GRE Informal Working Group „Simplification of Regulation“

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Presentation transcript:

GRE Informal Working Group „Simplification of Regulation“ SLR-23-05 GRE Informal Working Group „Simplification of Regulation“ Explanation of the “Change Index”2 The “Change Index” What is it and why do we need it? Additionally: Introduction of “Approval Numbering” and “Approval Marking” applied to the new draft LSD, RID and RRD Device Regulations Page 1

GRE Informal Working Group „Simplification of Regulation“ Change Index – Document source Document source for the introduction to „change index“ GRE/2018/16 + GRE-79-xx GRE/2018/18 + GRE-79-xx Proposal for an amendment to Regulations Nos. 48, 53, 74 and 86 (Installation of lighting and light-signalling devices for different vehicle classes) Draft new UN Regulation on uniform provisions concerning the approval of light- signalling devices (lamps) for power-driven vehicles and their trailers Draft new UN Regulation on uniform provisions concerning the approval of road illumination devices (lamps) and systems for power-driven vehicles Draft new UN Regulation on uniform provisions concerning the approval of retro- reflective devices and markings for power-driven vehicles and their trailers GRE/2018/02 + GRE-79-xx GRE/2018/03 + GRE-79-xx GRE/2018/04 + GRE-79-xx Agreement concerning the Adoption of Harmonized Technical United Nations Regulations… (Revision 3) E/ECE/TRANS/505/Rev.3 Draft General Guidelines for United Nations regulatory procedures and transitional provisions in un Regulations WP.29/2017/107 Page 2

GRE Informal Working Group „Simplification of Regulation“ Change Index – Document source Document source for the introduction to „change index“ These proposals provide the information about the definition and the usage of the „change index“ for the Installation Regulations GRE/2018/16 + GRE-79-xx GRE/2018/18 + GRE-79-xx Proposal for an amendment to Regulations Nos. 48, 53, 74 and 86 (Installation of lighting and light-signalling devices for different vehicle classes) These draft Regulations are using the „change index“ and provide Transitional Provisions for the usage. GRE/2018/02 + GRE-79-xx GRE/2018/03 + GRE-79-xx GRE/2018/04 + GRE-79-xx Draft new UN Regulation on uniform provisions concerning the approval of light- signalling devices (lamps) for power-driven vehicles and their trailers Draft new UN Regulation on uniform provisions concerning the approval of road illumination devices (lamps) and systems for power-driven vehicles Draft new UN Regulation on uniform provisions concerning the approval of retro- reflective devices and markings for power-driven vehicles and their trailers Revision 3 of the 1958 Agreement contains the information about approval marking & approval numbering for UN Regulations Agreement concerning the Adoption of Harmonized Technical United Nations Regulations… (Revision 3) E/ECE/TRANS/505/Rev.3 Draft General Guidelines for United Nations regulatory procedures and transitional provisions in un Regulations These guidelines to Revision 3 provide help when dealing with Transitional Provisions. WP.29/2017/107 Page 3

GRE Informal Working Group „Simplification of Regulation“ Change Index - Problem statement One Regulation = One Device (function). New series of amendments introduces higher stringency requirements to the device covered by the Regulation. CURRENT SITUATION: One Regulation covers many devices (functions). New series of amendments may introduce higher stringency requirements to only one or more of the devices (function) covered by the Regulation. However, according to the current system ALL devices covered by the Regulation need new type approvals following the new series of amendments. NEW SITUATION: Avoid unnecessary new type approvals for those devices (functions) for which a new series of amendments have not introduced higher stringency requirements. TARGET: Introduction of the „Change Index“. SOLUTION: Page 4

GRE Informal Working Group „Simplification of Regulation“ Change Index - Definition GRE-78 Question: What is the change index? Paragraph 2.1.6. of Regulation No. 48 (Definition) (see document GRE/2018/16 and GRE-79-xx) “2.1.6. "Change index" means a sequential number, starting from 0, specific to each lamp (function) covered by UN Regulations [LSD], [RID] and [RRD]. It indicates the number of times new series of amendments to the pertinent Regulation ([LSD], [RID] and [RRD]) have posed higher stringency requirements to this lamp (function).“ Table 2 of the Draft Regulation on Light-Signalling devices (LSD) (see document GRE-2018-02) 01 02 1 1 1 The series of amendments IS part of the approval marking The change index is NOT part of the approval marking Page 5

The change index is NOT part of the approval marking GRE Informal Working Group „Simplification of Regulation“ Approval marking Type approval marking acc. to the new simplified Regulations Regulation No. 87 Revision 2 of the 1958 Agreement Example of approval marking Regulation No. (LSD) Revision 3 of the 1958 Agreement Requirement for approval marking Symbol for DRL RL 01 Symbol for DRL RL 01 Series E4 E4 Contracting party Contracting party [LSD]R01-1111 1111 4 digit seq. number “R” 4 digit seq. number No. of Regulation 01 Series The change index is NOT part of the approval marking Page 6

The change index is NOT part of the approval numbering GRE Informal Working Group „Simplification of Regulation“ Approval numbering Type approval number acc. to the Rev.3 of 1958 Agreement Regulation No. 87 Revision 2 of the 1958 Agreement Example of approval number Regulation No. (LSD) Revision 3 of the 1958 Agreement Requirement for approval number E4 RL 1111 01 E4 RL [LSD]R01-1111 01 E4*01*1111 01 Series 4 digit seq. number Contr. Party E4*[LSD]R01/03*1111*00 No. of Regulation “R” 01 Series 4 digit seq. number Supp. No. Ext. No. Contr. Party The change index is NOT part of the approval numbering The changes to the approval numbering follow the provisions of the 1958 Agreement, Schedule 4, Par. 3 (E/ECE/TRANS/505/Rev.3) Page 7

What is the „change index“ needed for? - Device GRE Informal Working Group „Simplification of Regulation“ Change Index – Usage What is the „change index“ needed for? - Device Adding a paragraph 6.1.1. under subsection „Transitional Provisions“ in all three new draft Device Regulations (LSD, RRD, RID), see document GRE-79-xx: (Source: „Draft General Guidelines for United Nations regulatory procedures and transitional provisions in UN Regulations” WP.29/2017/107, Section 41.) “6.1.1. Contracting Parties applying this UN Regulation shall continue to accept UN type- approvals of the lamps (functions), to any of the preceding series of amendments to this UN Regulation, which are not affected by the changes introduced by the latest series of amendments. To verify this, the change index applicable to the pertinent lamp (function) shall not differ from its change index as indicated in the latest series of amendments. 01 1 Daytime running lamp: The change index differs -> par. 6.1.1. is NOT valid for this function Front direction indicator lamp: The change index does not differ -> par. 6.1.1. IS valid for this function Page 8

What is the „change index“ needed for? - Vehicle GRE Informal Working Group „Simplification of Regulation“ Change Index – Usage What is the „change index“ needed for? - Vehicle “5.32. A device type approved according to any preceding series of amendments to UN Regulations [LSD, RID and /or RRD] is deemed equivalent to one approved according to the latest series of amendments to the pertinent Regulation ([LSD], [RID] and [RRD]), when the change indexes (defined in paragraph 2.1.6.) related to each individual lamp (function) do not differ. In this case such a device may be fitted on the vehicle to be type approved without any update of the device type approval documents and device markings” (example for UN Regulation No. 48) Adding a general requirement in Installation Regulations Nos. 48, 53, 74 and 86 (GRE/2018/16, ../18 and GRE-79-xx) E4 [LSD]R00-3456 1a Even if the 01 series of amendments to Regulation No. [LSD] entered into force and the transitional period has expired, the device on the left side may be used for new vehicles because the change index for this function (front direction indicator), i.e „0“ did not change between series 00 and 01 01 1 Page 9

GRE Informal Working Group „Simplification of Regulation“ Change Index – Conclusions The „change index“ is merely a tool (an indicator) to support type approvals and the usage of type approved devices The concept of „change index“ is in line with Revision 3 of the 1958 Agreement and supported by the guidelines (accepted by WP.29 in November 2017) The „change index“ is not part of the approval marking nor of the approval numbering Page 10