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Transmitted by OICA Document No. IWVTA-SGR0-02-02 rev2. IWVTA: UN-Regulation No.0 Flexible scheme allowing for different levels of requirements in different Contracting Parties.
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Transmitted by OICADocument No. IWVTA-SGR0-02-02rev2 IWVTA: UN-Regulation No.0 Flexible scheme allowing for different levels of requirements in different Contracting Parties This document SGR0-02-02rev2 has been updated and extended to reflect the discussions which took place during the sub group R-0 meeting on 2012-09-27. It supercedes the previous document and should be used as basis for further discussion in the subgroup and informal group In comparison to the previously distributed rev1 feedback from several sides has been takebn up and a preamble slide has been added.
Preamble Forthedevelopmentof UN R-0 OICA hassuggested 2 schemeswhichshouldbekeptentirely separate fromeachother • The stepwiseapproachtowards IWVTA (cf. DocumentIWVTA-04-10): in theproposedstep 2 thiswouldallowtoincorporate national/regional requirementsinto an IWVTA • The flexible scheme (thisdocument) isproposedto handle thesituationthatContractingPartieswouldacceptlowerrequirements (approvalstoearlierversionsorevennoapprovalsat all). Itis not intendedto beusedtoincludeanyrequirementsthatare additional towhatis in the UN regulations. Way forward: a suitabestartingpointforimplementationof IWVTA wouldbetouseonlystep 1 ofthestepwiseapproach (i.e. a setof UN regulations) but applythe flexible schemerightfromthestart.
Basic Principles • All CPs applying R-0 must accept approvals to the latest level (=series of amendments) of any UN-Regulation annexed to R-0 * • However, a CP may declare that it will accept approvals to an earlier version of any such UN-Regulation • This leads to 2 different types of IWVTA approvals • Universal IWVTA: the manufacturer provides in his application approvals to the level of all annexed Regulations as specified in R-0 this IWVTA has to be accepted by all CPs applying UN R-0 • IWTVA of limited recognition: any CP can declare that for some or all annexed Regulations they are satisfied with approvals to earlier versions or no approvals at alla transparent method is required to determine whether the approval of limited recognition can be accepted in a given CP • The following slides explain how this evaluation can be achieved by a commonly available tool * a seperate discussion is necessary how to resolve the situation that CPs cannot accept approvals to the latest version on their territory e.g. because of fuel quality. However, this is seen as a topic independent of UN-R 0.
Evaluation Concept Repository of requirements Manufacturer´s application Acceptanceevaluationtool Acceptance table ü ü
How to handle if-fitted requirements • The evaluation concept can also be used to handle if-fitted requirements (as listed in table 2 of Annex 4 Part A of document IWVTA-09-08) • Guidance is needed with respect to 2 options: • If a CP does not mandate a system, this means it imposes no requirements even if the system is fitted voluntarily • If a system is fitted voluntarily then the requirements of the respective Regulation from table 2 must be met even if the system is not required in a CP
Consideration of options for if-fitted requirements Option a) • Evaluation isstraightforward • Onlyinformationaboutapprovals in themanufacturersapplicationisnecessary Option b) • In additiontotheapprovalsthemanufacturersapplicationneedstoincludeinformationaboutthefittingstatusofsystems (=necessityofapprovalsforvoluntarilyfittedsystems) • Forsomesystemsthismayleadtodiscussionswhether a voluntarilyfittedsystemisreallyofthe type coveredbytheif-fitted Regulation oronly „similar“ (= whethertheapprovalisnecessaryor not) Discussion in thesubgroup R-0 on 2012-09-27 showedthatmaybeboth Options maybeneeded on a casebycasebasis: • Forvehiclesystemslikemechanicalcouplingsoption b) seemsappropriate • Forsystemslike ESC itisOICA´srecommendationthatoption a) beconsidered in ordertoavoiddiscussionsaboutnecessityofapprovals.
Exemplary acceptance evaluation tool (1 of 3) • Usepresentationmodewhenviewingthisslide !!! • All entries in tablesareforillustrationonlyandmay not reflecttherequirementsof a CP • The tableconsistsof 3 sections: Manufacturers application Requirements for CPs Requirements for universal IWVTA series of amendments no requirement
Exemplary acceptance evaluation tool (2 of 3) • Manufacturer´s application is identical to R-0 content • Requirements of EU, Japan and Russia are identical with R-0,but no or lower requirements for Malaysia and South Africa in some cases Example 1: • The approval will be accepted in all CPs
Exemplary acceptance evaluation tool (3 of 3) • Manufacturer does not provide an ESC certifcate • As a consequence EU, Japan and Russia will not accept the approval. This is displayed by red markings. However, the approval has to be accepted in Malaysia and South Africa (no red markings in column)* Example 2: * under the hypothesis of option a) for if-fitted systems
Exemplary acceptance evaluation tool: comprehensive table • A more comprehensive table is provided as an attachment for testing purposes • It is based on the list of candidate Regulations and lists all CPs (except EC Member states which have harmonized requirements and are covered by the column EC) • Note that all entries concerning the required series of amendment are for illustration only and do not prejudge any decisions of CPs • The table can be used to test the concept by either changing the content of the manufacturer´s application or the required levels in CPs. Whenever the application is not „sufficient“ for a CP, the corresponding box will be marked in red. • evaluation_tool.xlsx
Possible future extension of the approach • When moving from step1 to step 2 of the implementation strategy for IWVTA* the presented approach can easily be generalized • Respective national requirements are simply added to the table • For these only 1 CP requires the corresponding approvals • This is illustrated for some elements of EC-WVTA for which currently no UN-Regulation exists in the 3rd sheet of evaluation_tool.xlsx(added entries compared to first sheet marked in yellow) * See Document IWVTA-04-10 by OICA: stepwise introduction scenario
Handling of the flexible scheme within Annex 4 of UN-R 0 • In Annex 4 only the requirements for a universal IWVTA shall be explicitly included this refers to tables 1 and 2 in SGR0-0204 (as well as table 4 when moving to step 2 of the implementations scheme) • The alternative requirements (including acceptance of previous versions) which can be used for an IWVTA of limited recognition would be documented outside of R-0 (based on a notification by CPs accepting IWVTA of limited recognition) table 3 would be replaced by a reference to another document („Repository of alternative requirements“) that while publicly available can be maintained independently of R-0(see following slide)
Process for the Repository of alternative requirements • A Contracting Party that intends to accept approvals to IWVTA with limited recognition has to notify the UN secretartiat according to which of the Regulations and which versions thereof it is accepting for IWVTA (similar to the single line entries in current table 3). A standardized format for such notification should be provided. • A Contracting Party accepting only approvals to universal IWVTA does not have to provide any notifications. • All notifications shall be documented and published by the UN secretariat. R-0 will refer to this repository of alternative requirements • It is seen as beneficial to create out of all notifications on central table like the evaluation tool refererred to in slide 9. However such a tool can be created and maintained by persons or organizations other than the UN secretariat. Nevertheless, for practical reasons it should also be commonly available, e.g. via the UN website. • Contracting Parties applying R0 for IWVTA with limited recognition may at any time upgrade their application of R0 (to the unniversal or an intermediate level) by notification to the UN secretariat. However, appropriate lead time should be respected for any such upgrade to enter into effect.To be discussed: upgrade become effective only xx months after they have been included into the repository.
Update of R-0 • As UN-Regulations are frequently updated to create new series of amendments this will cause the need to also upgrade the list of Regulations to be complied with for universal IWVTA • It should be decided whether the adoption of a new series of amendments of a Regulation referenced in Tables 1 and 2 of Annex 4 shall automatically trigger an upgrade or R-0 or whether this requires a special vote, e.g. by WP.29 during the adoption vote of the annexed Regulation. • Regardless of the outcome of the question from the previous bullet point it is impractical to upgrade R-0 whenever a annexed Regulation is upgraded. This would lead to too many series of amendments for R-0. • However, since upgrades of UN-Regulations are usually subject to transitional provisions, in turn upgrades of R-0 can be bundled taking the transition times of the individual amended Regulations into account. The following process is proposed: • Whenever a upgrade of R-0 due to a new series of amendments of an annexed Regulation is decided (see 2nd bullet point), this Regulation is inserted in a repository of candidate upgrades together with the information, by when the upgrade of R-0 has to be done at the latest to ensure that this is done before expiry of the transitional provisions. • In preparation of each WP.29 meeting this repository is reviewed to identify whether the recorded expiry of the trnasitional provisions necessitate a upgrade of R-0 in this WP.29 meeting or whether this can be postponed to the next meeting. • If an upgrade of R-0 has been determined to be necessary the entire content of the repository is used. • It should be decided which institution or group is responsible for the review of the repository of candidate upgrades.
Handling of IWVTAs with limited recognition • While the flexible scheme in principle allows for arbitrary combinations of limited or earlier requirements using the repository of alternative requirements, it has been discussed whether the number of levels of stringency should be restricted, e.g. allowing only for levels „universal“, „mid“, and „low“. Guidance is needed on this question. • In case of a restriction this would have to be implemented into the notification process for CPs to identify the level of the IWVTA with limited recognition (cf. Slide 13): not all series amendments of all Regulations could be notified but only a selection out of a predefined list would be possible. While this would have effect in terms of R-0, it would not compromise the ability of CPs to accept other levels of stringency than those offered in R-0 in their national WVTA-process. • It is further proposed to identify via the approval number whether a IWVTA is universal or of limited recognition. This could be implemented e,.g. by adding the letter „U“ for universal and „L“ for limited into the approval number. • In case, the number of variants for limited recognition is restricted (cf. 1st bullet point) the approval number could even indicate the level of stringency, e.g. „M“ for mid and „L“ for low. • If no such restriction is desried, the acceptance can still be determined using the acceptance table.
Consequences for the current draft of R-0 Based on the previous slides the follwing items have to be changed in the draft R-0: Reference to the repository of alternative requirements • It is suggested to rename the tables of Annex 4 as sections • With this change of wording the only further change in Annex 4 is that the table is replaced by a reference to the repository which should be available on the UN-website Defintion of the approval number • Distinguish between universal and limited recognition IWVTAs in Annex 2