Van Laarhoven - DEKRA -Simplification of UN Regulations - pro's and contra's

Name of author:        Wilfried van Laarhoven

Contact data:             DEKRA Certification B.V.

                               P.O. Box5185, 6802 ED Arnhem

                               TheNetherlands

Email:                        Wilfried.vanLaarhoven@dekra.com

Telephone:                 +31 88 968 3205

Topic of theabstract:Regulations/Directives/Standards

Title:                           Simplificationof UN Regulations - pro’s and contra’s

Summary

Many UN Regulations deal about lighting andlight-signalling. Especially many light-signalling regulations exist: 6, 7, 23,38, 50, 77, 87 and 91. Also regulations 4 and 119 can be considered assignalling regulations. A big part of each regulation is quite similar. Themain differences are the luminous intensity and colour requirements because ofthe different functionality. The rest of the regulation is intended to bemainly the same.

If the regulations however are accuratelyread and compared, one can find small differences in the text and the generalrequirements. Although these might be not intentional the differences are part ofthe legal system and lead to unwanted different judgements. One can think aboutthe markings, the light source options, type definition, application forapproval, test procedures, communication form and CoP procedures and more.

The above regularly is resulting inconfusion by the users of the regulations (e.g. test houses and manufacturers).One can also imagine the troubles for the rule makers, who have to modify theregulations independently resulting in a lot of paper work and possible errors.

Several ideas have been introduced to solvethis problem:

• To create one new UN regulationto combine groups of functions, such as signalling

• To create an external documentcombining the “non-essential” part and reducing each regulation to only containthe performance requirements.

  
  

  This IFAL contribution will contain a shortexplanation which parties are working on this item and what publications areavailable. Then an overview of the advantages (pro’s) and disadvantages(contra’s) from different perspectives will be listed and explained. Example:if regulatory requirements for one function are upgraded (e.g. better lightdistribution) then a new series of amendments needs to be introduced affectingthe first two digits of the approval number. This is necessary to be able todistinguish lamps approved according to old and new requirements. This mightresult in the unwanted and costly effect for manufacturers that also theapproval numbering (tooling) of unchanged functions has to be modified.