1. Japan’s Stance for the R129 Phase 2
44th GRSP Informal Group on Child Restraint System
23rd Apr. 2014
JASIC

2. Japan’s Stance for R129 Phase2 Correction of formal document
Delete the footnote “For lateral impact, Q6 dummy could be used for a size range up to 135 cm”.
Add “No lateral impact test is required for size ranges over 125 cm until Q10 dummy’s injury criteria for the lateral impact test are established”.
Correction of formal document
The following footnote in paragraph to be deleted:
For lateral impact, Q6 dummy could be used for a size range up to 135 cm
The following footnote in paragraph to be added:
“No lateral impact test is required for size ranges over 125 cm until Q10 dummy’s injury criteria for the lateral impact test are established.”

3. Justification
Technically, safety evaluation for children whose size exceeds 125 cm cannot be conducted with Q6 dummy.
In CRS evaluations for sizes 135 cm or above, safety differences would occur between evaluations that use Q6 dummy (as proposed by the draft amendment) and future evaluations that use Q10 dummy.
The current proposal can be incorrectly interpreted as being capable of ensuring the lateral impact performance for size ranges over 125 cm.
For these reasons, it is appropriate to state in the regulation that no lateral impact test is required for size ranges over 125 cm.

4. Reference
Table 6 in paragraph of R129 specifies the dummy used in each dynamic test per CRS size range.

5. Japan’s Opinion for Universal Booster Correction of formal document
All the universal boosters in size ranges 135 cm or below must be booster seats (as agreed in the past IWG meetings up to the 42nd meeting).
Correction of formal document
The sentence “All the universal boosters in size ranges 135 cm or below must be booster seats” to be added (in paragraph 6?)

6. Justification
Since booster seats are expected to provide higher levels of safety in collisions than booster cushions (because of the presence of the shoulder belt guide in frontal collisions and of the side protection in lateral collisions), it is desirable from a standpoint of child occupant safety that the universal boosters in size ranges 135 cm or below be booster seats.
Interference between adult occupant (5F dummy) protection and CRS can occur even with size ranges not exceeding 125 cm. It is unknown where to draw a line in order to solve this interference problem (interference between CSA and CRS has been reported with Q3 integral CRS).