1. Safety, quality & environmental services Headform Test with deceleration measurements : guide system UN ECE – GRSG – IGPG – 5 th Session 5 - 6 September 2012 - Paris Lucie Gerard IGPG-05-03

2. R43 – An. 3 §3.2 §3.2.2. To perform the headform test the phantom head is fixed to the cross arm of the guide system and moved to the required drop height by means of a lifting device. During the headform test, the cross arm with the phantom head is released. After passing the height adjustable light barrier the phantom head is released from the cross arm, the cross arms fall is dampened and the phantom head falls onto the sample. No impulse may be given to the phantom head by the drop appliance or by the measuring cable, so that it is accelerated only by gravity and falls vertically.

3. Question raised: Can the phantom head be used without the guiding system? The regulation in its present state does not offer an alternative to the guiding system § 3.2.2.2: (…) A guide system is not necessary for these [calibration] small drop heights. The heights for the calibration are comprised between 50 & 254mm DIN 52310-2: 2011-04 revision to allow the possibility of performing the test without the guiding system.

4. Guiding system: concerns Calibration problems No precision on the type of cables needed (roughness, etc.) Questioning the utility of the guide, instead of a free drop at the right height Repeatability better than on a free drop only?

5. Opinions from Dr Matthias Dümmler The calibration values of ECE-R43 cannot be reached with headforms set up according to the instruction given in the regulation. Further, we have added the alternative to operate with wireless data transmission because this is state of the art and has many advantages. In this case, the leading wires would not be required. There are also several more minor modifications. Presently, the ISO/TC22/SC11 works on the revision of ISO 15082. I have brought in a new section which describes the headform test with deceleration measurement according to our revised German standard. Therefore, when this revision of iSO 15082 has been published, there will be a base to adapt ECE-R43 accordingly. Until ECE-R43 has been modified concerning this test, in our opinion the modified test procedure can already be used, since with the current description you have no chance to do a successful calibration anyway.

6. Opinion from Christian Pichon (UTAC) « I dont have information on the new version of the DIN standard that is not integrated in the R43 and there is no proposition in that direction. We use the equipment conform to the regulation and we have had a lot of trouble to calibrate it when we got it years ago. The use of the equipment without the guide is not conform to the text and you will need to demonstrate that the solution [without the guide] respects the characteristics required, not only in terms of deceleration but also in terms of the precision of the point of impact and the positioning of the head (angularity with respects to the vertical). The main problem we met during the calibration was linked to the manufacturing of the phantom head that needed tweeking at every change of height. I am not responsible for these tests anymore and I didnt receive more recent information on the topic. (…) As ISO 17025 auditor, I will ask you to prove me that the equipment without the guide has no influence with regards to the regulatory text. » (translated from the original text in French) UTAC: Union Technique de lAutomobile, du motocycle et du cycle

7. Opinion from the VCA Tony Stenning: (…) I do have responsibility in VCA for interpretation of legislation. We have a process to deal with such queries and I will pass on your question to our Technical Support Group, who will respond to you in due course. Kevin Bridges: To certify to R43, all the equipment specified in Annex 3, 3.2.2 must be used when carrying out the testing. As DIN52310-22 is a voluntary standard and is not specified in R43, the test methods in it cannot be used for carrying out R43 type approval testing.

8. Opinion from IGPG members?