TSEI 2011 Fall Conference Transport... · TSEI – 2011 Fall Conference Washington, DC - 20 October...

Transport Canada update:

CMVSS 108 and CMVSS 101

&

Future of Regulations

Marcin Gorzkowski, P.Eng., M.Eng.

TSEI – 2011 Fall Conference Washington, DC - 20 October 2011

CMVSS 108

&

TSD 108

2

CMVSS – Canada Motor Vehicle Safety Standard

TSD – Technical Standard Document

(TSD = any legislated document of a foreign country)

Transport Canada Report

3

TC Report – CMVSS 108

TSD 108 – new FMVSS 108 (Dec. 1, 2012)

NHTSA’s new FMVSS 108 was translated

to French

to Canadian references and units

Several Canadian specific provisions proposed

to be added to CMVSS 108

4

CMVSS 108 additional requirements:

Definition of “design to conform”

Vehicles travelling on three wheels – 3.w.v.: same lamps and retro-reflectors as pas. cars – motor tricycle: tail, stop and r.-r. installed per pas. car + pas. car parking lamp – both may require additional retro-reflectors if needed to indicate width of vehicle

For limited speed motorcycle (motor driven cycle) no exemption for turn signal lamps

Restricted use motorcycle [ATV] - mandatory reflex reflectors as on motorcycle


CMVSS 108 additional requirements (cont.):

Aiming mandatory for: front fog lamps, auxiliary headlamps and motorcycle headlamps

Automatic activation of marking devices with rear and/or front fog lamps

Telltale for fog lamps (front and rear)

Stop signal priority over hazard warning signal

No permanent or automatic flashing of headlamps (modulating allowed for motorcycle headlamps)

All-time-ON motorcycle headlamp or UN Reg 87 DRL, tail lamp and licence plate lamp

5


CMVSS 108 allowances:

Use of 2011 SAE handbook instead of referred SAE standards

Intermediate side marker lamp and retro-reflector may be replaced by side marker lamps and retro-reflectors installed every 3 meters

Emergency stop signal

Rear end collision warning signal

Placement of upper beam above the lower beam

6


CMVSS 108 – DRL:

SAE J2087:2011 (except: testing of lower intensity lower beam at one test point allowed only if certain conditions met)

UN Reg 87 lamps

Front fog (J583:2005 or UN Reg 19) allowed only until 5 years after publication

Switching of DRL (mandatory OFF if front fog lamp ON & allow temporary OFF)

Switching of headlamps - automatic except as specified

7


CMVSS 108 publication:

Part I [NPRM]: July 2012

Part II [FR]: July 2013

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CMVSS 101 (no TSD 101)

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Transport Canada Report

10

CMVSS 101 vs. FMVSS 101:

Allow conformance with UN Regulation 121 Location and Identification of Hand Controls, Telltales and Indicators

Location requirements for passenger airbag OFF telltale copied from FMVSS 208

Explanation of all identifiers (symbols) must be provided to the driver in both official languages

Explanation of those symbols “critical to safety” provided in the vehicle


CMVSS 101 vs. FMVSS 101 (cont.):

Only symbols and small selection of internationally recognized words and abbreviations (?) - may expend to allowing words in both official languages

Accessibility of controls extended to all controls needed to operate a moving vehicle (?)

Telltales and indicators must be recognizable not just seen (?)

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CMVSS 101 vs. FMVSS 101 (cont.):

Words-only allowed to identify controls, telltales or indicators not in the Table; however, those related to operation of moving vehicle; however, must be in both official languages (?)

Any source of illumination in front of the driver not used to illuminate telltale, control of indicator must not flash (?)

For identifiers not specified in CMVSS 101 manufacturers may use symbols and colour scheme prescribed by ISO 2575:2010 (?)

12


CMVSS 101 publication:

Part I [NPRM]: March 2012

Part II [FR]: December 2012

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CMVSS 111 (no TSD 111 .

… at this time)

14


No immediate plans to follow latest NHTSA amendment

World Forum

for Harmonization

of Vehicle Regulations

(WP.29)

&

Working Party on Lighting and

Light Signalling (GRE)

15

United Nations work

SC.1Working Party

(Sub-Committee)

on Road Transport

WP.1Working Party on

Road Traffic Safety

(68 Vienna Conv.)

AC.11958 Agreement

43 members and 126+2 Regulations

affecting 49 countries

AC.31998 Agreement

31 members and 11+?? gtr

affecting presently 43 countries

AC.41997 Agreement

6 members

affecting Europe only

Other ITC assignments:

ITS

Task Force- Japan / UK -

GRELighting and light

signalling- Canada (TC) -

GRRFTires, brakes and

running gear- United Kingdom -

GRSPPassive safety- USA (NHTSA) -

GRSGGeneral safety

- Italy -

GRPEPolution & energy

- Germany -

GRBNoise

- Germany -

AC.2

WP.29Advisory function

Coordinates work of WP.29

WP.29World Forum

for Harmonization of

Vehicle Regulations

SC.2Working Party

(Sub-Committee)

on Rail Transport

SC.3

WP.5 6 11 15 24 30

UN ECE – ITC

17

UN Regulatory development procedure

NEW

global technical

regulation (gtr)

not addressed by

regulations listed in

the Compendium or

UN/ECE Regulations

UN/ECE Regulations

(UN registered)

Compendium of

Candidates

(UN registered)

AC.3 discussion

and vote on listing

in Compendium of

Candidates

Existing national

regulation proposed

by a Contracting

Party (CP) for listing

in the Compendium

1/3 vote

in favour

5 year review

AC.3

considers CP

proposal and later

preliminary report

from Working

Party (GR)

Global Registry of

global technical

regulations

(UN registered)

a) candidate regulation removed

by the originating CP or

b) a gtr on the same subject

was registered

UNECE Working Party

(GR) develops

1) preliminary report to AC.3 or

2) gtr and final report to AC.3

AC.3 considers

and votes on

gtr and final GR

report

proposal

rejected

HARMONISED

gtr based on

UN/ECE

Regulations

and/or regulations

listed in the

Compendium of

Candidates Contracting

Party (CP)

proposal

2) gtr &

final report

proposal referred to GR for:

1) preliminary consideration or

2) gtr development

gtr approved

by a consensus vote

request for

additional workrejected if less than

1/3 vote support

1) preliminary

report

1

2

1 2

ORDraft

NEW

UNECE

Regulation

Working Party (GR)

under UNECE/WP.29

develops Final draft

AC.1

Votes on

Final draft

proposal

rejected

Amendment to

an existing

UNECE

Regulation

Proposal by

Contracting Party

Accredited NGO or

Guest invited by

Secretariat or

Chairman

OR

Final draft

rejected

UN Regulation UN GTR

Why should US/Canada participate?

Impact on UN Regulations development Colour specification

CHMSL

Cornering lamps

Conspicuity marking on HD vehicles

Daytime running lights

Allow use of marking lamps with DRL

Working on: - mandatory side retro-reflector on short vehicles

Teach

Learn

Together develop new approaches 18

GRE work

Interesting subjects on the agenda

AFS (adaptive forward-illumination system) (adopted)

Emergency stop signal (adopted)

Rear collision alert signal (adopted)

Automatic upper beam switching (adopted)

Automatic headlamp levelling (adopted *)

Headlamp and rear lamp glare GTB-T.F.

Adaptive upper beam

Motorcycle conspicuity

Phantom light (clear and colourless lenses)

19

GRE work

… future

Role of lighting and light signalling:

Vehicle-based ITS components

Collision avoidance (visual signal emission and detection)

Pedestrian safety (illumination and visual warning signal)

Car-to-car communication

Vehicle trains “Safe Road Trains for Environment”

www.SARTRE-project.eu

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GRE work .

http://www.sartre-project.eu/



See into the future …

… provoking thoughts

21

Unique national regs became a thing of the past

Working with two sets of regulations

US FMVSS

UN 1958 Agreement – UN Regulations

UN 1998 Agreement – UN GTR

1998 Agreement and UN GTRs could provide best

means of regulatory harmonization

Instead of creating unique regulations - influence

US Standards / UN Regulations or create UN GTR

22


35 mph into full-width underride guard

Why influence not just adopt ?


Challenges of UN GTR development process

Required cost benefit analysis - different markets

Parliamentary procedures

Political pressures

Reluctance to change

Inconsistent interpretations of 1998 Agreement

Fear of legal repercussions for regulatory changes/improvements

Conflicting interests and protectionism

24


Harmonize with FMVSS – to the extent possible

Harmonize with UN Regulations – if feasible

Actively support development of UN GTRs

Canadian adoption process of UN GTRs

Goals:

Harmonize with FMVSS regulations

following US adoption of UN GTR

Offer as alternative UN Regulations

possibly with exceptions

Provide maximum flexibility when UN GTR

include options (e.g. UN GTR 1 - door locks)

25

Canadian (TC) perspective

26

… Harmonization


Everybody is talking about …

Harmonization

Benefits

Potential to improve safety by adopting best practice

Greater consumer choice and “tool” recognition

Lower unit cost and burden on industry

Increased regulatory efficiency (less cost, faster harmonization)

Risks

Harmonization to lowest common denominator

Reduced ability to address region-specific needs

Loss of market control - increased maintenance cost

Slower regulatory development process (many partners)

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Harmonization:

Stakeholders and issues

Pros:

Lower cost

one design

one test

Cons:

Increased competition

Loss of market control

Resulting need for globally supported warranties and spare parts distribution

29

Manufacturers

Pros:

World-wide styling selection

Uniformity of driver’s environment

Hope for increased safety

Cons:

Fear of safety regulations set at lowest common denominator

Loss of sovereignty

30

Consumers

Pros: Combined human efforts

Access to large pool of experts

Joint financial and infrastructure resources

Concerted enforcement

Cons: Loss of ability to address region-specific

demands

Slower regulatory development process

Getting together logistics of travel / communication

31

Governments

Harmonization

Who wants it / who needs it - examples:

Headlamp beam pattern

UN GTR “108” installation

UN GTR “101”

What is industry interest … (“hard” and “soft” regs)

32


Assuming all agree on

harmonization …

how to proceed?

33

Present regulatory requirements and:

Needs (wants?) – over-, under- regulation

design restrictiveness in regulatory text (FMVSS 102 “transmission shift lever” vs. “transmission control”)

new technology

Development (do we or don’t we?)

Utilization (can we do it? – AFS, cornering lamps, …)

FMVSS 108 para. S5.1.3 new S6.2.1 – opportunity for wise or “free for all” No additional lamp, reflective device, or other motor vehicle equipment [shall / is permitted to ] be installed that impairs the effectiveness of the lighting equipment required by this standard”

34


Performance-based regulations - lighting example

Need new evaluation process for

Road illumination (number/location/test point intensities vs. actual road/signs/obstacles illumination and glare)

Signalling and marking (size/test point intensities vs. actual visibility, glare and perception of signal during day and night)

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Performance-based regulations - lighting example (cont.)

Uniform nomenclature

Light bulb / LED / HID / LASER / = light source

Lamp = function

Pilot lamp / indicator lamp = telltale

Requirements describing performance

Driver must see (actual illumination vs. test points)

Lighting/light signalling function must not glare

Vehicle dimensions and bulk have to be seen

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QUESTIONS & ANSWERS

Marcin Gorzkowski: 1-613-998-1967

[email protected]

38

Thank you

for your

attention

TSEI 2011 Fall Conference Transport... · TSEI – 2011 Fall Conference Washington, DC - 20 October...

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