purpose vehicle with a non-standard chassis. The change was prompted by a modified vehicle where use of ESC was not feasible, but where the current UN R13 language left doubt as to whether the ESC requirement was applicable.

OICA-CLEPA draft contribution to integrate SWTAN in UN Regulations

OICA-CLEPA proposals for improvement of the draft text pursuant to open issues from the previous ACSF informal group session.

Presentation covering

1. Lane change functional test
2. Abort of lane change test
3. Overriding force test
4. Deactivation test
5. Sensor performance test
6. Sensor blindness test (industry proposal)
7. Engine start/run cycle test (three phases)

OICA-CLEPA “homework” input addressing open issues from the previous ACSF informal group session.

Following bench testing of steering override force of 50 N, all participants concurred that the 50 N force can be easily handled and therefore is appropriate for all categories of CSF, ACSF, and ESF systems.

With each development phase (series of amendments), UN R129 has expanded its scope in terms of child restraint applications (e.g., i-Size, specific vehicle ISOFIX, i-Size booster seat, specific vehicle booster seat, etc.). Paragraph 3.2.2. requires the applicant for type approval to declare the intended application or combination of applications. CLEPA proposes new language to specify the various possible combinations and related requirements in order to maintain consistency between phases 1 and 2 and phase 3.

Comparison of UN R44-approved child seats.

Presentation to initiate discussions on the impact of storage compartments, such as in vehicle floors, on the safe installation and use of i-Size CRS.

OICA/CLEPA comments on the proposal to restrict manual deactivation of AEB systems to speeds under 30 km/h, noting cases where, given the current state of the technology, manual deactivation (regardless of speed) is warranted.

This proposal supplements proposal GRRF/2017/23 which amends UN R13, R13H and R140, to allow the use of the ESC tell-tale to indicate the intervention on the steering angle of one or more wheels for the purpose of vehicle stability. The intention allow design options that avoid two optical warning signals (ESC flashing + constant CSF) during an ESC intervention.

Draft proposal to enable the approval of automated emergency steering systems intended to avoid or mitigate collisions. The proposal based on document ACSF-14-07 submitted by OICA and CLEPA which was discussed during the 14th meeting of the ACSF informal group. The square brackets indicates paragraphs which are still under discussion in the informal group.

Presentation on remanufactured brake calipers as part of the discussion on whether such products should be subject to a new UN Regulation separate from UN R90. CLEPA does not believe these products require a new regulation.

Diagram illustrating the phases of a lane-change maneuver as envisioned by the Category C¹ ACSF amendment to UN R79.

OICA and CLEPA positions on the development of regulatory requirements for light vehicle automatic emergency braking systems.

Proposal to modify the dates for phasing out Group 2 and Group 2/3 child restraint systems as proposed in document GRSP/2017/20. Approvals would cease to be granted for new type approvals from September 2021 and extensions to approvals would no longer be granted from September 2024.

Proposal to cease approvals under the 02 series of amendments from September 2020 in order to allow manufacturers adequate time to adapt to the new requirements;

• ESF, ACSF C and unexpectedly ACSF B1 (despite originally assumed to be compatible with ACSF C new requirements),
• new CEL assessment (documentation, tests…) whose scope is also extended to all non-complex electronic systems under series 03.

Regarding the application to “All Types” (e.g. for new registration), industry proposes to leave unchanged the existing vehicles on the market which are approved on the base of national of regional exemptions by Contracting Parties signatories of the UN R79 regulation, given the heavy technical impacts on ACSF C (sensor range…) which are indirectly affecting ACSF B1 systems that were initially assumed to be compatible with cat. C (e.g. 3s hands-off detection instead of 15s, lane centering prior to the lateral movement towards the marking etc.), and the add-on of requirements restricting design possibilities without clear safety benefits (e.g. the use of direction indicators to suppress the procedure).

Proposal to correct the omission of the exemption of non-integral ECRS with a stature range starting at 100 cm or above from the testing of toxicity in Supplement 1 to R129 (document WP.29/2016/106, paragraph 6.3.1.1.). This correction should also be applied to the later documents:

• GRSP /2017/44 Proposal for Supplement 7 to R129,
• GRSP /2017/43 Proposal for Supplement 4 to 01 series of amendments to R129,
• GRSP /2017/42 Proposal for Supplement 3 to 02 series of amendments to R129, and
• GRSP /2017/41 Proposal for 03 series of amendments to R129.

The proposal clarifies the test procedure in the amended paragraph 6.1.8 in document GRSP/2017/38 by adding one dimension (175 mm) . This dimension is in line with the dimensions of the fixture from Regulation 16 to check the vehicle safety belt length (Annex 17-Appendix 1, Figure 1) and also in line with document GRSP-61-14/Rev.1 that was adopted at the 61st session.

SLR informal group draft for the proposal of a new regulation consolidating all current regulations regarding retro-reflecting devices. This draft UN Regulation combines the provisions of the current Regulations Nos. 3, 27, 69, 70 and 104.

CLEPA request for a focused and urgent effort to incorporate all dummies and tools (especially including the child Q dummies integrated into UN R129 testing) into Mutual Resolution 1 which was intended as the repository for specifications of all tools used in WP.29 regulation test procedures.