ecall Technical considerations regarding type-approval testing of ecall in-vehicle systems

Transcription

1 ecall Technical cnsideratins regarding type-apprval testing f ecall in-vehicle systems EC Prject Number SI TRL Client Prject Reprt CPR1868 Prepared by TRL J Carrll, M Seidl, R Cuerden, A Stevens mmmll

2 Disclaimer This reprt has been prduced by the Transprt Research Labratry under a cntract with the Eurpean Cmmissin. Any views expressed in this reprt are nt necessarily thse f the Eurpean Cmmissin. The infrmatin cntained herein is the prperty f TRL Limited and des nt necessarily reflect the views r plicies f the custmer fr whm this reprt was prepared. Whilst every effrt has been made t ensure that the matter presented in this reprt is relevant, accurate and up-t-date, TRL Limited cannt accept any liability fr any errr r missin, r reliance n part r all f the cntent in anther cntext. Catalgue number: NB EN-N ISBN: DOI: /95970 Eurpean Unin, 2014 Reprductin is authrised prvided the surce is acknwledged. May

3 Executive summary One f the safety initiatives attempting t reduce the burden frm the 1,100,000 injurius accidents ccurring n the rads f Eurpe, each year, is the implementatin f pan-eurpean ecall. The cre functin f an ecall system is t ntify the emergency services autmatically and rapidly f a ptentially injurius accident. The benefit f ecall arises thrugh the reductin in respnse times fr emergency services attending t the accident, thus helping t save lives and t treat injuries mre rapidly. The Eurpean Cmmissin (EC) has adpted a prpsal fr a regulatin cncerning type-apprval requirements fr the deplyment f the ecall system. Hwever, the delegated/implementing acts t this regulatin, detailing technical requirements and test prcedures fr type-apprval, d nt exist as yet. This reprt dcuments, structures and assesses the available infrmatin which may ffer supprt in develping the vehicle apprval requirements and test prcedures with respect t ecall in-vehicle systems. A cmprehensive review was undertaken f all available relevant infrmatin which culd be used as a basis fr delegated/implementing acts supprting the Cmmissin s prpsal fr a Regulatin f the Eurpean Parliament and f the Cuncil cncerning type-apprval requirements fr the deplyment f the ecall in-vehicle system. This review frms the basis f the study and included surces frm prpsals fr EU, UN and Russian legislatin; Eurpean, Russian and internatinal technical standards; deliverables frm research grups; and psitin dcuments and statements prvided by stakehlders. It cnsidered the available ptins existing currently fr full-scale crash testing and cmpnent testing f ecall IVS. Based n the technical assessment f the material available and discussins with technical experts in the area f ecall and stakehlders frm varius grups, 20 distinct aspects f ecall were identified that need t be cnsidered fr a type-apprval regulatin. Fr instance, the aspects reviewed included such things as scpe f the regulatin, autmatic ecall triggering cnditins, mechanical resistance f the IVS, audi equipment tests, etc. The requirements n ecall shuld be defined s as t maximise the benefit, i.e. affect a large number f casualties, while aviding disprprtinate csts. Detailed cnsideratin was therefre given t which vehicles can and shuld be required t prvide autmatic ecalls and in which accidents autmatic triggering shuld ccur. Optins hw type-apprval testing can ensure that autmatic ecall triggers in accidents as required and the in-vehicle system remains peratinal after accidents as required are assessed in this study. Frm a detailed analysis f these 20 aspects, sme areas were identified where there is a general cnsensus n requirements and test methds and it is expected that regulatry text culd be drafted by cmbining, amending r expanding primary May

4 surces. In ther areas, differing views n the necessity f regulatry requirements and the apprach t be taken make a decisin necessary befre prgress can be made in specifying requirements. Finally, several aspects which shuld be included in a regulatin remain underdevelped, i.e. n test methds are currently available that culd reasnably be cnsidered fr immediate use in a type-apprval regulatin. These areas will require substantial wrk t define apprpriate requirements and test prcedures and represent pririties fr future develpment, if they are t be included. Areas where substantial further wrk was identified as being necessary were: The practicalities assciated with demnstrating pst-crash peratins f the ecall IVS within the envirnment f full-scale crash test facilities. A mechanism t test and discurage superfluus ecall triggering in very lw severity cllisins. The apprpriate testing regime fr assessing wireless link perfrmance f the vehicle regarding psitinal accuracy and mbile phne netwrk cmmunicatin rbustness. The extent f self-test features f the IVS (and perhaps als peridic technical inspectins) t identify faults and hence reduce the need t regulate lifetime perfrmance at the type-apprval stage. Defining guidelines fr the HMI design f ecall systems. These areas shuld be cnsidered as a pririty. May

5 Table f Cntents Executive summary Intrductin Supprting dcuments, standards and research Legislatrs, standardisatin and research grups Overview f relevant surces Future requirements and test methds fr ecall in-vehicle system (IVS) Scpe f the regulatin Optins Cmmentary Recmmendatin Privacy and liability aspects Expectatins Liability Privacy and data prtectin Cnfrmance t relevant technical standards Reasns fr requirements Optins Cmmentary Recmmendatins ecall triggering and test calls Reasns fr requirements Expectatins Optins Cmmentary Recmmendatins Resistance t mechanical impact during nrmal use Reasns fr requirements Optins Cmmentary Recmmendatins Resistance t mechanical impact during accident (crash) Reasns fr requirements Optins Cmmentary Recmmendatins May

6 3.7 Climate resistance Reasns fr requirements Optins Cmmentary Recmmendatins Autnmus pwer supply Reasns fr requirements Optins Cmmentary Recmmendatins Electrmagnetic cmpatibility (EMC) Reasns fr requirements Optins Cmmentary Recmmendatins Resistance t electric impacts Reasns fr requirements Optins Cmmentary Recmmendatins Wireless link perfrmance f glbal navigatin satellite system (GNSS) mdule and mbile netwrk device (MND) Reasns fr requirements Optins Cmmentary Recmmendatins Installatin and cnnectin Reasns fr requirements Optins Cmmentary Recmmendatins Audi equipment Reasns fr requirements Optins Cmmentary Recmmendatin In-vehicle system (IVS) self-test Reasns fr requirements May

7 Optins Cmmentary and recmmendatins Human-machine interface (HMI) Reasns fr requirements Optins Cmmentary Recmmendatins Test equipment Standards cnfrmance testing Wireless link perfrmance testing Resistance testing Electrmagnetic cmpatibility (EMC) testing Audi equipment testing Definitins f terms C-existence f third party and mandatry ecall systems Reasns fr requirements Expectatins Cmmentary Recmmendatins Nmadic ecall devices Additinal aspects Summary Aspects where a clear recmmendatin is available Aspects where a decisin is pending Aspects where develpment f a test cncept is required Cnclusins References Glssary f terms Appendix A May

8 1 Intrductin During 2012, in the Eurpean Unin, ver 28,000 peple were killed n rads 1. The number f peple injured was arund 1,400,000; resulting frm just under 1,100,000 accidents 2. One f the initiatives attempting t reduce the burden frm these accidents is the implementatin f ecall. The cncept f an autmatic crash ntificatin system r ecall is nt new. In the case f a crash, an ecall-equipped car will autmatically call the nearest emergency centre via the emergency number 112. Even if n passenger is able t speak, e.g. due t their injuries, a 'Minimum Set f Data' is transmitted, including the exact lcatin f the crash. Shrtly after the accident, emergency services therefre knw that there has been an accident, and where exactly it ccurred. The benefit f ecall arises thrugh the reductin in respnse times fr emergency services attending t the accident, thus helping t save lives and t treat injuries mre rapidly. EC dcuments suggest that ecall culd speed up emergency respnse times by 40% in urban areas and 50% in the cuntryside, and save up t 2500 lives a year 3. In additin t the rad safety benefits, ecall may als help t reduce the cngestin caused by traffic accidents and the ptential fr secndary accidents t ccur as a result f unsecured accident sites. Cnventinally, ecall is activated autmatically as sn as in-vehicle sensrs detect a serius crash. Once set ff, the system dials the Eurpean emergency number 112, establishes a telephne link t the apprpriate emergency call centre and sends details f the accident t the rescue services, including the time f incident, the accurate psitin f the crashed vehicle and the directin f travel (mst imprtant n mtrways and in tunnels). An ecall can als be triggered manually by pushing a buttn in the car, fr example by a witness t a serius accident. The Eurpean Cmmissin (EC) has adpted a prpsal fr a regulatin cncerning type-apprval requirements fr the deplyment f the ecall system. Hwever, the delegated/implementing acts t this regulatin, detailing technical requirements and test prcedures fr type-apprval, d nt exist as yet. It is the intentin f the new regulatin that it builds n the existing technical standards. Fr instance, the Eurpean Standardisatin Organisatins, ETSI and CEN, have already develped standards fr the deplyment f a pan-eurpean ecall service. These shuld apply fr the purpses f the regulatin. Therefre, as a first stage in wrking twards the develpment f type-apprval requirements, existing infrmatin is gathered that culd help in that purpse. This reprt dcuments, structures and assesses the May

9 available infrmatin which may ffer supprt in develping the vehicle apprval requirements and test prcedures with respect t i ecall in-vehicle systems. Fllwing this infrmatin gathering, it is expected that the available infrmatin will then be cmpared with the requirements and expectatins fr ecall in-vehicle systems befre final prpsals (draft regulatry texts) fr system validatin testing will be made at a later stage. May

10 2 Supprting dcuments, standards and research Many previus studies have reviewed the technlgy and investigated and discussed the ptential benefits assciated with ecall systems. The target fr this review f the supprting dcuments, standards and research was t prvide the EC with an bjective review f the existing dcuments supprting the implementatin f ecall. It is anticipated that the infrmatin cllated frms the basis f, and enables, the detailed technical requirements and tests fr the type-apprval f ecall IVS t be specified. Therefre it included, wherever pssible, the identificatin f prpsals fr methds and assessment prcedures which culd be used t assess ecall systems in a vehicle type-apprval setting. 2.1 Legislatrs, standardisatin and research grups The United Natins Infrmal Wrking Grup AECS 4 (Accident Emergency Call Systems) is in the prcess f drafting a new UN Regulatin n the type-apprval f accident emergency call systems (in the fllwing referred t as Draft UN Regulatin N. XX n AECD/AECS). The Infrmal Wrking Grup (IWG) is under chairmanship f the Russian Federatin and frms a sub-grup f the Wrking Party n General Safety Prvisins (GRSG) within WP.29 (1958 Agreement). The 1 st meeting tk place in Octber 2013 with the initial aim t cmplete the wrk by Octber At the 4 th meeting in April 2014 it was decided t pstpne the date fr finalising an agreed draft t Octber The discussins are based n an initial draft text prvided by the Russian federatin and input frm Cntracting Parties and stakehlders, including OICA, CLEPA, GSA and CETECOM. The wrk cncerns cmmn technical requirements f AECS devices and functins, the data t be transmitted, and test methds; it des nt address questins such as mbile phne cmmunicatin prtcls. The EC published a prpsal n type-apprval f M1 and N1 vehicles with regard t ecall in-vehicle systems (IVSs) in June This prpsal des nt cntain the detailed prvisins n technical requirements r testing. These "nn-essential" elements will be intrduced by the EC thrugh delegated/implementing acts. The Eurpean Parliament adpted a legislative reslutin n the text in February 2014; and the Cuncil discussed and adpted a general apprach in May Bth institutins supprt the mandatry intrductin f the ecall in-vehicle system prpsed by the EC. If an early secnd reading agreement can be reached between Cuncil and Parliament, this might lead t pssible draft delegated/implementing acts at the end f The pinin f the Eurpean Data Prtectin Supervisr n the prpsal f Parliament and Cuncil has been btained. A set f Eurpean EN standards with regard t ecall has been published by the Eurpean Cmmittee fr Standardizatin (CEN) since 2011 cvering numerus 4 May

11 technical aspects like perating requirements, data t be transmitted in case f an accident and end-t-end cnfrmance testing. The Russian Federatin is in the prcess f legislating n ERA-GLONASS which is the Russian equivalent t ecall. ERA-GLONASS will be required fr M1, M2, M3, N1, N2 and N3 vehicles (with varying levels f functinality) frm the beginning f January 2015 fr new types f vehicles. The Russian legislative prcess was supprted by a set f nine GOST standards, published in tw batches in 2011 and 2013 respectively. These cver numerus aspects f technical requirements and test methds and were designed with the aim in mind t ensure technlgical cmpatibility with the main functinal prperties f EU s ecall, e.g. using a mdem tne as the main mechanism fr transferring data, structure and frmat f the standardized mandatry data transmitted as part f the MSD, and tw-way vice cnnectin with vehicle ccupants. The Japanese ecall equivalent, HELPNET, was established in 2000 and has since been vluntarily adpted by majr vehicle manufacturers such as Tyta, Lexus and Hnda. The system is nt legally mandated r regulated but based n vluntary agreements and managed privately. The HeERO prject 5 is a pre-deplyment trial fr pan-eurpean ecall based n the cmmn Eurpean emergency number 112. The prject started with a first phase in January 2011 and cntinued with a secnd phase, running partly in parallel, in January 2013, extending t December The aim f the prject is t prepare the deplyment f the necessary infrastructure fr a harmnised in-vehicle emergency call system that is interperable and prvides crss-brder cntinuity. T test and assess the Eurpean technical standards in real-wrld cnditins trials are carried ut in 15 Eurpean cuntries (nine in HeERO 1; 6 in HeERO 2). Sme deliverables f the prject prvide assessments f the certificatin prcedures and recmmendatins fr future deplyment activities. The Eurpean ecall Implementatin Platfrm (EeIP) 6 is a crdinatin bdy fr stakehlders and natinal platfrms supprting the implementatin f ecall. The platfrm crdinates with member states and assists the EC in preparing legislatin. Its aim is t guide, crdinate and mnitr the prgress f implementatin in Eurpe t ensure a timely, effective and harmnised deplyment. The esafety Driving Grup ecall 7 was a wrking grup established by the EC under the esafety frum. It was c-chaired by ERTICO-ITS Eurpe and ACEA and finalised its wrk in Members f the wrking grup represented all sectrs invlved in the implementatin f ecall May

12 The ITS Advisry Grup 8 is a grup f experts n Intelligent Transprt Systems (ITS) set up by the EC t advise n business and technical aspects f deplyment and use f ITS, including ecall. The grup was frmed in 2012 and cnsists f 25 members, including service prviders, manufacturing industry, transprt peratrs. 2.2 Overview f relevant surces The supprting dcuments identified and reviewed thrughut this study are listed in Table A-1 (see Appendix A, page 127). The table prvides a cncise verview f the dcuments cnsidered relevant fr type-apprval legislatin n ecall IVSs. The relevant cntent f each dcument is listed with regard t ptential type-apprval requirements and ptential test prcedures. Furthermre, cmments n the status f the dcuments and their relevance are given. The table is intended t give a brief summary f all dcuments referenced in the main bdy f the reprt and t infrm the reader n the wider cntext f dcuments if needed while reading the reprt. 8 m May

13 3 Future requirements and test methds fr ecall invehicle system (IVS) Based n a technical assessment f the material available and discussins with technical experts in the area f ecall and stakehlders frm varius grups, many distinct aspects f ecall were identified that needed t be cnsidered fr type-apprval regulatin: 1. Scpe 2. Privacy and liability aspects 3. Cnfrmance t relevant technical standards 4. ecall triggering and test calls 5. Resistance t mechanical impact during nrmal use 6. Resistance t mechanical impact during accident (crash) 7. Climate resistance (temperature, temperature change, freign bdy ingress, water-tightness, cndensed water) 8. Autnmus pwer supply 9. Electrmagnetic cmpatibility (EMC) 10. Resistance t electric impacts 11. Wireless link perfrmance f glbal navigatin satellite system (GNSS) mdule and mbile netwrk device (MND) 12. Installatin and cnnectin 13. Audi equipment 14. In-vehicle system (IVS) self-test 15. Human-machine interface (HMI) 16. Test equipment 17. Definitins f terms 18. C-existence f third party and mandatry ecall systems 19. Nmadic ecall devices 20. Additinal aspects The fllwing technical sectins will discuss the relevant aspects f each f these items in detail. This includes a brief explanatin why requirements might be cnsidered; an verview f ptins fr requirements and testing existing in current legislatin, prpsals and technical standards; cmmentary and discussin f the mst relevant ptins; and a recmmendatin hw t prceed n each f the items. May

14 3.1 Scpe f the regulatin The scpe defines which vehicle categries the type-apprval regulatin applies t and whether separate ecall systems intended t be fitted in such vehicles are als cvered. The scpe f a regulatin is a fundamental requirement f its implementatin. The requirements within the regulatin are nt necessarily unifrm fr all vehicles in scpe Optins Different ptins have been prpsed as ways f defining the scpe fr a regulatin cncerning type-apprval requirements fr the deplyment f ecall IVS within the EU. During the curse f the legislative prcess, the Eurpean Cmmissin (EC), the Eurpean Parliament and the Cuncil f the Eurpean Unin (i.e. the member states) have adpted and published their psitins. The Cmmissin s initial prpsal included all M1 and N1 vehicles in scpe; the Parliaments reslutin added an exemptin fr small series vehicles; the Cuncil s general apprach included separate technical units and cmpnents within the scpe, but added exemptins fr individual apprval vehicles and vehicles which fr technical reasns cannt be equipped with an apprpriate ecall triggering mechanism: Cmmissin prpsal fr a regulatin f the Eurpean Parliament and f the Cuncil cncerning type-apprval requirements fr the deplyment f the ecall in-vehicle system and amending Directive 2007/46/EC, 2013/0165(COD), 316 final, dated 13/06/2013: Recital 7: The mandatry equipping f vehicles with the ecall in-vehicle system shuld initially apply nly t new passenger cars and light cmmercial vehicles (categries M1 and N1) fr which an apprpriate triggering mechanism already exists. In TRL s view, apprpriate triggering mechanism in this cntext culd be understd as either an accident detectin system fr triggering an autmatic ecall r a buttn fr triggering a manual ecall. If this is meant t refer t autmatic ecalls, it is assumed that this means a system able t detect a crash f severity sufficient t suggest ecall culd be f benefit. The practical manifestatin f this assumptin is, perhaps, thrugh the airbag mdules; where any vehicle fitted with an airbag will have a crash detectin system already installed and ptentially available fr triggering f an ecall. This might, in practice refer t all M1 and N1 vehicles in which an airbag is installed. Hwever, a frmal definitin wuld be required t fully define what is meant by a crash detectin system and/r a crash detectin sensrs. Recital 11: Small series vehicles and vehicles apprved pursuant t Article 24 f Directive 2007/46/EC are excluded under Directive 2007/46/EC frm the requirements n the prtectin f ccupants in the case f frntal impact and side impact. Therefre, thse vehicles shuld May

15 be excluded frm the bligatin t cmply with the ecall requirements. Mrever, sme M1 and N1 vehicles cannt be equipped with an apprpriate ecall triggering mechanism. Article 2: This Regulatin shall apply t vehicles f categries M1 and N1 as defined in pints and f Annex II t Directive 2007/46/EC. Eurpean Parliament legislative reslutin f 26 February 2014 n the prpsal fr a regulatin f the Eurpean Parliament and f the Cuncil cncerning typeapprval requirements fr the deplyment f the ecall in-vehicle system and amending Directive 2007/46/EC, P7_TA(2014)0154, dated 26/02/2014: Recital 7: The mandatry equipping f vehicles with the 112-based ecall in-vehicle system shuld initially apply nly t new types f passenger cars and light cmmercial vehicles (categries M1 and N1) fr which an apprpriate triggering mechanism already exists. The pssibility f extending the applicatin f the 112-based ecall in-vehicle system requirement in the near future t include ther vehicle categries, such as heavy gds vehicles (HGVs), buses and caches, pwered tw-wheelers (PTW) and agricultural tractrs, shuld be further assessed by the Cmmissin with a view t presenting, if apprpriate, a legislative prpsal. It shuld be nted that t date, few HGVs, buses, caches, and pwered tw-wheelers will be equipped with an airbag system. Hwever, it is nt knwn whether sme f them have accident detectin systems. Befre autmatic triggering ecall systems are required fr these vehicles, it shuld be demnstrated that the apprpriate system cmpnents can be installed at a reasnable cst. It is a general expectatin that ecall wuld be f benefit fr these vehicles as well as fr passenger cars and light cmmercial vehicles. Recital 7a (new): The equipping f vehicles f existing types t be manufactured after 1 Octber 2015 with the 112-based ecall in-vehicle system shuld be prmted in rder t increase penetratin. In respect f types f vehicles type-apprved befre 1 Octber 2015, an ecall system may be retrfitted n a vluntary basis. Recital 11: Small series vehicles are excluded under Directive 2007/46/EC frm the requirements n the prtectin f ccupants in the case f frntal impact and side impact. Therefre, thse small series vehicles shuld be excluded frm the bligatin t cmply with the ecall requirements set ut in this Regulatin. Article 2: This Regulatin shall apply t vehicles f categries M1 and N1 as defined in pints and f Annex II t Directive 2007/46/EC. This Regulatin shall nt apply t small series vehicles. May

16 General Apprach f the Cuncil with regard t the Prpsal fr a Regulatin f the Eurpean Parliament and f the Cuncil cncerning type-apprval requirements fr the deplyment f the ecall in-vehicle system and amending Directive 2007/46/EC, 9879/14 ENT 123 MI 428 CODEC 1299, dated 19/05/2014: Recital 7: The mandatry equipping f vehicles with the ecall in-vehicle system shuld initially apply nly t new types f passenger cars and light cmmercial vehicles (categries M1 and N1) fr which an apprpriate triggering mechanism already exists. Recital 11: Small series vehicles and vehicles apprved pursuant t Article 24 f Directive 2007/46/EC are excluded under Directive 2007/46/EC frm the requirements n the prtectin f ccupants in the case f frntal impact and side impact. Therefre, thse vehicles shuld be excluded frm the bligatin t cmply with the ecall requirements. Mrever, sme M1 and N1 vehicles cannt be equipped with an apprpriate ecall triggering mechanism. Article 2: 1. This Regulatin shall apply t vehicles f categries M1 and N1 as defined in pints and f Part A f Annex II t Directive 2007/46/EC and t ecall in-vehicle systems, cmpnents and separate technical units designed and cnstructed fr such vehicles. It shall nt apply t the fllwing vehicles: (a) vehicles prduced in small series apprved pursuant t Articles 22 and 23 f Directive 2007/46/EC; (b) vehicles apprved pursuant t Article 24 f Directive 2007/46/EC; (c) vehicles which cannt fr technical reasns be equipped with an apprpriate ecall triggering mechanism, as determined in accrdance with paragraph The Cmmissin shall be empwered t adpt delegated acts in accrdance with Article 9 t identify vehicles r classes f vehicles f categries M1 and N1 which fr technical reasns cannt be equipped with an apprpriate ecall triggering mechanism, n the basis f a cst/benefit analysis carried ut r mandated by the Cmmissin and taking int accunt all relevant safety and technical aspects. ( ) Fr the future UN Regulatin N. XX n AECD/AECS, the scpe is nt yet decided. The fllwing ptins are being discussed: Latest Draft UN Regulatin N. XX n AECD/ AECS, Part I, dcument number: AECS 03-04e, dated 26/02/2014 This Regulatin applies t: Part I: the AECDs which are intended t be fitted t vehicles f categries M1 and N1; May

17 Part II: the installatin n vehicles f categries M1 and N1 f AECDs which have been apprved t Part I f this regulatin. Part III: vehicles f categries M1 nt exceeding 2,5 tns, and N1 where the "R" pint f the lwest seat is nt mre than 700 mm frm grund level, with regard t AECS r equipped with an AECD which has nt been separately apprved accrding t Part I f this Regulatin. Other vehicles may be apprved at the request f the vehicle manufacturer. Discussins at the 4 th AECS meeting in April 2014 indicated that the scpe is still disputed: it might either be defined as a wide scpe, i.e. all M1 and N1 vehicles (pssibly except small series); r M1 and N1 vehicles which are fitted with accident detectin systems; r M1 and N1 vehicles which underg UN R94 and/r UN R95 full-scale crash testing. Separate technical units will als be cvered in the Regulatin. The fllwing vehicles wuld be cvered, if the scpe was linked t full-scale crash testing: Define scpe as M1/N1 underging bth UN R94 and UN R95 crash tests : Wuld capture nly M1 vehicles 2,500 kg Define scpe as M1 underging ne r bth f UN R94 and UN R95 crash tests : Wuld capture M1 vehicles 2,500 kg, and all M1 and N1 vehicles with R pint height f lwest seat 700 mm Cmmentary The scpe f the future Eurpean Regulatin has been cmmented n by Cmmissin, Parliament and Cuncil and will be defined s as t cver M1 and N1 vehicles with certain vehicles being exempt (small series, individual apprvals and vehicles which cannt be equipped). In TRL s view it is sensible t exempt individual and small series vehicle apprvals if they cannt meet the requirements fr destructive testing and assurance f ecall system perfrmance (i.e. if they dn t have t underg UN R94 r UN R95). Als, small series vehicle cnverters may have disprprtinate csts if they had t add ecall systems t campervan cnversins, etc. Anther example might be special purpse vehicles like emergency service vehicles it culd be unnecessary t make an ecall if ne is invlved in an accident given that the PSAP is prbably in direct cntact with the vehicle already and they might be tracked via a dedicated mnitring service anyway. At the UN level, prpsals have been made either t include all M1 and N1 vehicles, r t limit the scpe f the regulatin t thse vehicles f categries M1 and N1 which als belng t the scpe f UN Regulatins N. 94 and/r 95. The imprtance f this link with full-scale crash tests is discussed in detail in Sectin 3.4 in cnjunctin with autmatic ecall triggering, because it is imprtant even in the Eurpean cntext with regard t available assessment techniques. In summary, whilst UN R94 and UN R95 can prvide a useful testing envirnment fr checking autmatic ecall triggering and pst-crash perfrmance, linking the scpe f an ecall regulatin t the scpe f these May

18 UN regulatins wuld mean that it will n lnger apply t all M1 and N1 vehicles. This wuld severely limit the ptential safety benefits f ecall Recmmendatin Based n the General Apprach f the Cuncil, currently all large series M1 and N1 vehicles (and ecall systems and cmpnents intended t be fitted in such vehicles) shuld be included in the scpe f the regulatin as lng as they can be equipped with an apprpriate triggering mechanism. The vehicles which cannt be equipped will need t be clearly identified in the future, which is already cvered in the General Apprach by empwering the EC t carry ut analyses and adpt delegated acts in this regard. General Apprach f the Cuncil, 9879/14 ENT 123 MI 428 CODEC 1299, dated 19/05/2014, Article 2: 1. This Regulatin shall apply t vehicles f categries M1 and N1 as defined in pints and f Part A f Annex II t Directive 2007/46/EC and t ecall in-vehicle systems, cmpnents and separate technical units designed and cnstructed fr such vehicles. It shall nt apply t the fllwing vehicles: (a) vehicles prduced in small series apprved pursuant t Articles 22 and 23 f Directive 2007/46/EC; (b) vehicles apprved pursuant t Article 24 f Directive 2007/46/EC; (c) vehicles which cannt fr technical reasns be equipped with an apprpriate ecall triggering mechanism, as determined in accrdance with paragraph The Cmmissin shall be empwered t adpt delegated acts in accrdance with Article 9 t identify vehicles r classes f vehicles f categries M1 and N1 which fr technical reasns cannt be equipped with an apprpriate ecall triggering mechanism, n the basis f a cst/benefit analysis carried ut r mandated by the Cmmissin and taking int accunt all relevant safety and technical aspects. ( ) May

19 3.2 Privacy and liability aspects Basic expectatins regarding privacy and liability aspects assciated with ecall have been described by several authrs (including CEN, esafety Driving Grup ecall, Eurpean Data Prtectin Supervisr and Article 29 Wrking Party). In additin specific liability questins have been cnsidered in previus research and data privacy aspects have als recently been recnsidered by the Eurpean Data prtectin Supervisr. These surces f infrmatin n privacy and liability aspects have been reviewed and are summarised and, in sme cases, reprduced belw Expectatins Sme cre texts are prvided t set the cntext fr the privacy and liability aspects f ecall. EN ecall shall be cnsidered as a public service perating as part f the public emergency call service, where the first part f service prvisin is a Public Safety Answering Pint (which may be a public r private rganisatin under public delegatin as determined within natin states). All stakehlders invlved shall cmply with all EU and natinal regulatins related t the prtectin f data and the privacy f the citizens in relatin t emergency service supprt. The ecall service shall nly perate frm the pint f service demand (autmatic r manual) triggering f the ecall. ecall shall therefre be a 'sleeping' applicatin and shall nt be used t mnitr the mvement f vehicles ther than at the pint f ecall message triggering as defined in EN Fr detail f netwrk registratin, see ETSI TS NOTE Article 29 Wrking Party n the prtectin f the individuals with regards t the prcessing f persnal data have prvided an interpretatin f these requirements, and the attentin f implementers is directed t these interpretatins. See en.pdf. Recmmendatins f the esafety Driving Grup ecall (DG ecall) fr the intrductin f the pan-eurpean ecall, Versin 2.0 In rder t prtect the privacy f the citizens DG ecall recmmends that ecall is cnsidered as a public service build n tp f the pan-eurpean single emergency call number 112, which means that the data cntrller will be a Public Safety Answering Pint (PSAP), r a private rganizatin appinted by the public authrities t perfrm that rle. DG ecall als recmmends that all stakehlders invlved will be bliged t cmply May

20 with all directives related t the prtectin f data and the privacy f the citizens in relatin t 112. The different Directives related t the single Eurpean emergency number 112 and data prtectin can be fund in the Directive n data prtectin 95/46/EC. The DG ecall recmmends that the MSD includes nly the minimum required infrmatin needed by the emergency services t ensure an adequate respnse. The DG ecall recmmends that the citizen will be infrmed abut the existence f the ecall service at the mment f buying/hiring a vehicle. This must include infrmatin abut the data that wuld be transferred t the PSAP in the event f a call, and explain that the cntract will include the explicit acceptance f the citizen f the ecall service. The citizen shuld have the pssibility t ask fr a discnnectin f the service at the mment f purchase and in this scenari, it must be pssible fr the vehicle wner t ask fr a re-cnnectin f the service at a later stage. DG ecall recmmends that when implementing ecall it is ensured that it will nt be pssible t track the vehicle at all times. It is recmmended t make ecall a sleeping applicatin n the ecall generatr that nly cmes t life when the ecall generatr detect an incident serius enugh fr triggering an autmatic ecall r the vehicle ccupants generate a manual ecall. The pinin f the Eurpean Data Prtectin Supervisr (EDPS) f 29 Octber 2013 Taking int accunt: the functining f the Eurpean Unin, the fundamental rights f its members, the prcessing f persnal data and the prtectin f individuals with regard t the prcessing f persnal data; the EDPS prvided pinin n the Eurpean Cmmissin prpsal fr an ecall regulatin. This pinin is described in the dcument f 29 Octber It prvides general analysis f the Cmmissin prpsal, sme specific cmments and cnclusins. Extensive reference is made t this dcument in the Privacy and data prtectin Sectin (3.2.3) belw. Article 29 Wrking Party - Wrking dcument n data prtectin and privacy implicatins in ecall initiative In summary: If the ecall is ptinal, a user-friendly slutin taking care f self-determinatin f car users by intrducing the technical pssibility t switch ff/n ecall n a case-t-case basis must be intrduced, fr instance by means f electrnic switches, smart cards r ther devices allwing the vluntary activatin f the ecall device and als, if desired, enabling the cmmunicatin f data beynd the MSD. If the ecall is May

21 mandatry, rules have t be embdied in a dedicated law, taking int accunt data prtectin principles. In case the mandatry ptin is implemented, a system f prper data prtectin safeguards has t be intrduced. While using ecall, a Minimum Set f Data (MSD) t handle the emergency will be circulated. The Article 29 Wrking Party cnsiders that MSD including the cmplete VIN number as currently indicated culd be excessive in relatin t the clearly defined purpse. Frm a data prtectin pint f view, an emergency call released autmatically by a device r triggered manually and transmitted via mbile netwrks resulting in ge-lcalizatin f the emergency event is in principle admissible, prvided that there exists a respective specific legal basis and sufficient data prtectin safeguards are prvided. Hwever, the purpses f the emergency call system and the relevance f the data t be prcessed must always be taken int accunt, in particular if the prcessing invlves the s-called Full Set f Data. Eurpean Parliament legislative reslutin f 26 February 2014 n the prpsal fr a regulatin f the Eurpean Parliament and f the Cuncil cncerning typeapprval requirements fr the deplyment f the ecall in-vehicle system and amending Directive 2007/46/EC, P7_TA(2014)0154, dated 26/02/2014: Recital 7c new: Cnsumers shuld be prvided with a realistic verview f the 112-based ecall in-vehicle system and f the private ecall system, if the vehicle is equipped with ne, as well as cmprehensive and reliable infrmatin regarding any additinal functinalities r services linked t the private emergency service, in-vehicle emergency r assistance-call applicatins n ffer, and regarding the level f service t be expected with the purchase f third party services and the assciated cst. The 112-based ecall is a public service f general interest and shuld therefre be accessible free f charge t all cnsumers. Recital 8: The mandatry equipping f vehicles with the 112-based ecall in-vehicle system shuld be withut prejudice t the right f all stakehlders such as car manufacturers and independent peratrs t ffer additinal emergency and/r added value services, in parallel with r building n the 112-based ecall in-vehicle system. Hwever, any additinal services shuld be designed nt t increase driver distractin r affect the functining f the 112-based ecall in-vehicle system and the efficient wrk f emergency call centres. The 112-based ecall in-vehicle system and the system prviding private r added-value services shuld be designed in such a way that n exchange f persnal data between them is pssible. Where prvided, thse services shuld May

22 cmply with the applicable safety, security and data prtectin legislatin and shuld always remain ptinal fr cnsumers. Recital 13: Directive 95/46/EC f the Eurpean Parliament and f the Cuncil 1, Directive 2002/58/EC f the Eurpean Parliament and f the Cuncil 2 and Articles 7 and 8 f the Charter f Fundamental Rights f the Eurpean Unin 3 gvern the prcessing f persnal data carried ut in the cntext f this Regulatin. Any prcessing f data thrugh the 112-based ecall in-vehicle system shuld therefre be carried ut in accrdance with these Directives and under the supervisin f the Member States' cmpetent authrities, in particular the independent public authrities designated by the Member States pursuant t thse Directives, in particular t guarantee that vehicles equipped with 112-based ecall in-vehicle systems, in their nrmal peratinal status related t 112 ecall, are nt traceable and are nt subject t any cnstant tracking and that the minimum set f data sent by the in-vehicle ecall system includes nly the minimum infrmatin required fr the handling f emergency calls by PSAPs, and that n persnal data is stred after that. Given the cnsent f the data subject r a cntract between bth parties, ther cnditins may apply in case anther emergency call system is installed in the vehicle in additin t the 112-based ecall in-vehicle system, but it shuld nevertheless cmply with thse Directives. 1. Directive 95/46/EC f the Eurpean Parliament and f the Cuncil f 24 Octber 1995 n the prtectin f individuals with regard t the prcessing f persnal data and n the free mvement f such data (OJ L 281, , p. 31). 2. Directive 2002/58/EC f the Eurpean Parliament and f the Cuncil f 12 July 2002 cncerning the prcessing f persnal data and the prtectin f privacy in the electrnic cmmunicatins sectr (Directive n privacy and electrnic cmmunicatins) (OJ L 201, , p. 37) a OJ C 303, , p Liability One f the key riginal cncerns regarding ecall was wh wuld be liable if an ecall was unsuccessful. This issue was reviewed by Francsics et al. (2009). Infrmatin frm that reprt is summarised here: Due t its technical and rganisatinal cmplexity we can envisage several pssible causes fr an unsuccessful r crrupted ecall (i.e. the ecall failed partially r cmpletely), including: May

23 1. incidental flaws in hardware and sftware cmpnents in the in-vehicle equipment 2. the threshld fr triggering the autmatic ecall was nt met 3. the in-vehicle equipment is damaged in a crash befre an autmatic ecall was triggered 4. in-vehicle equipment was nt adequately installed r maintained 5. service prvider r PSAP ecall equipment nt adequately installed r maintained 6. lack f telecm service (due t lack f netwrk cverage r ther circumstances) 7. human errrs smewhere in the service delivery chain Depending n the reasn(s) fr the unsuccessfulness f the autmatic ecall, liability claims may be directed twards ne r mre f the actrs in the prductin and service delivery chain, including: 1. dealer/system supplier 2. car/system manufacturer 3. private service prvider 4. mbile netwrk peratr 5. PSAP (public safety answering pint) It shuld be nted that this is a smewhat abstract and nn-exhaustive typlgy f stakehlders. It may well be that in reality ne stakehlder embdies mre than ne f the abve mentined stakehlder categries. Furthermre, it is als pssible that, depending n the circumstances, ther parties may be cnfrnted with claims (e.g. installers, car rental cmpanies, certificatin bdies, autmbile servicers, fixed netwrk prvider, etc.). There may be a variety f liability relatinships between the different actrs. Liability under the Prduct Liability Directive Initially, prduct liability was gverned entirely by natinal laws. In 1985 hwever, a Eurpean Cuncil Directive n liability fr defective prducts was intrduced (Cuncil Directive 85/374/EEC, OJ 1985 L. 210/29). The gal f this Directive was t harmnize prduct liability rules in Eurpe. The mst imprtant element f the Eurpean Directive is the ntin f a defective prduct. Accrding t the Directive the prducer shall be liable fr damage caused by a defect in his prduct (Article 1). Article 6 (1) f the Directive prvides a definitin f a defective prduct: A prduct is defective when it des nt prvide the safety a persn is entitled t expect, taking all circumstances int accunt including: May

24 1. The presentatin f the prduct; 2. The use the prduct culd reasnably be put t; 3. The time when the prduct was put int circulatin. Frm the wrding f Article 6 it can be cncluded that the EC Directive defines "defect" in terms f cnsumer expectatins. Furthermre, the definitin f a defective prduct makes clear that curts are allwed t take a brad range f circumstances int accunt when deciding prduct liability questins and therefre there are n clear and unambiguus answers when it cmes t assessing prduct liability implicatins f ecall equipment. A key questin in relatin t ecall is whether an unsuccessful r crrupted ecall can render the system defective in terms f the Directive. T answer this questin it is useful t distinguish between manufacturing defects and defects that can be cnsidered t be inherent system limitatins. It seems reasnable that expectatins f the cnsumer regarding the inherent system limitatins culd be managed t sme extent via the prvisin f infrmatin regarding the service. Manufacturing Defects A manufacturing defect exists when a prduct (an ecall system r cmpnent) des nt meet the manufacturer s wn prduct specificatins. In ther wrds, the prduct deviates frm the prduct-line-standard. Fr example, it culd happen that sme badly prduced sensrs r electrnics have been used in ne r mre ecall-devices. In such cases it can be argued that the ecall system is defective in the sense f the Directive because the system des nt meet the manufacturer s wn prduct standards. Hwever, even if it was t be cncluded that an unsuccessful ecall was caused by a manufacturing defect, this des nt necessarily mean that the manufacturer culd be held liable twards vehicle ccupants. Fr the manufacturer s liability t be established it must als be shwn that the unsuccessful ecall cntributed t the damage (aggravating the injuries r causing death due t lnger rescue time). In ther wrds the claimant in principle has t prve the damage and the causal link between the defect and the damage. This means that the claimant in principle has t prve that, and t what extent, his injuries were aggravated due t the unsuccessful ecall. In many cases this questin cannt be answered easily and will require the help f medical experts. Clsely related t the cncept f causatin are theries f cntributry negligence (claimant s wn negligent cnduct leads t a decrease f the damages t be paid by the trtfeasr) and cntributry risks (ther causes fr which the claimant has t answer can reduce the amunt f the awarded damages). Fr example, if a driver caused the accident by reckless driving, he may nt claim full cmpensatin r any cmpensatin at all. In practice, questins f cntributry negligence are f majr imprtance. May

25 An unsuccessful (r crrupted) ecall may als be the result f inherent limitatins f the ecall system. The ecall may be unsuccessful as a result f specific accident situatins (e.g. threshld fr triggering the autmatic ecall nt met, vehicle under water), inadequate cverage f mbile phne netwrk, ecall equipment damaged in the crash, etc. It will be clear that manufacturers in principle cannt be held liable fr services independently delivered thrugh the in-vehicle equipment. It is nly fr defects in the in-vehicle equipment fr which the manufacturer is respnsible under the Directive. Liability fr false alarms The situatin f false alarms differs frm unsuccessful r crrupted ecall in terms f cnsequences (unnecessary dispatch f emergency services) and ptential claimants (gvernment entities respnsible fr emergency services).it shuld be nted that nrmal PSAP peratin already includes a high number f false alarms. An end user may be held liable in trt fr intentinally misusing an emergency number and as such an ecall system. Hwever, in ther cases recvery f csts will be prblematic because prviding emergency services is a typical public task and seeking recvery f csts thrugh a civil law claim may be regarded inadmissible. This is because it cnflicts with public law and because f the ptential hurdle it wuld create fr peple t call the emergency services. Summary All actrs in the prductin and service delivery chain are expsed t ptential liability fr negligence (breach f a duty f care) r attributable nn-perfrmance. Sme actrs are expsed t liability risks based n (mre) strict liability standards (fr example manufacturers in relatin t s called manufacturing defects) r are mre likely t be cnfrnted with ptential claims (e.g. service prviders because f their direct relatinship with the end user) Privacy and data prtectin When the Eurpean Cmmissin put frward the prpsal fr a regulatin n ecall, the Eurpean Data Prtectin Supervisr was asked t cmment n that prpsal and subsequently prepared the dcument cntaining his pinin (f 29 Octber 2013). Sme f the pinins cntained in that dcument are repeated here. ecall is a sleeper functin which has n live tracking ptential. In principle, it is nt pssible t identify the cars psitin at any time via the in-vehicle ecall device. Hwever, nce a call has been made, the AECD has presented the pprtunity fr the vehicle t be identified (as the VIN is transmitted). Fr privately wned cars, the vehicle identificatin is directly related t the identity f the wner f the car wh may be the driver. Fr ther cars, e.g. rental cars, infrmatin btained frm the wner will lead t the identificatin f the driver. Cmbined with these persnal details, the psitining infrmatin (lcatin data f the vehicle), and ther infrmatin prcessed, May

26 is related t a directly r indirectly identifiable individual and therefre qualifies as persnal data. Therefre, the PSAP is presented with persnal infrmatin which requires data prtectin. This means that in the technical and rganisatinal set up f ecall services the principles laid dwn in the relevant Eurpean Directives and natinal data prtectin laws have t be applied. Prcessing f persnal data is ne f the cre bligatins created by the Prpsal which is therefre subject t the applicatin f and cmpliance with data prtectin legislatin and safeguards. In this regard, the Eurpean Data Prtectin Supervisr (EDPS) prvided a reminder that it is essential t explicitly mentin the applicable EU data prtectin law in a substantive prvisin f the Prpsal: a mere indirect reference in a recital cannt be cnsidered as sufficient. The reference shuld explicitly prvide, as a general rule, that Directive 95/46/EC and its natinal implementing rules apply t the prcessing f persnal data within the framewrk f the Prpsal. Other cmments prvided by the EDPS were: Article 6 wuld require vehicle manufacturers i. t ensure that vehicles equipped with the system are nt traceable and are nt subject t any cnstant tracking in their nrmal peratinal status related t the ecall, ii. iii. iv. t make use f privacy enhancing technlgies (hereinafter 'PETs') as well as t adpt safeguards t prevent surveillance and misuse f the data, t make sure that the in-vehicle system nly prcesses the minimum set f data, and t infrm ecall users abut the prcessing f data and in particular: its legal basis, its activatin by default, the mdalities f data prcessing, the purpse pursued, the types f data cllected and prcessed and the recipients, the time limit fr the retentin f data, the fact that there is n cnstant tracking, the mdalities fr exercising data subject's rights and any necessary additinal infrmatin. May

27 The EDPS recmmends the intrductin f an additinal paragraph t Article 6 f the Prpsal which cntains these additinal essential safeguards, and in particular: i. Designates the data cntrller and the entity respnsible fr handling access requests. Specifies the list f data referred t as a minimum set f data and as a full set f data (pssibly t be elabrated in a delegated r implementing act). Includes the pssibility fr data subjects t deactivate private ecall and added value services. Specifies retentin perids fr the data prcessed. Specifies the mdalities f the exercise f data subjects rights, The EDPS highly welcmes that Article 6(3) requires manufacturers t prvide individuals purchasing new vehicles with infrmatin abut the embedded 112 ecall in-vehicle system and the resulting prcessing f data, and specifies in the Regulatin itself the details f what such infrmatin shuld cver, i.e. the fact that the system is activated by default, and the mdalities f the data prcessing that is perfrmed as required under Articles 10 and 11 f Directive 95/46/EC (such as the purpse f the 112 ecall prcessing, the reference t the legal basis fr the prcessing, the types f data cllected and prcessed, the recipients f the data, the fact that there is n cnstant tracking f the vehicle, the time limit fr the retentin f data in the in-vehicle system and the mdalities fr exercising data subjects' rights). The EDPS therefre recmmends that the requirement fr an apprpriate and distinct cntract between the cnsumer and the service prvider is stated in a specific prvisin f the prpsed Regulatin. He als recmmends clarifying in the prvisin that this cntract shuld cver data prtectin aspects, including prviding apprpriate infrmatin t cnsumers n the service(s) and cllecting their cnsent fr the prcessing f data in relatin t the prvisin f these added value services. This culd, if needed, be elabrated in the delegated acts that the Cmmissin will adpt. This cntract will have t prvide the fllwing additinal infrmatin: Clear and transparent infrmatin f end-users n the mandatry prcessing f lcatin data, including a clear descriptin f the data prcessed and the cnditins f prcessing. The absence f any cnstant ge-lcatin unless the user has been made aware f it and is in a psitin t give prir free and infrmed cnsent. The EDPS als recmmends that the prpsal ensures that data subjects are given the chice t pt fr the services, thrugh a specific cntract ffer, made prir t the prcessing. Nn-negtiable clauses part f a car sale cntract, r clauses belnging t May

28 general terms and cnditins, whse acceptance is mandatry, will nt fit this requirement. Under Directive 95/46/EC, data exchanged shuld nly be kept fr the time necessary t achieve the purpses fr which they were cllected and shuld be autmatically deleted fllwing the expiry f the retentin perid. The EDPS ntes that the retentin perid f the data prcessed fr 112 ecall purpse is nt specified even thugh this infrmatin is included in the ntice that shuld be given t data subjects by car manufacturers. In any event, the data shall nt be retained lnger than necessary fr adequate transmissin t the apprpriate PSAP and the MSD shuld be deleted afterwards. These strage perids shall be adapted and harmnised depending n the parties and lcatin f the data (in-car strage, PSAP databases strage). If the data were t be necessary after the expiratin f the required perid f strage, in particular fr statistical purpses, they shuld be annymised, i.e. there shuld be n way t identify directly r indirectly a persn based n these data. The EDPS advises specifying these safeguards with regard t retentin. May

29 3.3 Cnfrmance t relevant technical standards Reasns fr requirements Different actrs are invlved in the ecall chain (vehicle/ivs, MNO, PSAP, TPSP) and pan-eurpean ecall is intended t wrk acrss the EU. In rder t allw transfer f an emergency message and the establishment f a vice channel between IVS and PSAP via a mbile netwrk, cmmn prtcls and standards are required. T ensure interperability, test prcedures are necessary t assess cnfrmance withut having influence ver the ther actrs invlved. Als, the cntent and frmat f data t be transmitted frm the vehicle t the PSAP (the MSD) has t be defined t ensure interperability Optins As mentined in Sectin 2, Wrking Grup 15 f the CEN TC274 has written a set f standards regarding ecall. Cmpliance with these standards is required in the General Apprach f the Cuncil, dated 19/05/2014, Article 5.7: EN ecall high level applicatin requirements (HLAP) defines the high level applicatin prtcls t facilitate ecalls using mbile netwrks. Requirements fr the IVS include: Prcedures fllwing pwer-up, activatin f ecall, MSD transfer, handling f errr cases, and timings (Sectin 7, Annex 7). The standard als defines crrespnding test and cnfrmance requirements (Sectin 11.2). EN Pan-Eurpean ecall perating requirements specifies the generic peratinal requirements and intrinsic prcedures fr the prvisin f an ecall service that allws t transfer an emergency message and t establish a vice channel between IVS and PSAP. With regard t the IVS this includes high level functinal requirements, such as the presence f a NAD (Netwrk Access Device), capability f autmatic and manual ecall and rbustness t survive a crash (Sectin 6). Operatinal requirements, als cncerning the IVS, are set ut in Sectin 7 f the standard. Please nte: This standard includes the requirement t transmit an autmatic ecall in all crash tests which are required by regulatin fr the Eurpean type-apprval (Sectin 7.5, dcument versin 18/08/2011). It has t be carefully checked that this des nt cnflict with ther triggering requirements (Sectin 3.4). EN ecall - Operating requirements fr third party supprt cvers the same scpe fr but fr third party services in rder t allw service prviders t ffer services handling ecalls. Please nte that TPS ecall is nt in scpe f the current prject. EN ecall minimum set f data (MSD) specifies the cntent and frmat f the data t be transferred by the IVS t the PSAP during an ecall. This May

30 includes data presentatin, encding and transmissin. Brief requirements fr cnfrmance testing are set ut. CEN/TS ecall end t end cnfrmance testing sets ut test prcedures that allw different actrs in the ecall chain (vehicle/ivs, MNO, PSAP, TPSP) t claim cnfrmance t all abve listed EN ecall standards withut being able t cntrl the behaviur f ther actrs. The standard specifies a set f state transitin pints fr which cnfrmance requirements are defined and tests are arranged int. With regard t the IVS, 47 test bjectives and related tests are defined t demnstrate that it is capable f triggering an ecall, sending the MSD, and making a vice channel available (Sectins 2, 9.1 t 9.6, Annex A). Please nte that this dcument is currently has the status f a published Technical Specificatin (TS). A Technical Specificatin is established by a CEN Technical Bdy and apprved thrugh a vte by the CEN natinal members. It may be adpted as a natinal standard, but cnflicting natinal standards may cntinue t exist. A Technical Specificatin may hwever nt cnflict with a Eurpean Standard. If a cnflicting EN is subsequently published, the TS is withdrawn. Varius standards frm the Eurpean Telecmmunicatins Standards Institute (ETSI) exist fr mbile phne equipment t be interperable. The fllwing ETSI standards have been referenced in the varius ecall related dcuments: ETSI TS (Versin 1.3.1) ETSI TS (Release 8 r later) ETSI TS (Release 8 r later) ETSI TS (Release 8 r later) ETSI TS (Release 8 r later) ETSI TS (Release 8) ETSI TS (Release 8 r later) ETSI TS (Release 8 r later) ETSI TS (Release 8 r later) ETSI TS (Release 8 r later) ETSI TS (Release 8 r later) ETSI TS (Release 8 r later) ETSI TS (Release 8 r later) ETSI EN ETSI EN May

31 3.3.3 Cmmentary The EN ecall standards EN 16062, EN and EN prvide an agreed framewrk f high level and perating requirements specifically fr Eurpean cnditins. The standards are highly develped and were created by experts in the relevant fields. In rder t make these standards mandatry, cmpliance wuld need t be required in ecall type-apprval legislatin. As there is an nging review prcess fr these dcuments, the latest versin available at the time f legislating will need t be checked and referenced. CEN/TS defines an advanced prcedure fr demnstrating cnfrmance t the requirements defined in the EN ecall standard framewrk and culd be used fr typeapprval testing. This cnfrmance testing requires specialised test equipment (see Sectin 3.16) and is expected t be carried ut by the ecall system manufacturer (r n their behalf) in rder t prvide the vehicle manufacturer with a certificate f cmpliance t ecall standards fr the system t be integrated int the vehicle. EN defines a widely accepted and technically sund frmat and cntent f the MSD transmitted t the PSAP. This frmat is als used in the Russian standard GOST R and discussins n UN level indicate that it will be adpted, reginal discrepancies ntwithstanding, in the future UN Regulatin. The MSD as defined in EN includes, hwever, certain elements which are plitically disputed due t ptential privacy and data prtectin issues (see als Sectin 3.2): The VIN, which is intended t enable PSAPs t btain detailed infrmatin frm a database n vehicle make, mdel, clur, etc. in rder t facilitate identificatin f the vehicle. Tw recent vehicle lcatins, intended t enable PSAPs t determine the directin f travel. This might be relevant fr example n large carriageways with separate lanes. The Cmmissin prpsal fr a regulatin f the Eurpean parliament and f the cuncil cncerning type-apprval requirements fr ecall, dated 13/06/2013, des nt reference EN but nly defines that the MSD shall include nly the minimum infrmatin required fr apprpriate handling f emergency calls. The Eurpean Parliament legislative reslutin, dated 26/02/2014, sets ut in Article 6: The MSD sent by the 112-based ecall in-vehicle system shall as a maximum cnsist f the infrmatin required by the standard referred t in pint 2c f Article 3 [i.e. EN 15722]. The MSD shall nt be prcessed fr lnger than necessary fr the purpse fr which they have been prcessed, and shall nt be stred fr lnger than is required fr the apprpriate handling f emergency calls. The MSD shall be stred in such a way as t make pssible its full deletin. The General Apprach f the Cuncil, dated 19/05/2014, sets ut in Article 6: May

32 The minimum set f data sent by the ecall in-vehicle system shall include nly the minimum infrmatin as referred t in the standard EN 15722:2011 "Intelligent transprt systems - esafety - ecall minimum set f data (MSD)". The persnal data included in the ecall in-vehicle system shall nt be retained lnger than necessary fr their transmissin t the apprpriate PSAP. Data submitted shall nly be used fr the purpse fr which they were submitted. They shall be deleted as sn as they are n lnger necessary fr the purpse fr which they were cllected. Frm a technical pint f view, it is recmmended that the MSD data frmat is required t cmply with EN t ensure interperability. Regarding cntents, further discussin appears necessary t decide n the items mentined abve. In their final reprt in 2006, the esafety Driving Grup ecall recmmended that the MSD shuld include nly the minimum required infrmatin needed by the emergency services t ensure an adequate respnse. A stakehlder survey carried ut by EeIP amng rad peratrs (published in the Deliverable f Task Frce 3 in 2011) indicated the fllwing requirements regarding data transmitted: The system must prvide: Number f persns invlved Number f vehicles invlved Number f autmatic signals and manual signals related t ne event Only verified infrmatin n relevance and severity f the incident Infrmatin n incident type Infrmatin frm Samaritan signals (but the Samaritan signal cunt is sufficient) The system shall prvide: Fuel type f invlved vehicles Infrmatin n the make and type f vehicles invlved Infrmatin n the clur f vehicles invlved Infrmatin cncerning the pssible number f casualties and fatalities (the AIS scale) Infrmatin t what extent the vehicle can still drive Infrmatin n the speed f the vehicle immediately prir t the incident t prvide the rad traffic manager with an extra indicatr f the severity f the incident The Japanese vluntary HELPNET system cntains sme additinal elements cmpared t the Eurpean MSD, fr example (details can be fund in dcument AECS-03-05e): May

33 Psitin inf (reprt site and travel trail, 64 pints at 80 m intervals, i.e. ca. 5 km), based n GPS, gyr, velcity signals, map-matching, etc. Rad type Sensr inf (DeltaV, airbag sensrs, verturn sensr, multiple crash, etc.) Originatr ID (Originatr ID is used t acquire member and vehicle infrmatin (make, mdel, clur, etc.) frm a database. With regard t mbile cmmunicatin standards, it appears necessary fr the MND t be cmpliant in rder t successfully access PLMNs. The ETSI standards listed in Sectin are nt ecall specific and have nt been reviewed in-depth during this prject because they are well-established. Cnfrmance with these standards is, in part, already required by cnfrmance t the EN standards (as these cntain references). ISO n data registry prcedures fr Intelligent transprt systems, fr example, requires in a general way: ( ) wireless cmmunicatin shall be established in full cmpliance with lcal telecmmunicatin regulatins, prcedures and prtcls fr that media using the apprpriate Internatinal r Reginal Standards ( ) UN R116 fr vehicle alarm systems, which might als include transmitting equipment, requires cmpliance with the relevant ETSI standards and lists examples. The wrding used in UN R116, Sectin is: [The system] shall cmply with the relevant ETSI Standards, e.g. EN V ( ), EN V ( ), EN V ( ) and EN V ( ) (including any advisry requirements) Recmmendatins In rder t mandate cmpliance with the relevant EN and ETSI standards, the legislative text n ecall might set ut the fllwing: The ecall in-vehicle system shall cmply with the EN standards EN 16062, EN and EN Cnfrmance shall be demnstrated using the test prcedures prescribed fr IVS in CEN/TS The IVS shall als cmply with the relevant ETSI standards. A list f applicable ETSI standards might be prvided tgether with this statement in the regulatin if deemed necessary. The MSD data frmat is required t cmply with EN t ensure interperability. As discussed abve, the current versin f EN at the time f legislating shuld be checked fr ptentially cnflicting triggering prvisins. May

34 3.4 ecall triggering and test calls Reasns fr requirements It is a basic functinal premise f ecall that in the event f a cllisin the system is able t detect the cllisin and initiate the ecall. This is based n the assumptin that the cllisin is f a severity that is ptentially injurius and that the ccupants f the vehicle may nt able t initiate the call themselves. Thereby there is sme benefit assciated with autmatic triggering f a call t the emergency services. Within the cntext f vehicle type-apprval ne expects certain limitatins as t what can be assessed t guarantee safe perfrmance f vehicle systems. It is ften nt cst-effective r practical t test every cnceivable cnditin f use. In the case f expensive full-scale crash testing, these limitatins can be even mre evident. T reduce the csts assciated with ecall system develpment and type-apprval it is hped that existing crash tests can be used fr the assessment f the autmatic triggering f ecall. Optins fr this are discussed in the Sectin Alngside crash perfrmance f the vehicle, it is anticipated that each manufacturer will design and implement an algrithm fr deciding whether the ecall shuld be triggered. A level f in-huse develpment is therefre assumed. The type-apprval testing merely prvides sme assurance that fr an accepted severity the ecall will be activated. Furthermre the testing als prvides experimental validatin that the system in its cmplete, and truly representative, state will survive such an impact and still be able t ffer the rudimentary functins expected f it. Therefre, the features f the testing that are required include: Being cst effective Being f a severity where injury is pssible, in which case triggering shuld ccur If practicable, being f a severity where n injury is pssible, in which case triggering shuld nt ccur Representing as brad a range f real wrld accident scenaris as pssible Having a feasible means f checking the triggering state Having a feasible means f assessing pst-crash survival f the system and functins Being repeatable and reprducible May

35 3.4.2 Expectatins General Apprach f the Cuncil with regard t the Prpsal fr a Regulatin f the Eurpean Parliament and f the Cuncil cncerning type-apprval requirements fr the deplyment f the ecall in-vehicle system and amending Directive 2007/46/EC, 9879/14 ENT 123 MI 428 CODEC 1299, dated 19/05/2014: Article 5, Pint 2: Manufacturers shall demnstrate that all their new types f vehicle are cnstructed t ensure that in the event f a severe accident, detected by activatin f ne r mre sensrs r prcessrs within the vehicle, which ccurs in the territry f the Unin, an ecall t the single Eurpean emergency number 112 is triggered autmatically. Pint 7 f the intrductry text: The mandatry equipping f vehicles with the ecall in-vehicle system shuld initially apply nly t new passenger cars and light cmmercial vehicles (categries M1 and N1) fr which an apprpriate triggering mechanism already exists. EN 16072, Sectin 7.5 The autmtive manufacturer/equipment supplier shall make best reasnable effrt t enable an audi channel t be established s lng as the relevant equipment has nt been disabled in the crash. The in-vehicle ecall system shall transmit the MSD message, s lng as there is an ETSI prime medium wireless netwrk available t receive the signal, in all crash tests which are required by regulatin fr the Eurpean type-apprval: NOTE At the time f develping this Eurpean Standard, the relevant frntal crash tests are defined in Directive 96/79, amended by Directive 1999/98 (r equivalent ECE R94-01); and lateral crash tests are defined in: Directive 96/27 (r equivalent ECE R95-02). HELPNET System Specificatins - AECS-03-05e: Japan; Autmatic triggering is linked t airbag deplyment GOST R 54620, Sectins 6.1 and 6.2 These sectins require that ecall services shuld ensure the frmatin and transmissin f the MND upn the ccurrence f an accident: Fr vehicles f categry M1 this is expected t be based n autmatic triggering in the event f an accident in which there is a substantial likelihd f threat t life and health f peple in the vehicle at the time f the accident ; Fr vehicles f categries M and N this is expected t be via a manual mde. May

36 Draft UN Regulatin N. XX n AECD/ AECS, Part I: Autmatic triggering shall ccur at least under the cnditins f UN R94 and UN R95 crash tests (perhaps als ther cnditins). Calculatin f the autmatic triggering signal will nt frm part f the UN Regulatin Optins Draft UN Regulatin N. XX n AECD/AECS, Part II, Sectin 15.2 The specificatins apply t vehicles f categry M1, cvered by Regulatins Ns. 94 and (r) 95, and thse f categry N1, cvered by Regulatin N. 95. Russian prpsal fr text: The e-call system shall enable: Autmatic transmissin f infrmatin abut the accident at the time f the accident. The fact that transmissin has ccurred and the infrmatin abut the accident shall be recrded by the technical service: When simulating a frntal cllisin f the vehicle during tests under Regulatin N. 94. If the vehicle is nt cvered by Regulatin N. 94, frntal cllisin shall be simulated during tests under Regulatin N. 12. When simulating a lateral cllisin f the vehicle during tests under Regulatin N. 95. OICA prpsal fr text: Any vehicle fitted with an AECD cmplying with the definitin abve shall meet the perfrmance requirements cntained in paragraphs t The AECD shall demand in-band mdem cmmunicatin at the latest [1 secnd] after receptin f the triggering signal defined in paragraph The triggering signal shall be generated by ne f the fllwing means: Perfrmance r simulatin f a frntal cllisin. In the case f a simulatin, the lgic signal can be generated accrding t a test reprt established during a Regulatin N. 94 frntal cllisin; May

37 Perfrmance r simulatin f a lateral cllisin. In the case f a simulatin, the lgic signal can be generated accrding t a test reprt established during a Regulatin N. 95 lateral cllisin. Draft UN Regulatin N. XX n AECD/AECS, Part III, Sectin Sectin Generatin f the triggering lgic signal The triggering lgic signal shall be generated by at least ne f the fllwing events: Occurrence f a frntal cllisin accrding t Regulatin N. 94 (frntal cllisin); r Occurrence f a lateral cllisin accrding t Regulatin N. 95 (lateral cllisin); r Activatin f the AECS cntrl. Testing the generatin f a triggering lgic signal The manufacturer shall carry ut r simulate the fllwing tests with a vehicle that is representative f the vehicle type t be apprved t demnstrate that the triggering lgic signal is generated: A frntal cllisin accrding t Regulatin N. 94 (frntal cllisin); r A lateral cllisin accrding t Regulatin N. 95 (lateral cllisin); r Activatin f the AECS cntrl. as an alternative t paragraph , the manufacturer may present t the type-apprval authrity a certificate established in accrdance with the mdel set ut in Annex XXX. CLEPA Psitins as a fllw up f AECS-02, AECS-03-12e T have a meaningful system, AECS must be able t sustain certain level f shck. E94 E95 tests cnditins is a pssible reference. GOST R 54620, Sectin Autmtive system call emergency services shuld recgnize the fllwing types f accidents: a frntal cllisin, side impact, rear impact. May

38 6.2.2 Fr the AU, established in the cnfiguratin f standard equipment, the mechanism f determining the mment f the accident is determined by the vehicle manufacturer AC installed in the ptin cnfiguratins, as a criterin f peratin f the system it is recmmended t use the cnditin in which the value f the index is greater than the pssible damage ASI15_TRESHOLD, given in Annex A. NOTE: This limit was nt bvius in Annex A Index f pssible damage ASI 15 is calculated using the fllwing equatins: where: (t 2-t 1) - a recrd interval parameters fr evaluatin index f pssible damage equal t 15 ms - The current value f the index pssible damage - Cmpnents f the acceleratin pint vehicle in place f the sensr acceleratin directin f the main axes vehicle (lngitudinal -x, transverse -y, vertical -z); May

39 - Cmpnents f the acceleratin f the pint vehicle in place f the sensr acceleratin directin f the main axes vehicle averaged ver the interval δ = 50 ms; - The limit values fr the cmpnents f the acceleratin n the main directins f the axes f TS. CEN/TS Tests f the Pst-side-crash perfrmance f autmatic trigger; Pst-frntalcrash perfrmance f autmatic trigger; and Perfrmance f autmatic trigger - different crash types are defined in CEN These are available under CTP , and The cncept fr these tests is t establish that the autmatic trigger is activated as intended by the system manufacturer. Fr the lateral crash the cnditins refer t UN Regulatin 95, the frntal crash refers t Regulatin 94. In bth cases it is suggested that an equivalent pulse can be generated via sled testing. Fr the perfrmance in different crash types it is simply suggested that an invalid trigger, belw the threshld fr activatin, is generated in accrdance with the manufacturer s instructins. It shuld be nted that CEN des nt prvide any stipulatin as t whether triggering shuld activate the autmatic ecall during the crash tests. Simply that it perfrms in accrdance t the manufacturer s intentin. Instead it is suggested that a mre severe triggering input may be required t evaluate the autmatic behaviur if the crash tests are belw the triggering threshld. Recmmendatins f the DG ecall fr the intrductin f the pan-eurpean ecall, Versin 2.0, Sectin The autmatic ecall trigger shuld be safe, rust and designed s that a minimum f false ecalls are generated by the ecall generatr. Therefre the DG ecall recmmends that: The Autmatic ecall trigger signal is generated in the airbag cntrl mdule and/r a cmbinatin f ther sensr data (e.g. gyr, radar, axel lad, speed); The ecall shall be generated t reflect as many different crash types as pssible (e.g. frnt, rear, side and rll crashes); Trigger threshlds based n delta velcity culd be send as additinal ptinal data t the PSAP, prvided that this May

40 infrmatin can be used in PSAPs with a sufficient level f reliability t evaluate the likeliness f serius injuries; and The vehicle manufacturers are respnsible fr determinatin f the autmatic ecall trigger signal. Use f crash tests As mentined in the reasns fr requirements, it is hped that existing crash tests can be used fr the assessment f the autmatic triggering f ecall. The ptential crash tests available fr this purpse are listed belw. UN Regulatin 12 This Regulatin applies t the behaviur f the steering mechanism f mtr vehicles f categry M1, and vehicles f categry N1 with a maximum permissible mass less than 1,500 kg, with regard t the prtectin f the ccupants in a frntal cllisin. The unladen vehicle, in running rder, withut a manikin, is cllisintested against a barrier at a speed f 48.3 km/h (30 mph). This 30 mph test culd prvide sme helpful infrmatin with regard t ecall ffering a slightly different scpe t Regulatin 94. Hwever, this test can be mitted if UN Regulatin 94 has been passed. Therefre it is typically nly used in apprving heavier M1 vehicles withut an airbag system. UN Regulatin 33 This Regulatin applies t vehicles f categry M1 with regard t their behaviur in a head-n cllisin. The unladen vehicle is cllisin-tested frwards against a barrier at a speed f 48.3 km/h (30 mph) UN Regulatin 34 This Regulatin applies: PART I: T the apprval f vehicles f categries M, N and O 1/ with regard t the tank(s) fr liquid fuel. PART II: At the request f the manufacturer t the apprval f vehicles f categries M, N and O apprved t Part I r IV f this Regulatin fitted with liquid fuel tank(s) with regard t the preventin f fire risks in the event f a frntal and/r lateral and/r rear cllisin. May

41 PART II cncerns the apprval f vehicles with regard t the preventin f fire risks in the event f cllisin Part II requires: UN Regulatin 94 a frntal-impact test against a barrier carried ut by the prcedure specified in Annex 3 t this Regulatin, This is either the same 30 mph unladen vehicle test as in Regulatins 12 and 33 r the test prcedure described in annex 3 f Regulatin N. 94, 01 series f amendments. a lateral impact test perfrmed accrding t the prcedure described in Annex 4 f Regulatin N. 95, 01 series f amendments, and a rear-end impact test carried ut by the prcedure specified in Annex 4 heret, Fr this test an impactr is driven int the rear f the vehicle. The impactr may either be secured t a carriage (mving barrier) r frm part f a pendulum. The velcity f cllisin shall be between 35 and 38 km/h. The aggregate weight (mass) f carriage and impactr shall be 1,100 ± 20 kg. Vehicles f categry M1 f a ttal permissible mass nt exceeding 2.5 tnnes are required t underg the crash test defined in Annex 3 f the Regulatin. This is a frntal impact test with the test vehicle crashing perpendicularly int a barrier The severity f the test is related t: the impact speed {"Vehicle speed at the mment f impact is 56 km/h. Hwever, if the test is perfrmed at a higher impact speed and the vehicle meets the requirements, the test shall be cnsidered satisfactry."}, the bject struck {"The frnt face f the barrier cnsists f a defrmable structure as defined in Annex 9 f this Regulatin." - defined t represent crush characteristics f a typical car} and the level f interactin r verlap {"The vehicle shall verlap the barrier face by 40 per cent"} May

42 This test is designed t challenge the vehicle s structural crashwrthiness. Only ne side f the vehicle interacts fully with the barrier and is respnsible fr absrbing (r managing) mst f the energy. UN Regulatin 95 This is applicable t M1 and N1 categries f vehicles where the R pint f the lwest seat is nt mre than 700 mm frm grund level when the vehicle is in the cnditin crrespnding t the reference mass defined in paragraph f this Regulatin. Such vehicles underg a test in accrdance with Annex 4 f the Regulatin. Fr this test, a mbile defrmable barrier (MDB) cllides with the side f the vehicle. The barrier cnsists f a defrmable frnt face f an impactr (designed t represent crush characteristics f a typical car) n a trlley. The ttal mass f the impacting barrier is 950 kg. The mbile defrmable barrier speed is 50 km/h. Ptential future UN Regulatin 13x It shuld be nted that Regulatin 94 is being updated with a recmmendatin t include the additinal requirement f a full-width test int a rigid barrier at 50 km/h. This is likely t ffer a mre severe acceleratin pulse at the ccupant cmpartment than the ffset defrmable barrier test at 56 km/h. Currently at the prpsal stage fr cnsideratin by the GRSP Infrmal Wrking Grup n Frntal Impact. The ptential scpe is M1 vehicles 3,500 kg 50 km/h full-width frntal crash int rigid barrier (cncrete cvered with plywd) The intentin f this test is t prvide a greater fcus n restraint system perfrmance rather than n structural perfrmance. As such it is anticipated that the acceleratins (r mechanical shck) within the ccupant cmpartment will be greater than in the Regulatin 94 cnfiguratin. May

43 Rllver tests: UN Regulatin 66 This Regulatin applies t single-deck rigid r articulated vehicles belnging t categries M2 r M3, Classes II r III r class B having mre than 16 passengers. It includes a "Rllver test n a cmplete vehicle" meaning a test n a cmplete, full-scale vehicle t prve the required strength f the superstructure. There are currently n regulatry full-scale tests fr assessing M1 and N1 vehicles in rllver cnditins. It is assumed that nly a small percentage f the vehicles sld in Eurpe are currently equipped with sensrs t mnitr fr rllver r turnver f the vehicle. Hwever, mst M1 and N1 vehicles are fitted with acceleratin sensrs in rder t deply airbags; and it is therefre reasnable t believe that they culd als be used fr ecall systems. This limits ecall autmatic peratin t impacts where airbags are deplyed, but there is much real wrld evidence, including frm the accident analysis undertaken fr this study, that frnt and/r side airbags deply in many accident types, including rllvers. Therefre, it is the authrs pinin that essential devices t determine rllver cllisins (e.g. gyrscpes), which may be relatively cstly, are nt essential at this time f preparing initial requirements. Hwever, care shuld be taken s as nt t exclude them shuld a manufacturer which t include them in the crash detectin system. Lw severity tests (lwer bundary): In thery ne might expect accidents t ccur at tw ends f a spectrum, the first where a serius r life threatening injury is likely and the ecall system must trigger; and the secnd where a serius r fatal injury is very unlikely, and the ecall system shuld ideally nt trigger. In the middle this culd leave a regin f uncertain utcme, where it is recmmended that the manufacturer is permitted t use discretin as t whether ecall shuld be triggered r nt (Figure 3-1). May

44 Figure 3-1: Simple representatin f autmatic triggering cnditins based n severity The crash tests described in the sectin abve have a severity level set arund the pint at which there is a substantial risk f injury, in which case they culd be used t assess the pint abve which ecall must trigger. Hwever, it may als be useful t have a lw severity check t make sure that ecall is nt activated when there is n risk f injury. As such, there may be a desire t use tests at a lwer severity t try and identify a cnsistent severity under which ecall shuld nt be triggered. Therefre, when cnsidering trigger checks f the autmatic ecall system it may als be wrth acknwledging the ther end f the severity spectrum. This wuld prvide sme assurance that there wuld be at least a certain benefit acrss the market, that manufacturers wuld have a level playing field and that PSAPs wn t be inundated with (lw-urgency) superfluus r false calls. The fllwing tests were identified as ptential ptins fr this purpse. RCAR Lw-speed structural crash test prtcl Issue 2.2 This dcument describes the RCAR test prcedure t assess a vehicle s damageability and repairability. The assessment includes an estimatin f the vehicle damage (physical damage and repair cst) in tw impacts: A 15 km/h frntal impact int a rigid barrier and a rigid-faced mbile barrier striking the rear f the statinary vehicle at 15 km/h. The test prcedure was revised in 2006 t change the impact angle frm 0 t 10 and the rear impact mbile barrier weight frm 1000 t 1400kg. It is nw als accmpanied by a lwer speed bumper test described belw. RCAR Bumper Test Issue 2.0 This dcument describes the RCAR bumper test prcedures that assess bumper perfrmance. An internatinal RCAR wrking grup has May