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Advantages and Disadvantages
How to Reflect Revisions on Requirements for Backward Field of Vision – by Transcription or by Reference? Advantages and Disadvantages Chair of TFRWS Regarding the requirements for backward field of vision, discussion is under way toward making it a new regulation apart from R46.
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Background The TFRWS is discussing the feasibility, when the vehicle has other safety devices installed, of pausing the reverse warning sound temporarily. For the reverse warning sound to be paused temporarily, safety needs to be ensured by other safety devices. Meanwhile, at WP.29, the VRU-Proxi IWG under the GRSG is examining the requirements for field of vision while reversing and the requirements for backward obstacle detection systems. We think we can benefit from the results of their discussion. The minutes of the previous meeting of the Task Force stated the following: The Group pointed out, that an equal level of safety has to be fixed inside this UN-Regulation, if requirements about Pause Switch would be included (e.g. camera-monitor system, which also will be steered by an existing trailer with/without camera-monitor-system). It was suggested that, to reflect the results of those discussions in the new regulation, the revised requirements for field of vision be transcribed in the new regulation. Accordingly, we summarized the advantages and disadvantages of reflection by transcription as opposed to by reference.
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When Reflecting Revisions by Transcribing Specific Ones
Advantages: By transcribing specific revisions deemed reasonable by the TFRWS in the new regulation, we will be able to avoid facing inconvenient consequences (in that case, it would be smarter to reflect the revisions by specifying their numbers in the new regulation than fully transcribing the texts). Disadvantages: If R46 is revised, then the new regulation has to be revised accordingly whenever necessary by examining the appropriateness of reflecting the revision, etc. If the GRSG is to correct typos and make minute changes, we might not follow through all of them. (We would have to permanently follow GRSG’s moves, which would require tremendous effort.) Is the TFRWS even capable of accurately judging the requirements for cameras and sonars on its own?
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When Reflecting Revisions by Referring to Specific and Subsequent Ones
Advantages: The latest revisions discussed and adopted by the GRSG can be reflected in the new regulation without having to revise it. We can benefit from the results of discussion by experts on the requirements for field of vision and safety devices. Disadvantages: If R46 is revised, we might end up facing unexpected inconvenient consequences. The TFRWS will need to judge if it is appropriate or not to leave (include) older revisions. << EC expert: Both disadvantages can be avoided with the appropriate collaboration between the 2 GRs.
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When Reflecting Revisions by Referring to Latest Revisions
Advantages: The latest revisions discussed and adopted by the GRSG can be reflected in the new regulation without having to revise it. We can benefit from the results of discussion by experts on the requirements for field of vision and safety devices. Disadvantages: If R46 is revised, we might end up facing unexpected inconvenient consequences. << EC expert: This disadvantage can be avoided with the appropriate collaboration between the 2 GRs.
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