1. Unclear defined items in Regulation No.129
Hans Ammerlaan - Netherlands
IWG on CRS, Paris 23 March 2016
IWG on gtr No.7-Phase 2, 5-6 December 2011

2. Contents Introduction
Non defined use of ISOFIX anchorages by other systems
Definition of the presence of a top tether
Use of spacer
Use of anti-rotation devices
IWG on CRS, Paris 23 March 2016

3. Introduction
In the 56th meeting IWG CRS meeting, by means of document CRS 56-04, the item of ECRS with and without shield was raised.
Reg.129, meant to be the regulation for Enhanced CRS, in fact does not clear define for this ECRS with shield what are the rules.
A view of Reg.129, having in mind the extension with phase 2, revealed a number of items that also should be defined more clear.
This documents raises 4 of these items.
IWG on CRS, Paris 23 March 2016

4. Non defined use of ISOFIX anchorages I
Now in Reg.129 in par and is stated the following:
2.11. "ISOFIX anchorages system" means a system made up of two ISOFIX low anchorages fulfilling the requirements of Regulation No. 14 which is designed for attaching an ISOFIX child restraint system in conjunction with an anti-rotation device.
"ISOFIX low anchorage" means one 6 mm diameter rigid round horizontal bar, extending from vehicle or seat structure to accept and restrain an ISOFIX child restraint system with ISOFIX attachments
Strictly speaking in terms of a approving, this means that another use of these ISOFIX low anchorages for attaching CRS is not considered as part of the agreement and can be seen as forbidden.
IWG on CRS, Paris 23 March 2016

5. Non defined use of ISOFIX anchorages II
Proposal to get more options of use defined in a clear way:
Paragraph 2.11., amend to read:
“2.11. "ISOFIX anchorages system" means a system made up of two ISOFIX low anchorages fulfilling the requirements of Regulation No. 14 which is designed for attaching an ISOFIX child restraint system in conjunction with an anti-rotation device. Any use by a Child Restraint System of the ISOFIX anchorages system in another way than as described in par can only be approved as “specific vehicle” category.”
Paragraph , amend to read:
"ISOFIX low anchorage" means one 6 mm diameter rigid round horizontal bar, extending from vehicle or seat structure to accept and restrain an ISOFIX child restraint system with ISOFIX attachments or restrain (as exclusive lower anchorage) a child restraint system of the non-integral class of a mass less than 37 kg.
IWG on CRS, Paris 23 March 2016

6. Definition of presence of top tether I
Now in Reg.129 in par is stated the following:
“ It shall not be possible to remove or detach without the use of specific tools, any components not designed to be removable or detachable. Any components that are designed to be removable for maintenance or adjustment purpose shall be so designed to avoid any risk of incorrect assembly and use, as the assembly and disassembly processes shall be explained in detail in the restraint user guides. Any harness shall be capable of its full range of adjustment without disassembly.”
For harness belts this is safe guarded in this same par by: “Any harness belt shall be capable of its full range of adjustment without disassembly.” .
However other essential components have also to be named and brought under some rules to avoid diverging in assessment.
In an earlier presentation the impact shield was mentioned as essential component and herewith the top tether is brought up too.
IWG on CRS, Paris 23 March 2016

7. Definition of presence of top tether II
There is no rule that a top tether has to be permanently attached to an ECRS. This way of handling is taken over from Reg.44 CRS.
With some Reg.44 approved CRS a top tether is not even delivered together with the CRS; consumers have to pay extra money to get this top tether!
In the philosophy of enhanced CRS a top tether must be acknowledged as an essential component (to restrict rotational acceleration and accessive forward head movement) and must be part of the CRS.
Par shall be extended with subs , , etc. and define for essential components such as harness, impact shield, top tether what is the only way to get approval.
IWG on CRS, Paris 23 March 2016

8. Use of spacer
The use of the spacer is taken over from Reg.44, however two items with regard to its use lead to diverging opinions.
Item 1:
Some people think that the use of the spacer is restricted to CRS that have harness belts.
This is a misunderstanding because the spacer must be used for testing of all CRS that make use of adjustment systems.
Item 2:
We are confronted with a peculiair way of beating the requirements; namely the seat back of a CRS has been equiped with a corridor in which the spacer fits.
Beating the requirements like this does not help children in practice, the width of the spacer should be enlarged such that it is like the back of a fluffy winter coat.
IWG on CRS, Paris 23 March 2016

9. Use of anti-rotation devices
For coming up phase 2, the R129 does not take account of what new types of ECRS could need as anti-rotation device.
Now par states the following:
2.12. "Anti-rotation device" means a device intended to limit the rotation of the Child Restraint System during a vehicle impact and consisting of:
(a) A top-tether strap; or
(b) A support-leg, meeting the requirements of this Regulation and fitted to an ISOFIX anchorage system and ISOFIX top tether anchorages or vehicle floor contact surface meeting the requirements of Regulation No. 14.
An "Anti-rotation device" for a "Specific vehicle ISOFIX" Child Restraint System may comprise a top tether, a support-leg or any other means capable of limiting the rotation.
This could be extende with a (d) as follows:
(d) For ECRS up to … cm, that are restrained by the adult belt only. The ISOFIX topt teher connections may be used as additional anchorage.
IWG on CRS, Paris 23 March 2016

10. Thank you for your attention
IWG on CRS, Paris 23 March 2016