OICA input on TF1 discussions for GTR-EVS EVSTF-08-41e OICA input on TF1 discussions for GTR-EVS 2016-05-14

Rationale for Option 3 from TF1 discussions for GTR-EVS Option 3 from TF1 discussions: Postpone water requirements to phase 2 to allow time for research and a wider discussion of water exposure conditions Rationale for postponing water testing to phase 2 of the GTR-EVS: It still remains to be proven that water exposure poses a safety risk in EVs today. No reported field safety failure occurences caused by loss of isolation resistance exist. The issue is already satisfactorily addressed by existing technology and engineering practice in the automotive industry, see following pages. There is ongoing research at NHTSA and other contracting parties addressing water exposure in a wider sense (results of these studies are projected not to be available before 2018)

Background information: The current draft GTR-EVS proposes 2 tests to verify that isolation resistance needs to be considered after REESS has experienced significant water exposure: Flooding test Washing test Washing and flooding are representative examples of severe conditions in normal vehicle operation. The tests are only required by vehicles not equipped with isolation resistance monitoring systems, as these systems are designed to reliably identify and warn the driver if the isolation resistance threshold is effected. Both of these tests originate from the revoked ISO 6469-3 (2001) but were removed in the current edition of ISO 6469-3 (2011) since they were deemed unnecessary and not motivated by realistic safety concerns.

ISO 6469 Electrically propelled road vehicles - Safety specifications Part 3: Protection of persons against electric shock The requirements given in this part of ISO 6469 shall be met across the range of environmental and operational conditions for which the electrically propelled vehicle is designed to operate, as specified by the vehicle manufacturer. NOTE See ISO 16750 for guidance. Protection against electric shock shall be composed of Basic protection measures against direct contact with live parts Measures for protection under single-failure conditions. If the minimum isolation resistance requirement cannot be maintained under all operational conditions and over the entire service life, one of the following measures shall be applied: monitoring of the isolation resistance double or reinforced insulation

ISO 6469 Electrically propelled road vehicles - Safety specifications Part 3: Protection of persons against electric shock Protection against electric shock Basic protection measures Measures for protection under single-failure conditions Basic insulation Barriers, enclosures Isolation resistance Potential equalization Capacitive couplings De-energization If the minimum isolation resistance requirement cannot be maintained under all operational conditions and over the entire service life: double or reinforced insulation monitoring of the isolation resistance

Conclusions from ISO 6469-3 Isolation resistance is one of several measures for protection against electric shock under single-failure conditions. The concept is that safety is assured in normal operation and under single-failure conditions. Washing and flooding are just representative examples of severe conditions in normal vehicle operation. Vehicle safety performance shall be fulfilled under all normal operating conditions. Regulatory safety requirements cannot be tested under all normal operating conditions. Isolation deterioration doesn’t cause an electric shock when other protection methods (basic protection measures and protection under single-failure conditions) are in place.