Comments and Questions on Proposal for new Class VIII close-proximity and close rear-view devices UN R46 Devices for indirect vision GRSG-110-12 (Japan) or GRSG-111-23 (Japan)

UN R46 Devices for indirect vision GRSG-110-12 (Japan) Proposal for amendments to UN R46

UN R46 Devices for indirect vision Part I Discussion on accident data

UN R46 Devices for indirect vision Comments on R46TF-04-03 Study of Pedestrians fatal accidents.pdf This conclusion may be discussed as: -Looking at the total situation (upper chart) the collision rate at the front (1)(2)(3) is significantly higher. -Limitation to 10km/h over-emphasizes rear driving accidents because speeds during rearward driving are typically limited. -Frontal type impacts are much more frequent. The Japanese accident statistics does not seem to justify the rear view device. Slide 9 – Document: R46TF-04-03 Study of Pedestrians fatal accidents.pdf

UN R46 Devices for indirect vision Comments on R46TF-04-03 Study of Pedestrians fatal accidents.pdf Forward driven scenarios Rearward driven scenarios N ≥7.5t 71 7 N <7.5t 63 29 Bus 8 Box van 5 1 Mini van 30 11 SUV 4 Sedan 43 21 Light Cargo van 28 9 Light pass car The majority of fatalities in Japan is noticed in forward driven (red field) scenarios. The speed limitation to 10km/h seems not justified Slide 10 – Document: R46TF-04-03 Study of Pedestrians fatal accidents.pdf

UN R46 Devices for indirect vision Comments on R46TF-04-03 Study of Pedestrians fatal accidents.pdf Slide 11 – Document: R46TF-04-03 Study of Pedestrians fatal accidents.pdf The assessment of the collision rate leads to a misinterpretation of the relevant accidents scenarios in the field. Furthermore scenarios i) to iv) seem more important to be addressed than scenario v). Can Japan explain why right turning is so dominant over left turning, as the direct visibility should be much better on the right side in Japan?

UN R46 Devices for indirect vision Further questions to Japan‘s accident data analysis 6.4% In comparison to GIDAS (German In-Depth Accident Study) only 6,4% of pedestrian fatalities occur at speeds ≤10km/h (see adjacent diagram) Can Japan explain how such a high percentage of fatalities can occur at such low speeds (≤10km/h)?

UN R46 Devices for indirect vision Source: German In-Depth Accident Study (GIDAS) Filter I: Period: 1999 – today  Pedestrians in GIDAS (n = 3447) Pedestrian Accidents: Opponents and Age Groups n = 3447 Opponents see next slide n = 2510

UN R46 Devices for indirect vision Source: German In-Depth Accident Study (GIDAS) Pedestrian Accidents: Impact Location Overview Filter II: Period: 1999 – today Opponent: Cars Impact Location: all, excluding “unknown”  Pedestrians in GIDAS (n = 2510) n = 2510 1 12 6 2 5 4 11 10 9 7 8 3 see next slide n = 216

UN R46 Devices for indirect vision Source: German In-Depth Accident Study (GIDAS) Pedestrian Accidents: Impact Location at Rear - Age Groups Filter III: Period: 1999 – today Opponent: Cars PDOF: 4, 5, 6, 7, 8 (rear)  Pedestrians in GIDAS (n = 216) n = 216 Age Groups Focussing on children 0-12y, due to their height. 6 cases remain: - 5 have a case description, one case was not described in detail. - All Injuries: AIS ≤ 1. see next slide n = 6

Estimated effect of extended rear view or warning device UN R46 Devices for indirect vision Source: German In-Depth Accident Study (GIDAS) Pedestrian Accidents: Case-by-Case Analysis Case Description Car equipped with ultrasonic sensors or rear view camera Estimated effect of extended rear view or warning device Velocity Yes No Unknown 1 The driver moved backwards at 15kph towards sidewalk to turn. The driver overlooked child (4yo) coming from the left, hitting it with the left rear corner. Child fell and right foot was rolled over by the left front wheel. + (1) 15 km/h 2 The driver was leaving a cross parking backwards, hitting her own son (2,5yo) behind the car, who fell onto the road. She had assumed her husband had already placed the child into the car. + 5 km/h 3 The driver drove backwards at an autobahn rest stop, failed to see and hit a girl (6yo) crossing the road from left to right. + (2) 7 km/h 4 The driver was parking backwards at a fast food restaurant. He overlooked an adult with a pram behind the car. The car collided with the pram, the child fell out of the pram and suffered head injury. + (3) 5 A mother with her child (4yo) wanted to cross the street. The car driver went back and hit the both. 6 - No further description available - ? (1) Not clear whether child would have been within extended field of view before impact (2) Pedestrian not visible at early enough time before impact (3) Adult already visible through direct view

UN R46 Devices for indirect vision Source: German In-Depth Accident Study (GIDAS) Pedestrian Accidents: Conclusion Within lifetime of the GIDAS database (since 1999) only 6 cases involved children less than 12 years with potential relevancy to extended rear field of view have occurred. In these cases the struck pedestrians (children) experienced only minor injuries (AIS≤1). After case by case analysis the potential effectiveness of extended rear field of view is questionable in most cases. In GIDAS the impact to the front of the vehicle is much more relevant than to the rear. The percentage of injured pedestrians older than 12 years, presumably directly visible or within regulated field of view, is significantly higher than the group of injured children  visibility is probably not the root cause In GIDAS only 1 pedestrian was fatally injured by a rearward driving vehicle. Thus there is a huge discrepancy between German and Japanese dataset that needs further explanation before any regulation change.

UN R46 Devices for indirect vision General comments Manufacturers have concerns about the Japanese accident study and the conclusions drawn from it. The Japanese proposal is to be fulfilled with a combination of direct view and indirect view. Further the proposal suggests accepting new technology detecting close objects: It is therefore unclear as to whether the amendments would have to be added to UN R46, UN R125 or a new UN regulation covering new technologies. Frontal direct view and impact measures are already addressed in regulations (UN R125 and UN R127). The proposal does not give any indication about the conditions under which the new technologies are to be operated and are to be effective. Manufacturers see a need for the assessment of the regulatory and technological impact. German accident study does not give reasons to related actions to be taken.

UN R46 Devices for indirect vision BACK-UP

UN R46 Devices for indirect vision GIDAS: To evaluate the occurrence of fatalities after rear driving maneuvers, all pedestrian fatalities with PDOF 4-8 (rear side and rear) have been filtered. No age or impact speed filtering. A case-by-case investigation was carried out revealing the car impacts as wrong coding, also the impact with power two-wheelers (PTW). Only 1 truck case is clearly confirmed.