COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council Saving Lives: Boosting Car Safety in the EU Reporting on the monitoring and assessment of advanced vehicle safety features, their cost effectiveness and feasibility for the review of the regulations on general vehicle safety and on the protection of pedestrians and other vulnerable road users
Date: 2016-12-12
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: bus, commercial vehicle, innovation, motor vehicle, pedestrian, road safety, safety device, safety standard, technical standard, transport accident

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 12.12.2016  SWD(2016) 431 final   COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council Saving Lives: Boosting Car Safety in the EU Reporting on the monitoring and assessment of advanced vehicle safety features, their cost effectiveness and feasibility for the review of the regulations on general vehicle safety and on the protection of pedestrians and other vulnerable road users  {COM(2016) 787 final}  
 
 
Contents 

1. 

2. 

3. 

Introduction .................................................................................................................. 4 

Key issues to be addressed in the review of the regulations ........................................ 5 

Candidate Measures for Consideration for Implementation in the General Safety and 
Pedestrian Regulations ................................................................................................. 6 

3.1. 

Main items for all relevant vehicle categories ............................................................. 6 

3.1.1.  Automatic Emergency Braking .................................................................................... 6 

3.1.2.  Emergency Braking Display (Stop Signal) .................................................................. 8 

3.1.3. 

Intelligent Speed Adaptation ........................................................................................ 9 

3.1.4.  Lane Keep Assistance ................................................................................................ 11 

3.1.5.  Driver Drowiness or Distraction Monitoring ............................................................. 13 

3.1.6.  Safety belt reminders.................................................................................................. 14 

3.1.7.  Frontal Crashes .......................................................................................................... 15 

3.1.8.  Side Crashes ............................................................................................................... 18 

3.1.9.  Rear Crashes .............................................................................................................. 19 

3.1.10.  Alcohol Interlock Devices.......................................................................................... 21 

3.1.11.  Crash Event Data Recorder ........................................................................................ 22 

3.1.12.  Tyre Pressure Monitoring .......................................................................................... 23 

3.2. 

Trucks and Buses ....................................................................................................... 25 

3.2.1.  Front-end Design and Direct Vision .......................................................................... 25 

3.2.2.  Truck Rear Underrun Protection ................................................................................ 27 

3.2.3.  Truck Lateral Protection ............................................................................................ 28 

3.2.4.  Fire Safety for Buses .................................................................................................. 29 

3.3. 

Pedestrian and Cyclist Safety ..................................................................................... 30 

3.3.1.  Pedestrian and Cyclist Detection ............................................................................... 30 

3.3.2.  Head Impact on A-Pillars and Front Windscreen ...................................................... 31 

3.3.3.  Reversing (Backing up) Detection ............................................................................. 32 

4. 

5. 

5.1. 

5.2. 

5.3. 

5.4. 

6. 

Bunching of Technologies ......................................................................................... 34 

Further Studies in the Field of Vehicle Safety ........................................................... 34 

Frontal crashes ........................................................................................................... 34 

Side crashes ................................................................................................................ 35 

Roll-over accidents..................................................................................................... 35 

Rear crashes ............................................................................................................... 35 

Conclusions ................................................................................................................ 35 

ANNEX 1: List of proposed measures by introduction date ................................................... 36 

2 

 
ANNEX 2: Full list of potential measures as established for the feasibility and cost-benefit 

study (published in March 2015) ............................................................................... 40 

A2.1.  Active safety .............................................................................................................. 40 

A2.2.  Car occupant and pedestrian safety ............................................................................ 42 

A2.3.  Crashworthiness, HGV Safety and Fuel Systems ...................................................... 43 

A2.4.  Driver Interface, Distraction and Intelligent Transport Systems ............................... 44 

ANNEX 3: For candidate measures, summary of feasibility and cost benefit assessment 

reported initially ......................................................................................................... 46 

3 

 
 
 
 
 
 
 
1. 

INTRODUCTION 

A  traditional  approach  to  analyse  road  safety  is  to  identify  a  specific  issue  and  to  research 
mitigation  actions.  The  European  Parliament  and  Council  however  have  given  the 
Commission  clear  instructions  on  another  way  forward  to  review  of  the  existing  safety 
regulations:  assessing  the  inclusion  of  further  new  safety  features  and  proposal  of  new 
measures on the basis of the results of monitoring linked to the safety of pedestrians and other 
vulnerable  road  users.  This  is  indeed  the  work  that  is  being  undertaken  by  the  Commission 
and  rather  than  to  identify  specific  issues  and  work  from  there,  the  Commission  has  been 
reviewing a suite of unregulated measures that can be proposed in a package, with potential to 
provide  effective  incremental  but  significant  improvements  addressing  a  range  of  vehicle 
safety related areas. 

In  this  context,  Regulation  (EC)  No  661/2009  of  the  European  Parliament  and  Council, 
amended by Commission Regulation (EU) Nos 407/2011, 523/2012, 2015/166 and 2016/1004 
(the  ‘General  Safety  Regulation’)  governs  the  type-approval  requirements  for  the  general 
safety of motor-vehicles, their trailers and systems, components and separate technical units.  

The Regulation lists the individual measures that apply on a compulsory basis and the vehicle 
categories to which each measure applies. To date, a number of amendments have been made 
to the General Safety Regulation including mandating: 

  Electrical safety 
  Electronic Stability Control (ESC) systems on cars, vans, trucks and buses 
  Fitment of tyre pressure monitoring systems on cars 
  Lane  Departure  Warning  Systems  (LDWS)  and  Advanced  Emergency  Braking 

Systems (AEBS) for trucks and buses 

  Gear shift indicators on cars 
  Rolling resistance limits, noise emission limits and wet grip performance of tyres 
  Driver seat-belt reminder on cars 
 
ISOFIX child restraint anchorages on cars 
  Cab strength crash protection of vans and trucks 
  A large number of UNECE Regulations replacing repealed Directives 

In addition, Regulation (EC) No 78/2009 on the type-approval of motor vehicles with regard 
to  the  protection  of  pedestrians  and  other  vulnerable  road  users  (the  ‘Pedestrian  Safety 
Regulation’)  replaced  Directive  2003/102/EC  with  modified  and  more  advanced  provisions, 
adapted  to  the  technical  progress.  This  includes  passive  safety  requirements  to  mitigate  the 
risk of critical injury in case of a collision between a vehicle and a person. 

The  General  Safety  Regulation  Article  17  requires  that  the  Commission  reports  to  the 
European  Parliament  every  three  years  with  proposals  for  amendment  to  the  Regulation  or 
other  relevant  Community  legislation  regarding  the  inclusion  of  further  new  safety  features 
that  meet  the  CARS  20201  and  the  Policy  Orientations  on  Road  Safety  2011-2020  criteria. 
Commission monitoring reports to the European Parliament are also required, as appropriate, 
by the Pedestrian Safety Regulation Article 12. 

As  part  of  these  requirements,  a  report  was  produced  on  behalf  of  the  Commission  by  the 
Transport Research Laboratory TRL of the UK (Hynd et al, 2015)2 concerning an overview of 

1   CARS 2020: Action Plan for a competitive and sustainable automotive industry in Europe 
2   Hynd, D., McCarthy, M., Carroll, J., Seidl, M., Edwards, M., Visvikis, C., Tress, M., Reed, N. and Stevens, 
A. (2015). Benefit and feasibility of a range of new technologies and unregulated measures in the fields for 
occupant  safety  and  protection  of  vulnerable  road  users.  Final  Report.  Brussels:  European  Commission. 
http://bookshop.europa.eu/en/benefit-and-feasibility-of-a-range-of-new-technologies-and-unregulated-

4 

 
                                                 
the feasibility and cost-benefit assessment of a wide range of possible measures for inclusion 
in EU legislation as regards an update of the General Safety and Pedestrian Regulations. The 
main  outputs  of  the  report  were  indicative  cost-benefits  provided  in  order  to  differentiate 
those measures that would be very likely (gren light), moderately likely (yellow light) or very 
unlikely (red light) to provide a benefit consistent with the cost of implementation.  

The  report  also  provided  advice  on  the  necessity  and  feasibility  of  making  mandatory  the 
‘upper legform to bonnet leading edge test’ and the ‘adult headform to windscreen test’ that 
were  both  carried  out  by  car  producers  as  part  of  the  mandatory  monitoring  program 
encompassed in the pedestrian safety legislation. 

Using the results from this report and where appropriate, revised and updated information and 
insights  in  terms  of  the  benefit  and  feasibilty  of  specific  measures,  further  work  has  been 
performed  to select candidate measures for consideration for  implementation in  the General 
Safety and Pedestrian Regulations.  

This  Commission  Staff  Working  Document  lists  those  candidate  measures,  their  technical 
feasibility and legislative feasibility/readiness and potential target dates for implementation. It 
also  summarises  the  further  work  required  for  their  possible  implementation  in  the  General 
Safety and Pedestrian Regulations. Studies to perform this work are currently underway and it 
is  planned  to  use  the  output  of  these  studies  to  update  the  list  of  candidate  measures  upon 
completion of these studies. 

2. 

KEY ISSUES TO BE ADDRESSED IN THE REVIEW OF THE REGULATIONS 

The  study on the Benefit and Feasibility of a Range of New  Technologies  and Unregulated 
Measures in the fields of Vehicle Occupant Safety and Protection of Vulnerable Road Users2 
in the frame of the General Safety and Pedestrian Safety Regulations was published in March 
2015.  The  report  provides  an  overview  of  feasibility  and  cost-benefit  assessment  of  a  wide 
range  of  candidate  measures  for  possible  inclusion  in  the  General  Safety  and  Pedestrian 
Safety Regulations. The outputs of the report were indicative cost-benefits provided in order 
to  differentiate  those  measures  that  are  very  likely,  moderately  likely  or  very  unlikely  to 
provide a benefit consistent with the cost of implementation. The information was compiled 
and  provided  with  the  aim  to  enable  prioritisation  of  possible  future  measures  and  was 
debated intensively with the stakeholders and authorities of Member States and international 
partners. 

Thus,  in  the  initial  phase  of  this  exercise,  a  selection  of  55  of  the  most  promising  areas  of 
interest were established and assessed.  

In the present phase, the potential regulatory measures that have shown to yield an acceptable 
cost benefit as well good feasibility for implementation, 19 measures are now proposed to be 
debated in view of the review of the General Safety and Pedestrian Safety Regulations. 

In  some  cases,  the  measures  are  complementary  to  existing  rules.  An  example  is  seat  belt 
reminder  that  is  already  mandatory  on  the  driver  seat  of  passenger  cars,  but  this  will  be 
expanded to all occupant seats in cars and light commercial vehicles , as well as to all front 
seats  in  trucks  and  buses.  Tyre  pressure  monitoring  is  currently  required  on  passenger  cars 
only, but will be expanded to all motor-vehicles and heavy trailers. 

In  other  cases  an  identified  measure  is  split  in  multiple  facets  to  facilitate  a  pragmatic 
implementation timeline. When regarding the case for Automatic emergency braking (AEB), 

measures-in-the-field-of-vehicle-occupant-safety-and-protection-of-vulnerable-road-users-
pbNB0714108/;pgid=Iq1Ekni0.1lSR0OOK4MycO9B0000BAJ9tQVy;sid=OT_-Ap3uO3P-
V8j2wGFgpf_Lm_yCUpo9P-w= 

5 

 
                                                                                                                                                         
this  measure  is  proposed  in  four  steps:  In  the  first  step,  AEB  that  has  sensing  capability  of 
moving vehicles ahead that are slowing down is introduced, followed by systems that can also 
sense stationary ones. The third implementation step actually falls under the pedestrian safety 
measure, but is based on exactly the same technology, namely AEB with pedestrian detection 
capability.  The  final  step  is  foreseen  for  AEB  systems  that  can  also  detect  an  imminent 
collision  with  a  cyclist.  Annex  1  to  this  Commission  Staff  Working  Document  provides  a 
comprehensive overview of all measures and implementation steps that are divided by certain 
technological capabilities and applicability for specific vehicle categories. 

It  should  further  be  mentioned  that  in  some  specific  cases  updated  information  concerning 
cost evidence could be obtained and applied towards the improved assessment of the relevant 
proposed measures. Namely, in the initial phase it was highlighted that further analysis would 
be needed to obtain a clear view on the cost-effectiveness of a few given measures that have 
been reviewed in isolation. Such further analysis has indeed been carried out for the purpose 
of  providing  an  updated  overview  of  the  anticipated  cost-effectivenss  in  this  Commission 
Staff Working Document. 

When  certain  individual  safety  features,  yet  using  common  hardware  components,  are 
bundled, this also reflects such commonality in the eventual cost price, with a positive cost-
benefit effect. In any event, the cumulative cost of introducing technologies will be carefully 
assessed as part of a new in depth cost-benefit study, that will in turn form the basis for the 
overall  impact  assessment.  To  obtain  highly  credible  information  on  technology  costs,  it  is 
envisioned that a detailed cost teardown is performed where appropriate. 

In  this  context  it  is  important  that  a  thorough  overview  can  be  provided  on  the  costs  that 
might be passed on to the end consumer, in relation to the safety features that will need to be 
added  to  future  vehicles  as  a  result  of  the  revised  General  Safety  and  Pedestrian  Safety 
Regulations, as well as on the economic feasibility and how this may subsequently affect the 
competitiveness of the automotive industry. 

As part of the preparatory process, the Commission will involve stakeholders and ask citizens 
for  their  feedback  on  the  considered  new  vehicle  safety  rules.  For  this  purpose,  the 
Commission will prepare an inception impact assessment3. The feedback that will be provided 
can then be taken into account for the further development of the policy proposal. 

The  Commission  considers  that,  to  limit  the  enforcement  costs  for  the  industry  and  in  line 
with the better regulation principles, the requirements will need to be implemented with due 
lead-time and concentrated in a few implementation dates. The Commission considers that the 
target  date  for  already  mature  and  generally  available  technologies  to  become  mandatory 
might  be  set  to  2020  for  new  types  of  vehicles  and  to  2022  for  new  vehicles.  For  less 
developed  technologies,  the  target  date  might  be  2022  and  2024  respectively,  with  a  few 
exceptions of longer term objectives in some specific areas. 

3. 

CANDIDATE  MEASURES  FOR  CONSIDERATION  FOR  IMPLEMENTATION  IN  THE 
GENERAL SAFETY AND PEDESTRIAN REGULATIONS 

3.1.  MAIN ITEMS FOR ALL RELEVANT VEHICLE CATEGORIES 

3.1.1.  Automatic Emergency Braking 

Automatic  Emergency  Braking  (AEB)  combines  sensing  of  the  environment  ahead  of  the 
vehicle with the automatic activation of the brakes (without driver input) in order to mitigate 
or  avoid  an  accident.  The  level  of  automatic  braking  varies,  but  may  be  up  to  full  ABS 
braking capability.  

3  

http://ec.europa.eu/smart-regulation/roadmaps/index_en.htm 

6 

 
                                                 
From  1st  November  2015,  the  General  Safety  Regulation  has  required  the  fitment  of 
Advanced Emergency Braking Systems to new vehicles of categories M2, M3, N2 and N3. EU 
Regulation  No.  347/2012  specifies  technical  requirements  and  test  procedures  for  these 
systems. The systems shall detect the possibility of a collision with a preceding vehicle, warn 
the driver  by a combination of optical, acoustic or  haptic signals  and, if the driver takes  no 
action,  automatically  apply  the  vehicle’s  brakes.  Two  performance  levels  are  specified  with 
the more stringent level becoming mandatory from 1st November 2016 for new types and 1st 
November  2018  for  all  new  vehicles.  Note  that  only  the  more  stringent  level  contains  test 
pass/fail values for vehicles of categories M2 and N2≤ 8 tonnes, so there are no requirements 
for these vehicles before 1st November 2016.  

First  generation  AEB  for  passenger  cars  (M1)  are  capable  of  automatically  mitigating  the 
severity of two-vehicle, front to rear shunt accidents (on straight roads and curves dependent 
on sensor line of sight and environment ‘clutter’) as well as some collisions with fixed objects 
and motorcycles. These systems are becoming more and more common, notably through Euro 
NCAP  encouragement  for  systems  that  can  detect  slow  moving  or  even  stopped  vehicles 
ahead.  This  is  also  the  case  for  systems  that  have  the  capability  to  detect  pedestrians  and 
bicyclists, although these systems are currently still less common, but increasingly available 
on a number of car models. 

In  the  context  of  the  review  of  the  General  Safety  and  Pedestrian  Safety  Regulations,  an 
introduction  timeline  should  be  considered  that  allows  for  a  phase  in  of  the  detection 
capabilities and mandatory introduction on passenger cars (M1) and vans (N1). 

o  Make mandatory for M1 and N1 vehicles (that are derived from M1) 
o  01/09/2020 moving obstacle detection for new EU approved types 
o  01/09/2022 stationary obstacle detection for new EU approved types 
o  Plus 2-year period for all new vehicles sold in the EU 
o  All N1 vehicles 2-year offset to the above dates 

Technical feasibility:  

AEB are in production on a number of current pssenger cars, typically at the top-end of the 
market but increasingly also on standard vehicles. For passenger cars (M1), AEB are optional 
equipment on approximately 20-50% of 2013 vehicle models and are fitted as standard to an 
increasing share of vehicles. 

Legislation feasibility/readiness:  

Validated test procedures for AEB for M1 vehicles have been developed and implemented by 
Euro NCAP and could be used as a basis for future legislation. 

EU  Regulation  No.  347/2012  specifies  the  technical  requirements  and  test  procedures  for 
advanced  emergency  braking  systems  (AEBS)  for  M2/M3  and  N2/N3  category  vehicles  that 
detect the possibility of a collision with a preceding vehicle, warn the driver by a combination 
of optical, acoustic or haptic signals and, if the driver takes no action, automatically apply the 
vehicle’s brakes. The Regulation specifies requirements on the system operation and specifies 
two test procedures to check the performance of the system; one with the vehicle approaching 
a  moving  target  and  one  with  the  vehicle  approaching  a  stationary  target.  The  Regulation 
specifies two “Levels” of limit values on the timing of the warnings and on the vehicle speed 
reduction to be achieved in each of these tests, with the “Level 2” requirements being more 
stringent. To allow time for the development of suitable systems for lighter vehicles, vehicles 
with  hydraulic  braking  systems  and  vehicles  with  mechanical  rear  suspension  systems,  the 
“Level 1” limits are only applied to M3 Category vehicles, N2 Category vehicles with a GVW 
greater  than  8,000  kg  and  N3  Category  vehicles  that  are  equipped  with  pneumatic  or 
air/hydraulic braking systems and with pneumatic rear axle suspension systems. 

7 

 
The  fitment  of  advanced  emergency  braking  systems  (AEBS)  meeting  the  “Level  1” 
performance requirements has been mandatory for all new vehicles from 1st November 2013 
and  for  new  types  of  vehicle  and  from  1st  November  2015.  The  fitment  of  advanced 
emergency  braking  systems  (AEBS)  meeting  the  “Level  2”  performance  requirements 
becomes  mandatory  from  1st  November  2016  for  new  types  of  vehicle  and  1st  November 
2018 for all new vehicles. The “Level 2” performance requirements include requirements N2 
vehicles  with  a  GVW  less  than  8000  kg  and  N3  Category  vehicles  that  are  equipped  with 
pneumatic or air/hydraulic braking systems and with pneumatic rear axle suspension systems. 

The benefit of fitting AEB to M1 vehicles in terms of casualties saved has been estimated to 
be  far  higher  than  for  M2/M3  and  N2/N3  vehicles    (Grover  2008)4.  Even  so,  the  break  even 
cost per vehicle (i.e. the cost per vehicle for a benefit to cost ratio of 1) was estimated to be 
far higher for M1 vehicles because there are far more vehicles of this category in the vehicle 
fleet. However, costs for these systems are reducing (current consumer costs for AEB are as 
low as £200 (Ford, VW)), so it is likely that the benefit to cost ratio of fitment of AEB to M1 
vehicles will have a benefit to cost ratio greater than one. This is even more likely to be the 
case  for  ‘city’  AEB  systems  that  help  prevent  the  frequent  low  speed  collisons  and  the 
associated whiplash injuries and relatively minor vehicle damage.  

For consideration for implemenation in the GSR further work is required to:  

  confirm benefit to cost ratio. 

3.1.2.  Emergency Braking Display (Stop Signal) 

The emergency braking display, or emergency stop signal, consists of a rapid flashing of the 
brake lamp when full brakes are applied. This technology is already optionally available on 
motor  vehicles  and  has  proven  to  be  very  effective5.  Drivers  following  the  hard-braking 
vehicle are instantly aware that the vehicle in front is braking with a high retardation so that 
they can take appropriate action. This relatively simple but effective technology can thus help 
drivers  to  avoid  late  recognition  the  hard-braking  situation  and  avoid  subsequent  accidents 
that could result. 

This system is designed to address front-to-rear accidents. This system is primarily effective 
on  highways  and  provides  better  quality  information  to  following  drivers  so  that  rear  shunt 
accidents can be avoided or mitigated. 

The rationale behind Emergency Braking Display (EBD) is to decrease the time required to 
detect an emergency brake by the following driver, thereby avoiding or mitigating the effect 
of  rear-end  collisions.  A  road  user  who  is  temporarily  not  looking  at  the  road,  for  instance 
when  inspecting  in-vehicle  equipment,  will  notice  through  peripheral  vision  a  flashing  light 
more readily than the activation of ‘normal’ braking lamps. The emergency braking display, 
or  emergency  stop  signal,  consists  of  a  rapid  flashing  of  the  brake  lamp  or  hazard  warning 
lights when full brakes (e.g. > 6m/s2 for cars) are applied. Drivers following the hard-braking 
vehicle are more quickly aware that the vehicle in front is braking with a high retardation so 
that they can take appropriate action. It is proposed: 

Make emergency braking display mandatory for all M and N vehicles 

  01/09/2020 for new types 
  01/09/2022 for all new vehicles 

4   Grover C, Knight I, Okoro F, Simmons I, Couper G, Massie P and Smith B (2008). Automated Emergency 

Braking Systems: Technical requirements, costs and benefits. 
http://www.unece.org/fileadmin/DAM/trans/doc/2003/wp29gre/TRANS-WP29-GRE-51-09e.pdf 

5  

8 

 
                                                 
Some  studies  have  shown  that  flashing  the  amber  hazard  lights  are  a  more  effective 
emergency signal; Li at al. (2014)6 found a 0.11s (10%) improvement in brake response time 
for  flashing  hazard  lights  compared  with  flashing  red  brake lights.  Studies  consistently  find 
that the frequency is important and most effective at 4Hz7, although a lower frequency (3 Hz 
or less) is less likely to trigger photosensitive epilepsy (PSE). However, limiting the duration 
of the flashing will also limit trigger  of PSE, if photic simulation is limited to  2 sec  or less 
PSE hardly occurs. 

Technical feasibility:  

Emergency braking display (EBD) systems are currently fitted as standard to some cars, e.g. 
some Mercedes vehicles are fitted with EBD which flash the stop lamps and some VW group 
vehicles  are  fitted  with  EBD  which  flash  the  amber  hazard  warning  lamps.  For  best 
performance, EBD requires LED lights because this source provides a better fast response. 

Legislation feasibility/readiness:  

UN Regulation 48 contains specification for the lamps providing the optional emergency stop 
signal  (EBD)  to  flash  at  4Hz  (+/-  1Hz)  for  LED  and  4Hz  (+0Hz/-1Hz)  for  incandescent 
sources when a passenger car decelerates at greater than 6 m/s2 or a truck or bus decelerates 
at greater than 4 m/s2. 

Benefit is predicted to be significant; on the basis of data on German traffic accidents, EBD 
has been estimated to affect 25% of rear-end crashes in moving traffic and 15% in stationary 
traffic  resulting  in  a  14%  reduction  in  these  crashes.  These  estimates  were  based  on  the 
assumption of an EBD penetration rate of 70% of the German passenger vehicle fleet (Gail et 
al., 2001)8.  

No  information  is  available  on  costs,  but  they  are  likely  to  be  low  as  it  mainly  concerns 
adaptation of the stop lamp activation software. Therefore, the benefit to cost ratio is likely to 
be equal or greater than 1. 

For consideration for implementation in the GSR further work is required to: 

  confirm benefit to cost ratio  
  and  decide  if  either  system  (flash  stop  lamps  or  flash  hazard  warning  lamps)  or  just 
one  (one  study  showed  flash  hazard  warning  lamps  more  effective)  should  be 
mandated. 

3.1.3. 

Intelligent Speed Adaptation 

Intelligent  Speed  Adaptation  (ISA) describes  a range  of  technologies  which  are  designed  to 
aid drivers in observing the appropriate speed for the road environment.  

Speed  is  still  the  main  factor  linked  to  road  accident  deaths  and  severe  injuries.  Every  day 
motorists  are  taking  incredible  chances  by  not  adapting  the  driving  speed  to  the  traffic 
situation and road infrastructure. 

6  

7  

Li  G,  Wang  W,  Eben  Li  S,  Cheng  B  and  Green  P  (2014).  Effectiveness  of  Flashing  Brake  and  Hazard 
Systems  in  Avoiding  Rear-End  Crashes.  Advances  in  Mechanical  Engineering.  Volume  2014,  Article  ID 
792670 
Study on the Validity of Emergency Brake light Display. Informal document No. 9. 51st GRE, 15-19 
September 2003, agenda item 1.1.2.9. 
http://www.unece.org/fileadmin/DAM/trans/doc/2003/wp29gre/TRANS-WP29-GRE-51-09e.pdf 

8   Gail  J,  Lorig  M,  Gelau  C,  Heuzeroth  D  and  Sievert  W  (2001).  Optimization  of  rear  signal  pattern  for 
reduction of rear-end accidents during emergency braking manoeuvres. Technical Report, Federal Highway 
Research Institute, Bergisch Gladbach, Germany. 

9 

 
                                                 
The link between excessive speed and increased severity/frequency of accidents has long been 
established (e.g. Finch et al., 19949; Taylor et al., 200010; Taylor et al. 200211). These studies 
broadly conclude, across all road types, that a 1 km/h decrease in mean speed would reduce 
the number of road collisions by 3%. As well as the having an influence on the frequency of 
collisions,  speed  also  affects  injury  severity  since  collision  energy  is  proportional  to  the 
square of velocity, and in an accident this means that the subsequent injury risk also increases 
more rapidly at greater speed. 

A  potential  solution  for  this  problem  is  the  introduction  of  mandatory  intelligent  speed 
adaptation  (ISA)  systems,  consisting  of  a  range  of  technologies  which  are  designed  to  aid 
drivers  in  observing  the  appropriate  speed  for  the  road  environment.  These  systems  which 
warn the driver when the speed limit is exceeded, or prevent the driver from doing so, provide 
a very effective strategy for reducing accidents and injury severity. The three main forms of 
ISA are: 

  Advisory - alert the driver to when their speed is too great; 
  Voluntary  -  the  driver  chooses  whether  the  system  can  restrict  their  vehicle  speed 

and/or the speed it is restricted to; and  

  Mandatory - the driver’s speed selection is physically limited by the ISA system. 

The  magnitude  of  casualty  savings  depends  on  the  type  of  system  used  and  depends  on  the 
type  of  system  used.  Estimates  vary  between  studies,  however,  many  studies  are  in  broad 
agreement with the estimates that purely advisory systems offer around 8.4% accident savings 
whereas mandatory systems offer up  to 30% reduction12. However, we need to be weary of 
the possibility that when requiring very intrusive speed adaptation systems, this may lead to 
much  less  public  support  and  poor  user  acceptance.  For  this  reason,  a  pragmatic  phased 
introduction of the measure should be reviewed. 

In any case the system should always be easily overridden by the driver when necessary, e.g. 
when overtaking. We further suggest that it should be a system based on providing effective 
haptic feedback, for instance by gently pushing the pedal back to signal the vehicle is driving 
too fast and speed needs to be reduced. Also, consideration needs to be given to requirements 
for accurate recognition of speed limits. 

  Current technology based on sign recognition 
  Need to work on infrastructure requirements (i.e. integrated approach) 

o  Initial technology based on best-effort recognition and map-data 
o  Could  consider  to  develop  harmonised  speed  limit  beacons  (or  other  ITS 

solutions, t.b.d.)  

  Make mandatory for all M and N vehicles  

o  01/09/2020 new types 
o  01/09/2022 for all new vehicles 

Technological feasibility:  

9  

Finch  DJP,  Kompfner  P,  Lockwood  CR  and  Maycock  G  (1994).  Speed,  speed  limits  and  accidents. 
Crowthorne, TRL. 

10   Taylor  MC,  Lynam  DA  and  Baruya  A  (2000).  The  effects  of  drivers’  speed  on  the  frequency  of  road 

accidents. Crowthorne: Transport Research Laboratory. 

11   Taylor  MC,  Baruya  A  and  Kennedy  JV  (2002).  The  relationship  between  speed  and  accidents  on  rural 

single-carriageway roads. TRL Report TRL511. Crowthorne: Transport Research Laboratory 

12   Wilkie SM and Tate FN (2003). ISA UK – Intelligent Speed Adaptation. Implications of travel patterns for 

ISA. University of Leeds and MIRA Ltd. 

10 

 
                                                 
Many  current  vehicles are fitted with  voluntary speed limiting  systems which can  be set by 
the driver to ensure compliance with a particular speed threshold. However, the speed limiter 
is  set  by  the  driver  and  is  not  linked  to  any  digital  map  of  speed  limit  information.  ISA 
systems require an accurate knowledge of speed limits, either from a digital map with satellite 
navigation to locate the vehicle to the speed limit, or a series of local beacons (in traffic signs 
or other roadside furniture) and/or traffic sign recognition. 

As  the  cost  of  technologies  have  decreased,  GPS-based  systems  have  emerged  as  the 
preferred solution, mostly due to their superior flexibility, the potential to integrate ISA into a 
package of wider “intelligent vehicle” technologies, and avoiding the need to set up a costly 
network of national beacons. 

Legislation feasibility/readiness:  

The Safety Assist protocol of Euro NCAP assesses and rewards ISA systems. This addresses 
functional aspects regarding the speed limitation and warning function but does not perform a 
performance assessment of, for example, the reliability of the speed limit detection.  

The  greatest  benefits  were  predcited  to  be  delivered  for  mandatory  systems,  save  20%  of 
injury accidents and 37% of fatal accidents Carsten and Tate (2005)11. Systems which could 
respond to current network and weather conditions were predicted to deliver greater benefits, 
a reduction of 36% in injury accidents and 59% in fatal accidents. Other benefits also come 
from  improved  fuel  economy.  No  benefit  studies  were  found  for  fitment  of  ISA  to  large 
vehicles (N2/N3 and M2/M3), although a study on the effectiveness of Directive 2002/85/EC 
(the Speed Limitation Directive) found a positive impact on safety; accident reductions of 9% 
for  fatal  accidents  on  motorways  with  HCVs  involved,  4%  of  serious  injuries,  and  3%  of 
injury accidents were estimated (Transport and Mobility Leuven, 2013)13.  
A cost-benefit analysis of ISA was performed by Carsten and Tate (2005)14 which produced 
ratios of 7.9 to 15.4 depending on the type of ISA system considered; mandatory ISA yield 
the greatest benefit to cost ratios. Other studies have also found benefit to cost ratios in excess 
of  one  and  consistently  show  that  the  benefits  substantially  outweigh  the  costs  of  ISA 
implementation15.  

For consideration for implementation in the GSR further work is required to:  

  confirm  implementation  strategy,  including  methods  for  recognition  of  appropriate 

speed limit. 

  consider technology bunching, e.g. camera for sign recognition could also be used for 
‘Lane  keeping  assistance’  and  possibly  AEB  camera  based  systems  as  well,  thus 
reducing costs. 

  confirm benefit to cost ratio. 

3.1.4.  Lane Keep Assistance 

Current  Lane  keep  Assistance  (LKA)  systems  help  the  driver  to  stay  in  their  lane.  They 
function at speeds typically from 65 km/h and work by monitoring the position of the vehicle 
with respect to the lane boundary, typically via a camera mounted behind the windscreen sited 
behind the rear view mirror. When the vehicle drifts out of the lane the LKA gently guides the 

13   Transport and Mobility Leuven  (2013).  Ex-post evaluation  of Directive 92/6/EEC  on  the  installation and 
use of speed limitation devices for certain categories of motor vehicles in the Community, as amended by 
Directive 2002/85/EC. Transport & Mobility Leuven, Diestsesteenweg 57, 3010 Leuven – Belgium. 
14   Carsten  O  and  Tate  F  (2005).  Intelligent  speed  adaptation:  accident  savings  and  cost–benefit  analysis. 

Accident Analysis and Prevention 37 (2005) 407–416. 

15   Carsten  O  (2005).  PROSPER  Results:  Benefits  and  Costs.  Presentation  at  the  PROSPER  Seminar  on  23 

November 2005 in Brussels 

11 

 
                                                 
vehicle  back  into  the  lane  by  the  application  of  a  torque  to  the  steering  wheel  or  one-sided 
braking.  LKA  can  take  corrective  action  only  if  the  lane  marking  is  being  approached  very 
gradually:  more  rapid  departures  cannot  be  corrected.    Future  enhanced  LKA  systems  have 
been developed which will be able to steer the vehicle around normal bends on highways, i.e. 
roads where the traffic in each direction is separated and users such as pedestrains and cyclists 
are  not  permitted.  However,  currently  these  systems  are  not  permitted  by  Regulation  79, 
although work is ongoing in Geneva to change this. 

In  brief,  current  LKA  systems  can  help  avoid  accidents  in  which  a  vehicle  leaves  the  lane 
unintentionally,  usually  because  of  driver  distraction  or  fatigue,  that  can  result  in  head-on 
collisions  with  oncoming  vehicles,  involve  impacts  with  roadside  furniture  or  side-swipe  of 
the vehicle that is travelling in the same direction in an adjacent lane.  

Fitment  of  Lane  Departure  Warning  Systems  (LDWS)  to  M2/M3  and  N2/N3  vehicles  is 
mandatory from 2013 for new types and 2015 for new vehicles. LDWS warn the driver if the 
vehicle  leaves  its  lane  unintentionally,  howver  they  do  not  guide  the  vehicle  back  into  the 
lane.  

  Make  current  Lane  Keeping  Assistance  (LKA)  mandatory  for  M1  and  N1  vehicles 

(derived from M1) 

o  01/09/2020 for new types 
o  01/09/2022 for all new vehicles 
o  All N1 vehicles 2-year offset to the above dates 

Technological feasibility:  

LKS  are  in  production  and  offered  by  many  of  the  major  vehicle  manufacturers,  ususally 
offered  as  an  optional  extra  typically  packaged  with  other  related  systems,  e.g.  Lane 
Departure Warning (LDW), traffic sign recognition, driver alert and auto high beam.  

Legislation feasibility/readiness:  

ISO standard 17387 contains technical requirements that could potentially be used as a base 
for legislation. 

Benefits  of  fitment  of  LKA  for  M1/N1  vehicles  in  the  EU  are  estimated  to  be  up  to  3,500 
fatalities and 17,000 serious injuries (Visvikis 2008)16. Benefit to cost ratios of 1.6 to 2.1 have 
been  estimated  by  Cowi(2006)17  and  of  0.25  to  2.12  by  Robinson  et  al.  (2011)18  for  Lane 
Departure  Warning  Systems  (LDWS)  for  M1/N1  vehicles.  Because  LKA  systems  are  more 
effective  than  LDWS,  cost  benefit  ratios  are  likely  to  be  greater  than  one  and  closer  to  the 
higher ratios predicted by Robinson et al. 

For consideration for implementation in the GSR further work is required to:  

  consider technology bunching, e.g. camera could also be used for sign recognition in 
ISA systems and possibly AEB camera based systems as well, thus reducing costs. 

  confirm benefit to cost ratio. 

16   Visvikis  C, Smith  TL,  Pitcher  M and  Smith  R (2008). Study on  lane departure  warning  and lane  change 

assistant systems: Final report. PPR374. TRL Limited, Crowthorne, UK. 

17   COWI  (2006).  Cost-benefit  assessment  and  prioritisation  of  vehicle  safety  technologies  -  Final  report. 
Framework  Contract  TREN/A1/56-2004;  Lot  2:  Economic  assistance  activities.  ECORYS,  COWI,  ECN, 
Ernst & Young Europe and Consultrans. 

18   Robinson  B,  Hulshof  W,  Cookson  R,  Cuerden  R,  Hutchins  R  and  Delmonte  E  (2011).  Cost  benefit 
evaluation of advanced primary safety systems: Final report. PPR586. TRL Limited, Crowthorne, UK. 

12 

 
                                                 
3.1.5.  Driver Drowiness or Distraction Monitoring 

Distraction and drowsiness are both considered types of driver inattention for which the key 
shared feature is the absence of visual attention on the driving task, either due to fatigue or 
due to some activity that competes for a driver’s visual attention. The current estimate for the 
impact  of  road  user  distraction  on  accidents  in  the  EU  is  that  it  is  a  contributory  factor  in 
around  10-30%  of  road  accidents19.  Statistics  relating  to  the  proportion  of  road  accidents 
attributable to driver fatigue vary between country and reporting body, but reports of it being 
a  contributing  factor  in  approximately  20%  of  accidents  are  common.  Furthermore,  there  is 
even general agreement in the research community that any percentages based on crash data 
underestimate the true magnitude of the problem, since the evidence for distraction or fatigue 
involvement in crashes is often based on subjective criteria that exclude other factors rather 
than identifying definite involvement of fatigue or distraction.  

Adding  new  technology  to  vehicles  that  can  correct  driver  mistakes  because  of  lack  of 
observance  will  make  cars  a  lot  safer20,  but  caution  will  be  needed  because  a  category  of 
drivers may become dependent on these systems for reasons that are not linked to driving, for 
instance because of in-vehicle social media access with interactive screens. 

A wide range of technologies may be used to identify distraction or drowsiness in drivers in 
order to minimise related accidents. Systems may employ physiological monitoring, physical 
monitoring or behavioural indices and patterns. The review of the General Safety Regulation 
should consider the introduction of technology neutral solutions that could help address this 
increasingly common threat to road safety . 

  Technology neutral, testing protocol to be determined, but with several phases linked 

to the improving sophistication of the detection systems 

  Make mandatory for all M and N vehicles 
  Application  dates  recommended  to  be  coupled  with  Automatic  Emergency  Braking 

and Lane Keeping Assist if possible. 

Technological feasibility:  

Systems  to  detect  driver  drowsiness  and  in  some  cases,  driver  distraction  typically  use 
camera-based systems directed at the driver for eye, face and head feature detection. The next 
most  common  type  of  system  is  based  on  vehicle  control  measures  (typically  the  primary 
controls such as steering, braking and acceleration). Camera-based systems are more likely to 
be available as aftermarket options, whereas systems that utilise data on vehicle control inputs 
are more often found as original equipment on vehicles. There are also other systems that can 
detect  driver  inattention  using  physiological  measures  such  as  heart  and  brain  wave  feature 
detection.  These  systems  are  generally  more  invasive  and  thus  are  used  more  for  research 
purposes.  

Systems  for  monitoring  driver  drowsiness  and  distraction  are  available  now  as  both 
aftermarket  and  original  equipment  in  vehicles.  There  are  a  multitude  of  systems  using 
cameras and vehicle control measures in both types of market. However, an effective system 
will likely need to consist of a combination of systems because of the limitations of individual 
systems, e.g. camera based systems that monitor percentage of eyelid closure (PERCLOS) are 
limited by factors such as ambient light and use of sunglasses or prescription lenses. 

Legislation readiness:  

19   EC,  DGMOVE  (2015).  Study  on  good  practices  for  reducing  road  safety  risks  caused  by  road  user 

distractions. http://ec.europa.eu/transport/road_safety/pdf/behavior/distraction_study.pdf 

20   http://www.sersc.org/journals/IJAST/vol64/7.pdf 

13 

 
                                                 
The wide range of systems available have adopted very different approaches to monitor driver 
drowiness  and  distraction.  This  makes  standardisation  of  devices  and  protocols  difficult  to 
achieve.  Further  work  required  to  determine  how  to  define  and  test  effectiveness  of 
distraction/drowsiness monitoring systems and to define what action the system should take if 
inattention is detected. 

The  expected  benefit  of  using  systems  to  monitor  for  driver  drowsiness  and  distraction  is  a 
reduction  in  the  substantial  number  of  collisions  where  these  issues  are  a  causal  factor.  In 
contrast,  a  possible  dis-benefit  is  that  drivers  may  regard  the  system  as  a  ‘safety  net’  that 
enables  them  to  drive  for  longer  when  tired,  and  may  discourage  taking  regular  breaks  or 
maintaining a healthy cycle of rest and wakefulness. 

Costs  for  these  systems  vary  substantially  with  a  lower  end  of  around  €100  and  upper  end 
€10,000. Therefore benefit to  cost ratio likely  to be greater than one, because of substantial 
potential benefit and assuming system can be developed for reasonable cost. 

For consideration for implementation in the GSR further work is required to: 

  Develop a technology neutral assessment protocol with several phases to improve the 

effectiveness of the detection systems. 

o  Possibly,  Euro  NCAP  could  help  with  this,  by  introduction  of  assessment  of 

systems to detect drowiness and distraction within their rating. 

  Confirm cost benefit analysis 

3.1.6. 

Safety belt reminders 

Since  November  2014,  safety  belt  reminders  are  mandatory  on  the  driver  seat  of  passenger 
cars through the General Safety Regulation. However, it is important to consider mandating 
safety belt reminders to also address the casualty problem associated with non-seat belt use on 
the other seats in passenger cars, as well as on the front seats of all trucks and buses. 

Safety  belt  reminder  systems  detect  the  presence  of  occupants  on  front  and  rear  seating 
positions and monitor their belt status. In order to encourage seat belt use, an audible and/ or 
visual warning is issued if occupants are not wearing a seat belt. 

It is widely recognised that the safety belt is one of the most important and effective vehicle 
safety features and studies have shown that the risk of fatal injury can be reduced by 60% by 
using a seat belt21. Seat belts in the front of the vehicle are designed to, usually in conjunction 
with a frontal airbag, minimise injury by arresting the occupant before any hard structures are 
contacted.  Those  in  the  rear  of  the  vehicle  provide  the  same  function  but  also  prevent 
injurious interaction with the driver and front seat passenger. 

Despite  mandatory  safety  belt  wearing  legislation  in  the  EU,  the  benefit  provided  by  the 
safety belt has not been fully realised yet because a proportion of occupants do not wear their 
seat belt. For example, the seat belt wearing rate for front seat occupants in Italy and Croatia 
was only 64% and 65% respectively. For rear seat passengers, the seat belt wearing rate was 
significantly lower with just 10% and 30% respectively in these two Member States22.  

Research has further shown that even in countries with high seat belt usage rates, the potential 
benefit from improved wearing rates is significant because a large portion of those killed as 
car  occupants  were  indeed  unrestrained.  Seat  belt  reminder  systems  therefore  have  the 
potential to further prevent fatalities or mitigate injuries by increasing the safety belt wearing 
rates across the EU. 

21   WHO (2004) 
22   WHO  2015.  Global  status  report  on  road  safety.  http://www.who.int/violence_injury_prevention/ 

road_safety_status/2015/en/ 

14 

 
                                                 
  Make mandatory for all front and rear seats of M1 and N1 vehicles 
  Make mandatory for all front seats of N2, N3, M2 and M3 vehicles 

o  01/09/2020 for new types 
o  01/09/2022 for all new vehicles 

It  should  be  noted  that  Euro  NCAP  has  rewarded  SBRs  on  driver’s  seat  since  2002  and  all 
seat positions since 2009. This has been effective at encouraging SBRs to be fitted in advance 
of regulation: In 2013, the percentages of vehicles tested by Euro NCAP equipped with SBR 
were  100%  on  driver’s  seat,  95%  on  passenger’s  seat  and  77%  on  rear  seats.    However,  it 
must be remembered that Euro NCAP is voluntary, and changes in reward scheme may result 
in changes to the approach of vehicle manufacturers to future SBR fitment, hence the need for 
regulatory action. 

Technological feasibility:  

SBRs are mandatory for the driver’s seat in passenger cars (M1) and standard equipment for 
other  seating  positions  in  many  passenger  cars.  No  technological  barriers  for  other  vehicle 
types,  but  for  passenger  seats  in  buses  and  coaches  (M2,  M3)  adaptations  of  the  warning 
strategy would be needed. 

Legislation feasibility/readiness:  

Legislative text for the driver’s seat of M1 vehicles exists in UNECE Regulation No 16. The 
Euro  NCAP  test  protocol  sets  out  well  established  and  generally  accepted  requirements  for 
front and rear M1 seating positions. 

Benefit to cost ratios greater than one have been estimated for fitment of SBR to M1 front seat 
passengers and all M2/M3 and N2/N3 vehicle seating positions23. However, for M1 rear seated 
passengers benefit to cost ratio was estimated to be slightly less than one assuming a cost of 
€4 per rear seat.   

For consideration for implementation in the GSR further work is required to: 

  Confirm cost benefit analysis  
  Consider  legislation  for  M1  second  and  other  rear  row  seats  on  the  basis  of  safety 

equality. 

3.1.7.  Frontal Crashes 

Frontal impact crash protection is currently successfully legislated through the General Safety 
Regulation. It is however generally agreed that one of the next major steps to improve frontal 
impact legislation and help worldwide harmonisation is to introduce an integrated set of test 
procedures  containing  both  a  full  width  and  an  offset  test24.  A  full  width  test  is  required  to 
provide  a  high  deceleration  pulse  to  control  the  occupant’s  deceleration  and  check  that  the 
car’s restraint system provides sufficient protection (‘softness’) at high deceleration levels. An 
offset test is required to load one side of the car to check compartment integrity.  

An important step under consideration for the medium to longer term includes an significant 
improvement of protection for the full range of  occupants, in particular for vulnerable older 

23   McCarthy M and Seidl (2014). Benefit assessment for fitment of Seat Belt Reminder (SBR) systems to M1 
passenger  seat  positions  and  to  other  vehicle  types.  CPR1818  Available  from  EU  bookshop 
http://bookshop.europa.eu/en/benefit-assessment-for-fitment-of-seat-belt-reminder-sbr-systems-to-m1-
passenger-seat-positions-and-to-other-vehicle-types-pbNB0214430/ 

24   EEVC (2007). EEVC Approach to Develop Test Procedure(s) for the Improvement of Crash Compatibility 
http://www-

Passenger  Cars. 

conference, 

07-0331. 

paper 

ESV 

no. 

20th 
Between 
nrd.nhtsa.dot.gov/departments/esv/20th 

15 

 
                                                 
occupants, small female occupants, children and rear seated occupants in general. This could 
be addressed by using a full width crash test in combination with the new generation THOR 
crash dummies. Two further  steps would be to address occupant protection in case of small 
overlap  collisions,  as  well  as  that  of  partner  protection  when  two  vehicles  collide  head-on, 
also known as crash compatibility25. 

The Commission is currently finalising a study on the assessment of intended and unintended 
consequences of vehicle adaptations to meet advanced frontal crash test provisions, in order to 
provide  for  a  clear  way  forward  in  terms  of  a  comprehensive  set  of  regulatory  measures 
addressing the outlined issues. 

  Currently off-set impact UNECE R94 is performed for only M1 < 2,500kg maximum 

mass 

  Expand scope to include all M1 and N1 
o  01/09/2022 new types 
o  01/09/2024 all new vehicles 

  Addition of full-width crash test UNECE R137 for M1 and N1 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles 
  Addition of small-overlap crash test for M1 

o  01/09/2022 new types 
o  01/09/2024 all new vehicles 

Technological feasibility:  

Expand scope of Reg 94 

Euro NCAP  have  assessed the frontal crash performance of  a selection of vans  (usually  the 
passenger carrying versions) and pickups using a 64 km/h ODB test. Note that the Reg 94 test 
has a speed of 56 km/h. The good performance observed in these tests clearly show that both 
heavy M1 as well as these N1 vehicles have the possibility to meet the requirements of Reg 94. 

The expansion of the scope is particularly important to further assess the vehicle’s fuel system 
integrity,  protection  against  electrical  shock  (in  case  of  electric  vehicles)  and  door  latch 
resistance, as these are also assessed as part of the test. 

Addition of Reg 137 full width test 

Regulation 137 test speed is 50 km/h which is lower than the 56 km/h for US FMVSS 208. 
The basic  set up consists  of a 50th percentile Hybrid  III male in  the driver’s seat and a 5th 
percentile  Hybrid  III  female  in  the  front  passenger  position.  Both  dummies  must  meet  a 
Thorax  Compression  Criterion  (ThCC)  of  42  mm,  compared  with  the  current  US  chest 
compression of 62 mm for the 50th Hybrid III and 52 mm for the 5th Hybrid III albeit at the 
higher  speed.  By  2020,  the  companion  01  series  of  amendments  would  increase  the  ThCC 
stringency to 34 mm for the 5th female ATD. The fact that WP.29 have adopted Regulation 
137 illustrates that it is technically feasible to meet its requirements.   

Addition of small overlap test 

The technical feasibility of protection against longitudinal small-overlap collisions is clearly 
demonstrated  by  the  response  of  car  manufacturers  to  the  new  IIHS  small  overlap  test 
procedure. 

Legislation feasibility/readiness:  

25   EEVC (2007) 

16 

 
                                                 
Expand scope of Reg 94 

IIHS in the US have used the Regulation 94 test (albeit at a higher test speed of 64 km/h) to 
assess vehicles with a gross vehicle mass in excess of 2,500 kg, thus demonstrating that the 
test is suitable for assessment of vehicles with a higher mass.  

Despite  the  fact  that  they  are  involved  in  similar  types  of  accidents,  in  the  past  EEVC 
recommended  that  the  scope  of  Regulation  94  should  not  be  expanded  to  include  heavier 
vehicles  (>  2,500  kg  &  <  3,500  kg)  because  this  may  increase  their  stiffness  and  hence 
encourage them to become more aggressive26. However, the introduction of a full width test 
should counteract this because if the vehicle is made too stiff then it will be unable to meet the 
requirements of Regulation 137.  

For consideration for implementation in the GSR further work is required to: 

  Perform cost benefit analysis 

Addition of Regulation 137 full width test 

The  Regulation  137  full  width  test  is  suitable  for  regulatory  application.  However,  an  EC 
study that is currently being finalised indicates that the benefits that it may deliver may not be 
significant because most current vehicles woud meet the requirements without modification. 
To deliver benefit the following changes are recommended: 

 

Introduction of the THOR dummy (which is more biofidelic for thorax injuries) into 
the test, note that currently Hybrid III dummies are specified. 

  Changes  to  enforce  the  introduction  of  adaptive  restraint  systems,  in  particular  to 
improve protection of older persons (against thorax injuries) in lower speed impacts. 
With  regard  to  restraint  system  adaptations  (seat  belt  and  airbags),  a  variety  of 
solutions exist already for the detection of and tuning for occupants of different sizes. 
However, fully adaptive restraint systems remain near-to-market and further research 
is needed to determine how adaptable these systems can be made to accident severity 
and how reliable information can be obtained about the severity of the accident about 
to occur. One potential route is to use information from pre-crash / accident avoidance 
systems. 

For consideration for implementation in the GSR further work is required to: 

  Complete  development  of  proposals  to  improve  effectivenesss  of  Regulation  137  as 

noted above. 

  Perform cost benefit analysis 

Note that to counteract the possible disbenefit of expanding the scope of Regulation 94, the 
introdcution of a full width test, i.e. Regulation 137, is recommended. 

Addition of small overlap test 

The  small  overlap  test  used  by  the  IIHS  in  the  USA  since  2012  would  be  suitable  for 
regulatory application. No benefit estimates found for US or Europe. However, benefits could 
be significant because although target population is not that large, effectiveness may be high 
because  countermeasures  likely  to  reduce  high  cost  head  (improved  airbag  coverage  to 
mitigate  effect  of  head  impact  in  A  pillar  region)  and  lower  extremity  injuries  (improved 

26   EEVC  (2000).  EEVC  report  to  European  Commission,  ‘A  review  of  the  front  and  side  Directives’. 

http://www.eevc.net/?site=52 
Edwards et al. (2001). Review of the European frontal and side impact Directives. 17th ESV, http://www-
nrd.nhtsa.dot.gov/pdf/esv/esv17/Proceed/00214.pdf 

17 

 
                                                 
 
passenger compartment integrity). Therefore benefit to cost ratio could likely be greater than 
one. 

For consideration for implementation in the GSR further work is required to: 

• 

Perform cost benefit analysis 

3.1.8. 

Side Crashes 

Side impact still remains an issue on EU roads. Between 29 and 38% of all car crash fatalities 
are in side collisions where 60% are seated at the struck side and 40% at the non-stuck side 27. 
In  particular,  the  ratio  of  fatalities  on  the  non-struck  side  is  very  significant  and  could  be 
influenced  by  occupant-to-occupant  interaction.  It  should  be  noted  however  that  more 
research  regarding  these  vehicle  occupant  deaths  is  needed  before  any  introduction  of 
targeting measures could be considered. 

To  reduce  the  number  of  casualties  in  side  impacts,  EEVC  (WG13  and  21)  performed  cost 
benefit  analysis  for  a  number  of  options28.  One  option  was  to  introduce  an  updated  mobile 
deformable barrier, representing a larger and heavier car impacting into the side of the struck 
vehicle. Another was to introduce a pole side impact test. Also the combination of these was 
considered, however, it was concluded that the combination of these measures would cause a 
combination  of  costs  without  yielding  any  significant  benefit  over  the  improvement  as 
achieved  by  only  the  mandatory  introduction  of  the  pole  side  impact  test.  Therefore,  this 
stand-alone  option  should  be  considered  for  the  review  of  the  General  Safety  Regulation  at 
this stage with  consideration of  measures  to  protect non-struck side occupants  in  the  longer 
term. 

There is currently an exemption for vehicles with high seating positions (e.g. SUVs) because 
little  dummy injury  recorded because  the barrier impacts low down below the height  of the 
seated dummy and thus the test is not worthwhile from the point of view of occupant injury. 
However, fuel system integrity, protection against electrical shock and door opening are also 
assessed  as  part  of  the  test.  To  assess  these  factors  it  is  proposed  that  the  exemption  is 
removed.  Note  that  the  test  for  currently  exempted  vehicles  could  be  performed  without 
dummies to reduce cost. 

  Currently  only  side  impact  UNECE  R95  is  performed  which  consists  of  a  mobile 

barrier test which represents being impacted by another vehicle 

  Expand scope to include all M1 and N1, i.e. remove current exemption. 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles 

  Addition of pole impact crash test UNECE R135. 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles 

  Addition of far-side occupant protection 

o  Test protocol needs to be established 
  01/09/2022 new types 
  01/09/2024 all new vehicles 

Technological feasibility:  

Addition of Pole impact test (Regulation 135) 

27   EEVC (2010): WG13: A Review and Evaluation of Options for Enhanced Side Impact Protection.  
28   EEVC  (2010):  WG13  &  WG21:  Analysis  to  estimate  likely  benefits  and  costs  for  the  EU  of  modifying 

Regulation 95.  

18 

 
                                                 
Vehicles perform well in the current Euro NCAP pole test, which is similar to the Regulation 
135  one,  which  demonstrates  clearly  that  current  vehicles  can  meet  the  proposed  test 
requirements. 

Addition of far-side occupant protection 

There  now  seems  to  be  a  sufficient  technology  base  so  that  far-side  protection  can  be 
evaluated  and  rated  by  side  impact  testing.  A  front  centre  side  airbag  has  recently  been 
introduced in three top range crossover SUVs. 

Legislation feasibility/readiness:  

Addition of Pole impact test 
The Regulation 135 pole impact test is suitable for regulatory application. An EEVC study29. 
indicated  that  the  benefit  to  cost  ratio  of  implementing  a  pole  test  may  be  less  than  one. 
However, it should be noted that the costs estimated in this study were thought to be too high 
by  some  stakeholders  and  this  study  did  not  consider  potential  extra  benefits  related  to  the 
mitigation  of  ejection  (partial)  in  rollover  accidents  that  curtain  aitrbags  with  adequate 
coverage  could  offer.  For  this  reason  it  is  proposed  that  an  additional  requirement  for  an 
assessment  of  the  window  curtain  airbag  coverage  is  added  to  the  Regulation  135  for 
implementation  in  the EU. This  requirement could be based on the Euro NCAP one, which 
assesses  the  inflated  airbag  position  with  respect  to  a  zone  defined  by  the  seating  and  head 
positions  of  5th  percentile  female  and  95th  percentile  male  dummies.Note  that  an  exemption 
could  be  given  for  vehicles  for  which  fitment  of  a  curtain  bag  is  not  practical,  e.g. 
convertibles. 

For consideration for implementation in the GSR further work is required to: 

  Develop airbag coverage requirement and associated exemptions needed. 
  Repeat cost benefit analysis with consideration of ejection mitigation benefits. 

Addition of far-side occupant protection 

There are currently no requirements to fit far-side impact protection systems in vehicles, and 
consumer rating programmes such as Euro NCAP do not have a test that covers this scenario. 

From  a  review  of  the  literature  its  was  estimated  that  in  Europe  by  fitment  of  far-side 
occupant  protection  it  could  be  possible  that  up  to  670  fatalities  and  up  to  4,600  seriously 
injured casualties may be prevented annually, with a monetary value of €1.2 to €1.9 billion. 
Component cost with installation was estimated to be about $200, so the annual cost to equip 
each new car each year was calcualted to be about €1.8 billion. This gives a beenfit to cost 
ratio in the range of 0.6 to 1.1, but likely to be greater than one because cost estiamte thought 
to be high. 

For consideration for implementation in the GSR further work is required to: 

  Develop assessment protocol. (Note that Euro NCAP plan to introduce assessment of 

far-side occupant protection, so will need to develop protocol to enable this). 

  Perform cost benefit analysis. 

3.1.9.  Rear Crashes 

A rear-end collision is defined as a crash in which the front of one vehicle collides with the 
rear of another vehicle and it has been reported that 19% of all passenger cars involved in an 

29   EEVC  (2010):  WG13  &  WG21:  Analysis  to  estimate  likely  benefits  and  costs  for  the  EU  of  modifying 

Regulation 95.  

19 

 
                                                 
accident have at least one rear impact30. One of the most detailed sources of fatality rates from 
vehicle  fire  data  was  collected  by  the  Swedish  Transport  Administration  between  1998  and 
2008.  In-depth  data  was  recorded  from  fatal  crashes  involving  passenger  cars,  SUVs,  vans 
and  minibuses.  Viklund  et  al.  (2013)31  summarised  the  findings  of  the  study  relevant  to 
vehicle  fires.  In  total,  181  fire  related  deaths  caused  by  133  separate  road  crashes  were 
recorded  nationally,  which  accounted  for  5%  of  all  road  fatalities  that  occurred  during  this 
period.  Fire and smoke were ruled as the primary cause of death in 55 cases. The source of 
the  fire  was  not  identified  for  61  of  the  133  cases.  However,  of  the  remaining  72  cases,  16 
fires were found to originate from the fuel tank. Two fuel tank fires were found to be caused 
by rear end impacts. 

Rear  impact  testing  is  not  mandatory  in  the  EU,  but  it  has  been  regulated  in  the  USA  and 
Japan for many years, notably linked to fire-related deaths. Therfore it may be expected that 
many  vehicles  on  the  EU  roads  currently  already  comply  with  one  or  both  countries’ 
standards. Modifying the EU legislation to include a compulsory rear impact test would aid 
the process of harmonising vehicle regulations. For this purpose, it is recommended that the 
rear impact test in UNECE R34 is made mandatory for the EU (with an exemptions to reduce 
cost). Also R34 should be updated to include post crash electrical safety as in Regulations 94 
and 95 for the rear impact test. 

A  mandatory  rear  impact  test  could  be  deemed  much  less  relevant  if  the  fuel  tank  is  not 
located near the rear of the vehicle, notably behind the rear axle. We should however also not 
forget that post-crash electric safety should also be assessed as a part of the rear impact test 
when  high  voltage  parts  of  electrically  propelled  vehicles  are  located  at  their  rear.  These 
conditions  should  therefore  be  incorporated  in  the  existing  regulation  that  can  then  be 
introduced on a mandatory basis as part of the review of the General Safety Regulation. 

  Currently  no  rear  impact  test  is  required  to  be  performed  to  comply  within  the  EU 

legislation 

  Modify UNECE R34 (revision 3) to add assessment of post crash electrical safety for 

rear impact test as in Regulations 94 and 95. 

  Make rear impact crash test in UNECE R34 mandatory, i.e. accede to R34 revision 3. 

o  Make mandatory for M1 and N1 vehicles 
o  Add exemption for vehicles which do not have fuel storage, fuel supply lines 

and/or high voltage components located near rear axle.  

  01/09/2020 new types 
  01/09/2022 all new vehicles 

Technological feasibility:  

There  are  no  principal  concerns  regarding  techncial  feasiblity.  Vehicles  sold  in  the  USA 
currently  have  to  comply  with  the  FMVSS  301  rear-impact  test.  Japan  also  requires  a  rear 
impact test and has recently acceded to UNECE Regulation No 34. It is not known how many 
manufacturers  volunteer  to  carry  out  the  optional  UNECE  Regulation  No  34  assessment  on 
their vehicles.  

Legislation feasibility/readiness:  

30 

Eis V, Sferco R, Fay P (2005). A Detailed Analysis of the Characteristics of European Rear Impacts. 19th 
ESV 

31   Viklund A, Björnstig J, Larsson M and Björnstig U (2013). Car Crash Fatalities Associated With Fire in 

Sweden. Traffic Injury Prevention (2013), 14, 823–827. 

20 

 
                                                 
UNECE Regulation 34 revision 3 contains a mandatory rear impact test. However, it does not 
include assessment of post crash electrical safety which needs to be added so that consistent 
with Regulations 94 and 95.  

More detailed analysis is needed to quantify benefits and costs to enable cost benefit analysis 
to be performed. However, it hsould be noted that at present theer is only mandatory testing 
for fuel tanks at a component level, so it is likely that the realtively good performance in the 
field  is  due  to  manufacturer  good  practice.  Ideally,  this  critical  safety  issue  should  be 
formalised in a more appropriate manner. 

For consideration for implementation in the GSR further work is required to: 

  Add assessment of post crash electrical safety for rear impact test in Regulation 34 as 

in Regulations 94 and 95. 

  Develop  exemption  for  vehicles  which  do  not  have  fuel  storage,  fuel  supply  lines 

and/or high voltage components located near rear axle. 
Identify further cost and benefit information and perform cost benefit analysis 

 

3.1.10.  Alcohol Interlock Devices 

Alcohol interlock devices require a vehicle operator to provide a breath sample or use a finger 
touch  sensor  and  prevent  the  vehicle  ignition  from  operating  if  alcohol  above  a  pre-defined 
threshold is detected. Application of alcohol interlock devices is intended to reduce collision 
risk by restricting the opportunity for drivers to operate vehicles when under the influence of 
alcohol. 

Despite lower alcohol limits, increased enforcement and awareness campaigns, drink-driving 
is  still  a  major  safety  problem.  Drink-driving  accounts  for  20-28%  of  all  road  accidents, 
deaths  and  injuries  on  European  roads.  The  vast  majority  of  the  accidents  in  which  drink-
driving  is  involved,  namely  75%,  is  caused  by  a  small  group  of  offenders  thought  to  be 
around  1%  of  the  driving  population32.  For  this  reason,  it  is  difficult  to  justify  mandatory 
installation of these devices from a cost-effectiveness standpoint. 

However, the European Committee for Electrotechnical Standardisation CENELEC has been 
working on the development of a standardisation scheme as regards the connection interface 
for  motor-vehicles.  This  initiative  concerns  a  mandatory  and  standard  format  of  highly 
detailed electrical connection information to be provided in standardised format by the vehicle 
manufacturers to authorised installers, as part of vehicle type-approval provisions, and it has 
received  broad  support  by  stakeholders.  The  relevant  CENELEC  standard  is  expected  to 
become  available  in  the  short  term  and  this  will  greatly  help  to  facilitate  easier  fitment  of 
alcohol  interlocks  to  future  vehicles.  It  has  been  devloped  in  cooperation  with  the 
Commission,  device  manufacturers  and  vehicle  manufacturers,  so  it  is  tailor-made  for 
incorporation  into  EU  legislation.  Clearly,  the  focus  of  the  review  of  the  General  Safety 
Regulation should be on this aspect. 

  Make  provisions  of  CEN  Standard  504536-7  (device  interface)  mandatory  for  all  M 

and N vehicles 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles. 

Technological feasibility:  

32   http://ec.europa.eu/transport/road_safety/pdf/behavior/study_alcohol_interlock.pdf 

21 

 
                                                 
Alcohol interlocks exist on the market and can be retrofitted to vehicles, for example those of 
drunk-driving  offenders.  Breath-based  interlocks  have  been  in  use  since  the  1970s; 
transdermal (touch-based) solutions were developed recently. 

Legislation feasibility/readiness:  

The CENELEC standard 50436 (expected to become available in the short term) can provide 
the  basis  to  ensure  compatibility  between  interlock  and  vehicle  ignition  system  to  avoid 
vehicle designs that do not allow installation of alcohol interlocks.  
Ecorys  (2014)33  estimated  the  casualty  reduction  figures  for  alcohol  interlocks  deployed 
across  four  groups  based  on  2010  fatality  statistics  and  estimated  benefit-cost  ratios.  The 
ratios  estimated  were  greater  than  one  for  the  offender  (1.0  -2.8)  and  goods  vehicle  (1.4) 
groups. However they were less than one for the buses and coaches (0.3) and all passenger car 
groups (0.8 – 1.3). 

For consideration for implementation in the GSR further work is required to: 

  Perform  cost  benefit  analysis  for  mandatory  implementation  of  CENELEC  standard 

50436. 

3.1.11.  Crash Event Data Recorder 

Event data recorders record a range of vehicle data over a short timeframe before, during and 
after  a  triggering,  usually  by  the  deployment  of  an  airbag,  caused  by  a  vehicle  crash.  It 
contains  critical  crash  related  information  such  as  vehicle  speed,  state  of  restraints  and 
braking system as well as other relevant vehicle data at the time of the accident. 
In  a  recent  study34,  it  was  concluded  that  event  data  recorders  appeared  to  largely  fitted  to 
passenger  cars  and  vans  already,  so  additional  costs  resulting  from  legislative  action  were 
deemed  negligible.  There  was  evidence  found  on  the  effect  of  device  fitment  on  driving 
behaviour for commercial fleets. If similar effects would apply to private fleets, or if the effect 
on safety would be greater than predicted by the estimates for commercial fleets, this would 
have  very  large  benefits  associated  with  monetised  casualty  savings.  Some  other  important 
potential  benefits  could  not  be  monetised,  namely  improved  accident  data  leading  to 
enhancements  in  safety  and  benefits  relating  to  access  to  justice.  However,  it  was  however 
that these could represent very significant benefits as well. 

As cost-effectiveness appear to be supported, in addition to the benefits that significantly aid 
future  road  safety  analysis  in  general,  the  review  of  the  General  Safety  Regulation  should 
strongly consider the introduction of this mandatory feature. 

  Technology widely available 

o  Consider harmonisation with US Part 563 prescriptions 

  Cost-effective measure for accident investigation and road safety research 
  Make mandatory for M1 and N1 vehicles 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles 

Technological feasibility:  

EDR technology is already fitted to most passenger cars and car-derived vans in the USA and 
Europe,  which  clearly  demonstrates  technical  feasibility.  However,  in  Europe,  access  to  the 

33   Ecorys  (2014).  Study  on  the  prevention  of  drink-driving  by  the  use  of  alcohol  interlock  devices. 

http://ec.europa.eu/transport/road_safety/pdf/behavior/study_alcohol_interlock.pdf 

34   http://ec.europa.eu/transport/road_safety/pdf/vehicles/study_edr_2014.pdf 

22 

 
                                                 
data is deliberately blocked in many cases. For heavy vehicles, the fitment of EDRs appears 
feasible, but is not yet widespread because the airbag and accident detection system fitment 
rate is low. 

Legislation feasibility/readiness:  

For  light  vehicles,  compliance  with  EDR  standards  has  recently  become  mandatory  in  the 
USA,  if  EDR  is  indeed  fitted,  where  CFR  49  Part  563  defines  minimum  performance 
requirements  and  structure  of  and  access  to  the  data.  These  minimum  requirements  on  data 
could  be  duplicated  in  Europe  or  manufacturers  could  be  required  to  make  available  the 
method of access so that any provider could make a vehicle or brand specific suitable tool (i.e. 
open access).  

Real  benefits  identified,  although  difficult  to  monetise.  A  recent  study  for  EC  DG  MOVE 
estimated benefit to cost ratio for fitment of EDR  

  M1 vehicles  0 to 5.7, central estimate 0.1 
  N1 vehicles 0 to 6.6, central estimate 1.0 
  M2/M3 vehicles 0 to 4, central estimate 2 
  N2/N3 vehicles 0 to 4.6, central estimate 2.3 

However,  most  new  M1  and  N1  European  vehicles  have  EDR  functionality  although  it  is 
currently not accessible in most, so most of the cost has already been spent. Therefore, benefit 
to  cost  ratio  for  the  M1/N1  category  of  vehicles  should  be  greater  than  one  if  approach  is 
taken to legislate minimum performance requirements and structure of and access to the data 
as the US CFR 49 Part 563 or require manufacturers to make available the method of access 
to  the  EDR  installed  so  that  any  provider  could  make  a  suitable  tool  to  access  it  (i.e.  open 
access). 

For consideration for implementation in the GSR further work is required to: 

  Perform cost benefit analysis 

3.1.12.  Tyre Pressure Monitoring 

Severe  tyre  under-inflation  contributes  to  accident  causation.  A  pressure  deviation  of  more 
than 15% generally results in noticeable change of tyre properties which affects the wear rate 
of  the  tyre  and  the  braking  and  handling  performance  of  the  vehicle.  The  increased  heat 
generation  due  to  tyre  under-inflation  reduces  the  maximum  lateral  tyre  force,  creating  a 
further safety risk. Proper tyre pressure also reduces rolling resistance and thus saves fuel and 
reduces CO2 emissions.  Tyre  pressure monitoring has  therefore been  mandatory  for all  new 
passenger cars sold since 2014. A recent study on tyre safety in general35 supported an update 
of the relevant provisions of the existing regulation that is currently part of the General Safety 
Regulation, in order to avoid regulatory loopholes and to improve its effectiveness in terms of 
vehicle safety. 

Light  and  heavy  commercial  vehicles  as  well  as  buses  are  currently  not  subject  to  tyre 
pressure  monitoring  requirements  even  though  such  systems  could  potentially  contribute  to 
improved vehicle safety and reduce fuel consumption and CO2 emissions as well. The review 
of current products and their suppliers concluded that tyre pressure monitoring for application 
in  vans,  trucks  and  buses  is  technically  and  economically  mature  at  this  stage36.  Based  on 
various  studies,  speed  related  accidents  are  found  to  account  for  almost  20%  of  heavy  duty 
vehicle  accidents.  In  accidents  that involve  deaths  or  severe  injuries  of truck  occupants  this 

35   http://ec.europa.eu/transport/road_safety/pdf/vehicles/study_tyres_2014.pdf 
36   http://ec.europa.eu/clima/policies/transport/vehicles/heavy/docs/tno_2013_final_report_en.pdf 

23 

 
                                                 
share  is  in  the  range  of  7.5  to  10%.  A  reduction  in  the  number  of  speed  and  tyre  related 
accidents due to proper tyre pressure conditioning should be expected and it is estimated that 
properly  maintaining  the  tyre  inflation  pressure  can  reduce  the  number  of  speed  and  tyre 
related accidents  by  4%  to  20%, and  thus  the  total  number  of  accidents  by  0.8%  up  to  4%, 
which is still significant. Adding mandatory tyre pressure monitoring on vans, trucks, buses 
and heavy trailers should therefore be considered to further improve road safety. 

  Make TPM mandatory for all M and N vehicles and O3 and O4 trailers 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles 

Technological feasibility:  

Tyre Pressure Monitoring Systems (TPMS) report real-time tyre-pressure information to the 
driver  of  the  vehicle,  either  via  a  gauge,  a  pictogram  display,  or  a  simple  low-pressure 
warning light. TPMS can be divided into two different types — direct (dTPMS) and indirect 
(iTPMS).  TPMS  are  provided  both  at  an  OEM  (factory)  level  as  well  as  an  aftermarket 
solution.Indirect  TPMS  do  not  use  physical  pressure  sensors  but  estimate  air  pressures  by 
monitoring individual wheel rotational speeds and other signals available outside of the tyre 
itself.  First  generation  iTPMS  systems  utilize  the  effect  that  an  under-inflated  tyre  has  a 
slightly  smaller  diameter  (and  hence  higher  angular  velocity)  than  a  correctly  inflated  one. 
Second generation iTPMS can also detect simultaneous under-inflation in up to all four tyres 
using  spectrum  analysis  of  rotation  speeds  of  individual  wheels.  The  spectrum  analysis  is 
based on the principle that certain eigenforms and frequencies of the tyre/wheel assembly are 
highly sensitive to the inflation pressure. These oscillations can hence be monitored through 
advanced  signal  processing  of  the  wheel  speed  signals.  Current    iTPMS  consist  of  software 
modules being integrated into the ABS/ESC units. Direct TPMS employ pressure sensors on 
each tyre, either internal or external. The sensors physically measure the tyre pressure in each 
tyre and report it to the vehicle’s instrument cluster or a corresponding monitor. Some units 
measure and alert temperatures of the tyre as well. These systems can identify under-inflation 
in  any  combination,  be  it  one  tyre  or  all,  simultaneously.  Although  the  systems  vary  in 
transmitting  options,  many  dTPMS  products  (both  OEM  and  aftermarket  solutions)  can 
display real time tyre pressures at each location monitored whether the vehicle is moving or 
parked.  

A study for EC DG Clima which reviewed current products and their suppliers concluded that 
tyre  pressure  monitoring  for  application  in  vans,  trucks  and  buses  is  technically  and 
economically mature at this stage37. 

Ideally TPMS: 

  Should  be  capable  of  detecting  over  a  wide  range  of  road  and  environmental 

conditions 

  Should not be possible to deactivate 
  For  M1/N1  should  detect  a  pressure  of  less  than  1.5  bar  or  detect  incorrect  set/reset 

attempt 

  Should  cover  any  tyre  of  approved  size,  including  after-market  (different  brand) 

replacement tyres 

o  On this basis UNECE Regulation 64, Annex 5, clause 1.4.6 “…vehicle shall be 
tested  with  the  tyres  installed  on  the  vehicle  according  to  the  vehicle 
manufacturer’s recommendation…” should be deleted. 

37   http://ec.europa.eu/clima/policies/transport/vehicles/heavy/docs/tno_2013_final_report_en.pdf 

24 

 
                                                 
Legislation feasibility/readiness:  

UNECE  Regulation  64  contains  the  relevant  prescriptions  that  can  serve  as  a  basis  for  the 
inclusion of other vehicle categories, provided that shortcomings in the regulatory text, noted 
above, are addressed. 

The  benefits  for  fitment  of  TPMS  to  for  light  commercial  and  heavy  duty  vehicles  can  be 
divided into two parts;  

  Reduction in number of accidents 
  Reduction in fuel consumption and CO2 emissions 

The  study  for  EC  DG  Clima32  investigated  benefits  and  costs  for  for  mandatory  fitment  of 
TPMS for light commercial and heavy duty vehicles in the EU. It was estimated that properly 
maintaining  the  tyre  inflation  pressure  can  reduce  the  number  of  speed  and  tyre  related 
accidents by 4% to 20%, and thus the total number of accidents by 0.8% up to 4%, which is 
still significant. This equates to a societal cost reduction of 11 to 58 M€ per year.  

It was also estimated that for OEM fitted TPMS (which mandatory fitment would deliver) and 
even  with  a  50%  response  to  tyre  pressure  warnings  TPMS  would  be  cost  effective  with  a 
payback  time  of  generally  3.5  years  or  less  and  associated  benefit  of  CO2  reductions,  with 
negative  abatement  costs.  For  these  estimations  an  oil  price  of  $100  a  barrel  was  assumed. 
The largest benefit to cost ratios were for the long haul truck and trailer, regional trucks and 
service / delivery vans. For these vehicle categories TPMS was cost effective for all scenarios 
considered which included an assumption of 50% lower fuel savings and using current costs 
for TPMS. The smallest benefit to cost ratio was for municipal buses.  

For consideration for implementation in the GSR further work is required to: 

  Confirm cost benefit analysis 

3.2. 

TRUCKS AND BUSES 

3.2.1.  Front-end Design and Direct Vision 

For reasons related to efficient use of available space, mainly due to limitation of truck and 
trailer  dimensions  when  driving  within  the  EU,  truck  drivers  are  seated  high  on  top  of  the 
engine  since  many  decades.  This  high  seating  position  is  highly  detrimental  for  the  direct 
vision  capability  of  the  driver,  especially  concerning  what  happens  in  the  vicinity  of  the 
truck’s  front  end.  Whilst  representing  only  3%  of  vehicles  on  EU  roads,  trucks  have  been 
involved in a disproportionate number of collisions, namely over 15%, killing more than 4000 
people  in  200938.  As  regards  other  vulnerable  road  users,  trucks  are  also  disproportionately 
involved in fatal collisions with pedestrians and cyclists39. 

For  the  abovementioned  reasons,  and  taking  into  account  that  the  current  ‘brick’  shaped 
cabins  have  the  least  aerodynamic  shape,  the  Commission  proposed  to  grant  derogations  to 
the  maximum  Weights  and  Dimensions  as  laid  down  in  Directive  96/53/EC40.  The 
Commission proposal, which was adopted by the European Parliament and the Council on 6 
May  2015  under  Directive  (EU)  2015/71941,  provides  the  possibility,  subject  to  certain 
conditions, to extend the length of cabs and thus to provide manufacturers with more space to 
design safer and cleaner trucks. 

38   http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52013SC0108&from=EN 
39   https://consultations.tfl.gov.uk/roads/safer-lorries 
40   OJ L 235, 17.9.1996, p. 59 
41   OJ L 115, 6.5.2015, p. 1 

25 

 
                                                 
It has been suggested that either better mirrors and detection systems or simply the addition of 
side  windows  in  the  lower  portion  of  truck  cab  doors  could  be  required  to  improve  the 
situation,  but  the  effectiveness  of  such  short-term  measures  may  not  be  sufficient.  It  has 
however been suggested that a comprehensive improvement of direct vision of truck drivers 
has the potential to greatly contribute to much improved safety for vulnerable pedestrians and 
bicyclists42.  This  hypothesis  is  supported  through  knowledge  about  the  current  strict 
passenger car forward and side vision requirements that virtually eliminate any of such issues 
related to the non-visibility of pedestrians and bicyclists. Hence, it would be logical to aim for 
similar  comprehensive  direct  vision  requirements  for  all  motor-vehicle  categories,  with  due 
lead-time for introduction. 
Modified  truck  cabs  can  furthermore  be  made  much  more  aerodynamic43  than  conventional 
cabs are today  and this translates into  great benefits in  terms of fuel consumption and CO2. 
Directive  (EU)  2015/719  provides  the  possibility  to  extend  cabs  provided  that  conditions 
related to improved aerodynalics and visibility, reduced damage or injury to other road users 
in cases of collisions as well as safety and comfort for drivers are taken into account44. 

For reasons related to efficient use of available space, mainly due to limitation of truck and 
trailer dimensions when driving within the EU, for many decades trucks have been designed 
such that the drivers are seated high on top of the engine. This high seating position is highly 
detrimental for the direct vision capability of the driver, especially concerning what happens 
in the vicinity of the truck’s front end. Whilst representing only 3% of vehicles on EU roads, 
trucks  have  been  involved  in  a  disproportionate  number  of  collisions,  namely  over  15%, 
killing more than 4,000 people in 200945. As regards other vulnerable road users, trucks are 
also disproportionately involved in fatal collisions with pedestrians and cyclists46. 

It has been suggested that either better mirrors and detection systems or simply the addition of 
side  windows  in  the  lower  portion  of  truck  cab  doors  could  be  required  to  improve  the 
situation,  but  the  effectiveness  of  such  short-term  measures  may  not  be  sufficient.  It  has 
however been clearly suggested that a comprehensive improvement of direct vision of truck 
drivers  has  the  potential  to  greatly  contribute  to  much  improved  safety  for  vulnerable 
pedestrians  and  bicyclists47.  This  hypothesis  is  supported  though  our  knowledge  about  the 
current strict passenger car forward and side vision requirements that virtually eliminate any 
of  such  issues  related  to  the  non-visibility  of  pedestrians  and  bicyclists.  Hence,  it  would  be 
logical  to  aim  for  similar  comprehensive  direct  vision  requirements  for  all  motor-vehicle 
categories,  especially  if  this  can  be  supported  from  a  cost-effectiveness  standpoint 
underpinning this aspect of the General Safety Regulation review process. 

  Focus on direct vision requirements to reduce blind spots to improve safety for VRUs 

such as pedestrians and cyclists 

o  Facilitate through Masses and Dimensions Directive (EU) 2015/719 
o  Once  improved  safety  requirements  for  longer  cabs  have  been  developed, 
consideration  can  be  given  to  whether  it  is  appropriate  to  apply  them  to 
vehicles  which  do  not  benefit  from  the  length  extension  as  mentioned  in 
Directive (EU) 2015/719. 

 

In the short term deploy camera or detection systems to reduce blind spots 

42   http://etsc.eu/weights-and-dimensions-of-heavy-goods-vehicles-maximising-safety/ 
43   http://www.transportenvironment.org/sites/te/files/media/2012%2002%20FKA%20Smart%20Cab% 

20study_web.pdf 

44   Article 9 of Directive (EU) 2015/719 
45 
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52013SC0108&from=EN 
46 
http://etsc.eu/weights-and-dimensions-of-heavy-goods-vehicles-maximising-safety/ 
47   http://etsc.eu/weights-and-dimensions-of-heavy-goods-vehicles-maximising-safety/ 

26 

 
                                                 
o  For  this  action  the  link  to  Directive  (EU)  2015/719  should  be  further 

investigated 

o  This action is envisaged as a complimentary measure only to improved direct 

vision action above in the long-term 

  Make mandatory for M2, M3, N2 and N3 vehicles 

o  01/09/2020 new types – Camera and Detection (no length advantage) 
o  01/09/2022 all new vehicles – Camera and Detection (no length advantage) 
o  01/09/2028 new types – Direct Vision (length advantage, encouraging vehicle 

manufacturers to bring to market earlier) 

o  No new vehicles date foreseen due to impact on overall truck cab designs 

Technological feasibility:  

The  suggested  improvements  are  technically  feasible  but  would  need  to  be  developed  and 
implemented  by  the  vehicle  manufacturers  in  the  course  of  a  cab  re-design  because  they 
constitute major design changes. However, much progress has been made. Some designs with 
much  improved  direct  vision  are  already  in  production  such  as  the  Mercedes-Benz  Econic. 
This low-entry vehicle has a particularly large windscreen area and improved glazed areas to 
the side. Unfortunately, the design leads to certain limitations (engine size is limited because 
of  packaging  problems;  no  hydraulic  cab  support),  which  limits  its  use  to  regional  services 
and doesn’t allow use in long-haul traffic. 

Legislation feasibility/readiness:  

A  mandatory  direct  vision  standard  for  HGVs  could  potentially  be  developed  with  limited 
effort  and  could  deliver  high  benefits.  Previous  research to  inform  the  legislative  process is 
available. 

There  is  broad  agreement  among  experts  that  improved  direct  vision  would  be  effective  in 
preventing casualties. It is predicted that improved direct vision could reduce the number of 
VRU fatalities by up to 553 per year in the EU2.  

For consideration for implementation in the GSR further work is required to: 

  Develop direct vision standard for HGVs 
  Perform cost benefit analysis 

3.2.2.  Truck Rear Underrun Protection 

Accident data and crash tests have shown that rear under-run protection devices as currently 
required by legislation appear to  be inadequate for collisions of  modern  passenger cars into 
the  rear  end  of  a  truck  or  trailer,  in  particular  at  speeds  exceeding  50  km/h48.  For  better 
performance,  improvements  in  the  strength  of  these  devices  and  better  vertical  geometric 
alignment  with  the  main  structures  of  M1  vehicles  are  needed.  The  relevant  legislation  is 
currently undergoing a parallel update that is supported by this review process of the General 
Safety Regulation. 

  Work under UNECE is well advanced 
  03 Series of amendments to UNECE R58 proposed 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles 

Technological feasibility:  

48   http://ec.europa.eu/transport/road_safety/pdf/projects/vc-compat.pdf 

27 

 
                                                 
Technically,  it  is  feasible  to  increase  the  strength  of  a  rear-underrun  protection  device  and 
decrease its ground clearance. However, practically this involves issues such as the effect of 
lowering the ground clearance on departure angles and the influence of this on the vehicle’s 
operability (related to cost-benefit rather than feasibility). 

Legislation feasibility/readiness:  

A  proposal  to  amend  UNECE  Regulation  No  58  (Rev  3)  is  being  considered  in  Geneva 
(changing  test  loads  and  ground  clearance)  currently.  Introduction  of  an  additional  load 
condition  of  100  kN  applied  simultaneously  to  three  points,  as  suggested  by  Smith  et  al. 
(2008)49, might be necessary to ensure adequate strength of device. 

For fitment of a device with adequate strength, Smith et al. (2008) estimated a benefit for the 
EU  of  between  43  and  93  fatalities  and  694  and  2,063  serious  injuries  prevented  per  year. 
This equated to a beenfit to cost ratio of 0.6 to 14.8 using best cost estimates. 

For consideration for implementation in the GSR further work is required to: 

  Check load conditions proposed for Regulation 58 rev 3 are adequate. 
  Confirm cost benefit analysis. 

3.2.3.  Truck Lateral Protection 

Heavy  goods  vehicles  and  their  trailers  are  presently  required  to  be  fitted  with  structures to 
reduce  the  open  space  ahead  of  the  rear  axle(s)  to  provide  protection  to  pedestrians  and 
cyclists in collision with the side of such vehicles, reducing the likelihood of them being run 
over.  However,  the  current  legislative  text  allows  for  broad  exemptions  to  fitting  these 
structures, therefore action has now been taken on the relevant UNECE level to improve this 
situation, that is supported by this review process of the General Safety Regulation. 

  Work under UNECE is ongoing 
  02 Series of amendments to UNECE R73 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles 

Technological feasibility:  

The exemptions are primarily based on feasibility for certain types and uses of vehicle. Before 
removing  the  exemptions,  some  formal  consideration  should  be  given  to  the  feasibility  of 
meeting  the  functional  requirements  for  vehicles  with  the  addition  of  side  guards.  For 
example, some off-road activities could be completed with side guards, whilst other off-road 
activities  may  be  impossible  without  ground  clearance  which  prevents  the  fitment  of  side 
guards.  

Legislation feasibility/readiness:  

No  barriers  regarding  legislative  feasibility.  However,  it  is  recommended  in  addition  to 
consider amendments to existing side-guard requirements in order to make their designs more 
effective.  
Potential annual monetary benefits were estimated to range from €7.8M to €20.3M2 by Hynd 
et al (2015). Also, this study estimated a beenfit to cost ratio, for fitting the currently exempt 
N2 and N3 vehicles with lateral protection, would lie in the range from 0.06 to 1.37. 

49   Smith T, Grover C, Gibson T, Donaldson W and Knight I (2008). Development of test procedures, limit 
values, costs and benefits for proposals to improve the performance of rear underrun protection for trucks, 
ENTR  05/17.  https://circabc.europa.eu/sd/a/bf5be9b8-54d5-42be-866d-a1c47e81cad4/20140903-121938_ 
PPR317_RUP_Final_report_March_08.pdf 

28 

 
                                                 
In summary, benefit to cost ratio likely to be less than one for vehicles that genuinely need 
either  an  exemption  or  adjustable  side  guards.  However,  the  classification  of  these  vehicles 
should  be  improved,  so  that  the  vehicles  that  do  not  genuinely  need  an  exemption  are 
identified better and for these vehicles the benefit to cost ratio is likely to be greater than one.  

For consideration for implementation in the GSR further work is required to: 

  Develop performance requirements for side guards 
  Confirm cost benefit analysis 

3.2.4.  Fire Safety for Buses 

Bus  safety  legislation  is  regulated  on  EU  level  through  the  implementation  of  relevant 
UNECE  regulations.  The  situation  for  bus  fire  safety  has  been  under  review  which  is  now 
leading to a foreseen mandatory introduction of automatic fire extinguishers in certain classes 
of  buses  through  amendments  to  UNECE  Regulation  107.  In  addition,  in  response  to  fire 
incidents  with  CNG  powered  buses,  an  amendment  to  UNECE  Regulation  110  has  been 
proposed. The proposal is to regulate the direction of discharging the pressure relief devices 
of the CNG containers based on existing provisions within Regulation (EU) No. 79/2009 on 
hydrogen  vehicles.  These  developments  are  being  supported  by  this  review  process  of  the 
General Safety Regulation which is underway in parallel. 

  CNG: 02 Series of Amendments to UNECE R110 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles 

  Fire suppression: 07 Series of amendments to UNECE R107 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles 

Technological feasibility:  

CNG fire requirements 

Experts believe that the changes brought into force by an amended version of UN Regulation 
110 would be technically feasible since they are based on provisions within Regulation (EC) 
No.  79/2009  on  hydrogen  vehicles,  which  use  similar  technologies  to  store  and  vent 
hydrogen. 

Fire suppression 

Automatic fire extinguishing systems for vehicles are commercially available as off-the-shelf 
items  and  are  therefore  technically  feasible.  The  systems  are  available  with  several 
extinguishing agents which no longer damage the ozone layer.  

Legislation feasibility/readiness:  

CNG fire requirements 

Proposals  for  amendments  to  the  relevant  UNECE  Regulations  are  available.  For 
consideration for implementation in the GSR further work is required to: 

  Perform cost benefit analysis 

Fire suppression 

No  standard  type-approval  test  procedures  for  fire  extinguishing  systems  exist  yet,  but  the 
road  administrations  from  Sweden  and  Norway  have  carried  out  research  and  proposed 
amendments  to  UNECE  regulation  No  107.  These  amendments  were  prepared  to  introduce 

29 

 
fire  suppression  systems  for  buses  and  coaches  upon  detection  of  fire  in  the  engine  and/or 
heater compartment.  

Fire suppression systems have been required by insurers in some countries and have proved 
effective. More analysis is required to identify benefits and calculate the benefit to cost ratio 
for implementation. 

For consideration for implementation in the GSR further work is required to: 

  Perform cost benefit analysis 

3.3. 

PEDESTRIAN AND CYCLIST SAFETY 

3.3.1.  Pedestrian and Cyclist Detection 

This  item  is  closely  linked  to  Section  3.1.1.  on  Automatic  Emergency  Braking,  because 
pedestrian  and  cyclist  detection  are the  third  and  fourth  steps  in  addition  to  the  first  step in 
which the system detects a slow moving obstacle ahead, as well as the second step in which it 
detects a stationary vehicle. 

Especially  children  act  on  impulse  and  are  mostly  not  capable  of  assessing  and  detecting 
dangerous  situations,  frequently  running  in  front  of  driving  cars  in  urban  areas.  Therefore, 
these  detection  capabilities  should  be  considered  to  improve  the  safety  situation  of  such 
vulnerable road users that are hit by cars, by either reducing significantly the impact speed or 
by avoiding a collision altogether. 

Pedestrians  comprise  over  21%  of  EU27  fatalities  and  in  2011  there  were  over  6,500 
pedestrian fatalities in Europe (EC, 2013). In the same period, there were over 2,000 cyclist 
fatalities, comprising over 8%  of all EU27  fatalities (EC, 2013).  The majority of pedestrian 
and  cyclist  casualties  occur  in  urban  areas  and  over  80%  result  from  collisions  with  motor 
vehicles (cars, lorries, and buses). Therefore, these detection capabilities should be integrated 
in  the  review  of  the  Pedestrian  Safety  Regulation  to  improve  the  safety  situation  of  such 
vulnerable road users that are hit by cars, by either reducing significantly the impact speed or 
by avoiding a collision altogether. 

  Make mandatory for M1 and N1 vehicles (that are derived from M1) 
  Coupled with AEB application 

o  01/09/2024 pedestrian detection for new types 
o  01/09/2026 cyclist detection for new types 

  Plus 2-year period for all new vehicles 
  All N1 vehicles 2-year off-set to the above dates 

Technological feasibility:  

Pedestrian detection  systems are currently  offered as  an option by approximately 5%  of M1 
manufacturers. Volvo are the only manufacturer to offer a cyclist AEB system (since 2013); 
some other AEB systems may detect cyclists, but they are not specifically designed to do so.  

Legislation feasibility/readiness:  
Test procedures for pedestrian AEB have been developed by the EU FP7 AsPeCSS project50. 
Since  January  2016,  Euro  NCAP  assesses  the  performance  of  pedestrian  AEB  for  three 
crossing  scenarios.  These  are:  an  adult  runs  from  the  driver’s  side  of  the  vehicle;  an  adult 
walks from the passenger’s side (two tests are done for this scenario); and a child runs from 
between parked cars on the passenger’s side. To date, test protocols for cyclist AEB do not 
exist but some initial development work has been performed in the EU FP7 AsPeCSS project.  

50    http://www.aspecss-project.eu 

30 

 
                                                 
The  AsPeCSS  project  performed  a  benefit  analysis  for  pedestrian  AEB51  and  estimated  that 
current AEB systems could reduce fatal pedestrian casualties by 2.9-6.2%, serious casualties 
by 4.2-4.4% and slight casualties by 2.2-4.4%. This gives a break even cost per car of about 
€80, indicating that current AEB systems implemented in a stand-alone manner are not likely 
to  have  a  benefit  to  cost  ratio  greater  than  one.  However,  their  performance  is  expected  to 
improve,  the  AsPeCSS  project  estimated  that  this  could  increase  the  break-even  cost  up  to 
around €280. Clearly, if the benefit of cyclist AEB was also added in and these systems were 
bunched with other systems, which also use cameras such as Lane Keep Assist, the system as 
a whole would likely have a benefit to cost ratio far greater than one. 

For consideration for implementation in the GSR further work is required to: 

  Complete development of test protocols for cyclist AEB 

  Confirm cost benefit analysis 

3.3.2.  Head Impact on A-Pillars and Front Windscreen 

Despite an introduction of automatic braking in the context of pedestrian and cyclist safety, 
some collisions will still be unavoidable because of certain specific factors or limitations. In 
this context it is noted that currently the windscreen and A-pillars are exempted from testing 
in  terms  of  head  impacts  on  these  structures,  whereas  it  is  generally  known  that  impacts 
frequently occur.  

The idea to use airbags to protect the A-pillar and possibly the upper windscreen frame has 
existed  for  more  than  a  decade.  Whilst  the  centre  of  the  windscreen  may  be  relatively  safe 
when hit by the head of a pedestrian, the glass towards the edge of the screen may not break at 
the same load.  This has been confirmed from the monitoring data that has been gathered as 
part  of  the  current  legislation  and  this  reporting.  Also,  at  the  base  of  the  windscreen,  it  is 
likely that the head of a vulnerable road user would penetrate the glass sufficiently to contact 
the dashboard fascia underneath. 

The  windscreen  frame  itself  is  very stiff  to  persons,  because  it  is  an  important  load-bearing 
part of the vehicle’s structure. Therefore impacts to the windscreen frame and around the edge 
of the windscreen can be considered to represent significant gaps in the protection assessed by 
the  current  legislation  and  this  should  therefore  be  taken  into  serious  consideration  for  the 
review of the Pedestrian Safety Regulation. 

  Extend the adult head impact zone 
  Make mandatory for M1 and N1 vehicles (that are derived from M1) 
  Coupled with AEB application 
  May consider introduction of reduced impact speeds with AEB pedestrian and cyclist 
detection  (for  windscreen  and  cyclist  detection  (for  windscreen  and  A-pillar  testing 
only) 

o  01/09/2024 new types 
o  01/09/2026 all new vehicles 
o  All N1 vehicles 2-year off-set to the above dates 

When the legislation for pedestrian protection was implemented the head to windscreen tests 
were included for monitoring purposes only, based on concerns from the automotive industry 
that  the  centre  of  the  windscreen  was  ‘safe’  and  not  within  the  control  of  the  vehicle 

51   Edwards et al. (2014). Estimate of Potential Benefit for Europe of Fitting Autonomous Emergency Braking 
(AEB)  Systems  for  Pedestrian  Protection  to  Passenger  Cars.  Traffic  Injury  Prevention  (2014)  15,  S173–
S182.  

31 

 
                                                 
manufacturer. Has sufficient technological progress been made to make these tests feasible for 
mandating? 

Technological feasibility:  

In general, the vehicle manufacturer can only alter effective properties of the windscreen by 
changing the overall design, for example, the curvature and angle of the screen. However, for 
impacts to the central region of the windscreen it might be that the variation of performance 
of the windscreen material can be controlled more closely, and give safety improvements, via 
arrangements between vehicle manufacturer and glass supplier. 

Pedestrian airbags (and pop-up bonnet) are now technically feasible, but are not yet adopted 
widely throughout the fleet.  

AEB systems have the potential to avoid or reduce the speed in pedestrian impacts and hence 
mitigate the head impact. 

Legislation feasibility/readiness:  

The requirements and test procedures exist, but are currently applied for monitoring purposes 
only,  i.e.  not  mandatory.  Before  the  current  headform  is  transferred  to  the  windscreen  for 
regulatory  use,  it  is  strongly  suggested  that  the  appropriateness  of  using  the  current  Head 
Protection Criterion (HPC) with a headform, in such conditions, is demonstrated.  

The GSR review estimated that the potential benefit for head-to-windscreen contacts is up to 
500 fatalities and 11,000 serious injuries (~ €3 billion) in M1 vehicles2. The benefit to  cost 
ratio of passive headform protection measures was estimated to lie in the range from less than 
0.25 to 1. However, as mentioned above, for impacts to the central area of the windscreen, it 
may  be  possible  to  control  the  performance  of  the  windscreen  via  arrangements  between 
vehicle manufacturer and glass supplier. Therefore further research could be useful to isolate 
the relationship between variations in the windscreen fabrication process and HIC. Once that 
relationship  is  understood  better,  then  the  monitoring  tests  (to  the  central  region  of  the 
windscreen) could become feasible and would likely have a benefit to cost ratio greater than 
one. 
For  active  counter-measures,  Edwards  et  al  (2015)52  has  indicated  that  even  with  AEB  for 
pedestrians protection of the A-pillars using airbags would still offer substantial benefits. On 
this basis, it is recomemnded that an integrated approach is adopted for the way forward.  

For consideration for implementation in the GSR further work is required to: 

  Perform further research to: 

o  Understand  if  possible  to  control  the  performance  of  the  windscreen  central 

area 

o  Determine  appropriateness  (biofidelity)  of  current  haedform  for  windscreen 

impact 

o  Investigate potential integrated solutions using AEB. 

  Perform cost benefit analysis 

3.3.3.  Reversing (Backing up) Detection 

Reversing  detection  systems  are  those  that  increase  the  view  of  drivers  or  otherwise  warn 
them of persons or obstacles behind reversing vehicles. Particularly vulnerable in this context 

52   Edwards  et  al.  (2015).  Assessment  of  Integrated  Pedestrian  Protection  Systems  with  Autonomous 

Emergency Braking (AEB) and Passive Safety Components. Traffic Injury Prevention (2015) 16, S2–S11. 

32 

 
                                                 
are  short,  crouching  and  slow  moving  people,  such  as  the  elderly  and  children.  There  is  an 
increasing concern about accidents involving young children being run over by reversing slow 
moving  vehicles  while  playing  in  private  driveways.  In  these  circumstances,  there  is  a 
possibility that these young children are too short to be seen, and so detections systems could 
be employed to warn the driver of such children in the path of the reversing vehicle. 

The  USA  has  recently  mandated  reversing  cameras  as  a  technical  solution  to  the  above 
mentioned problem. Whereas in the context of the revision of the General Safety Regulation 
we should strive for technology neutral safety solutions, we could also consider harmonising 
with the relevant amended FMVSS No 111 which requires one of the accepted solutions that 
may be developed and deployed to prevent this type of potentially fatal accidents. 

 
Investigate trend with more commonplace SUVs 
  Reversing camera and/or acoustic warning, t.b.d. 

o  Possible to consider the new US FMVSS 111 requirements designed to 

protect small children 

  Make mandatory for all M and N, as well as O3 and O4 vehicles 

o  01/09/2020 new types 
o  01/09/2022 all new vehicles 

Technological feasibility:  

Ultrasonic, radar, and camera systems all exist on the market. Ultrasonic (parking sensors) are 
widely  equipped  to  current  vehicles  but  are  not  specifically  designed  for  the  detection  of 
pedestrians. Camera and radar systems are available as optional systems on some models. 

Legislation feasibility/readiness:  

Although the US FMVSS 211 standard specifies a camera system, a performance requirement 
(which  is  non-technology  specific)  would  be  preferable.  A  minimum  viewable  area  and 
quality  of  view  could  be  defined.  An  assessment  of  national  statistics  in  Europe  would  be 
required  to  take  into  account  the  situations  causing  the  majority  of  casualties.  For  an 
assessment  method  to  be  developed  the  distance  between  the  pedestrian  and  vehicle  before 
reversing  started  may  be  needed  as  would  the  driving  direction  (i.e.  turning);  this  is  highly 
unlikely to be recorded with a statistical significance in any of the main accident databases.  

It  should  be  noted  that NHTSA  originally  took  the  same  view  (Public Law  110–189,  110th 
Congress), but concluded that the only option currently able to fulfil all requirements was a 
rear  view  camera  including  specific  requirements  on  luminance  of  the  screen,  image  size, 
image response time, and system start up time etc. 
Based  on  UK  data,  the  GSR  review2  estimated  that  the  benefit  to  cost  ratio  for  mandatory 
fitment of pedestrian  detection (camera system)  to  prevent  pedestrian run over would likely 
be in the range of 0.1 to 0.5 depending on the cost of the system. However, if the benefit of 
prevention of damage only accidents is also included, the benefit to cost ratio rises to be in the 
range 1.5 to 7.5. Furthermore FMVSS 211 will be mandatory from May 2018 so system costs 
are likely to reduce, thus increasing the benefit to cost ratios.  

For consideration for implementation in the GSR further work is required to: 

  Decide approach for implementation, i.e. implementation regulation for camera based 
systems (following US approach) or implement perfromance based generic approach 

  Perform cost benefit analysis. 

33 

 
4. 

BUNCHING OF TECHNOLOGIES 

Some  of  the  candidate  measures  listed  above  could  utilise  the  same  systems.  Therefore,  if 
these measures are considered as a package, the cost of the systems common to them would 
be spread amongst the individual measures and hence improve the BCR of the package as a 
whole  compared  to  that of  individual  measures.  Manufacturers  already  use  this  approach  to 
reduce  costs  for  measures  supplied  as  options  or  standard  fit,  for  example  Autonomous 
Emergency  Braking (AEB)  is  often packaged with  Adaptive Cruise Control (ACC)  because 
ACC can use the same camera / radar that is used for AEB. 

System sharing between the measures listed that should be considered includes: 

  Driver distraction and drowiness (DDR), Autonomous Emergency Braking (AEB) and 

Lane Keeping Assistance System (LKA) 
o  Camera based systems with a driver view can be used to monitor a range of eye, 
face and head features for multiple purposes including drowsiness and distraction. 
Such systems can be expanded to have a forward facing camera (e.g. to monitor 
lane deviation and provide alerts, to record collisions, to monitor headway).  
o  Systems  based  on  vehicle  control  measures  can  monitor  drowsiness  by  utilising 
existing  vehicle  sensors  for  steering,  braking,  acceleration  and  metrics  derived 
from  these  inputs.  This  is  why  such  systems  are  favoured  by  automotive 
manufacturers.  

o  Systems can also utilise existing safety features of vehicles, such as lane keeping 
devices, to identify whether drivers appear distracted or drowsy according to the 
consistency  with  which  they  remain  in  a  lane,  the  number  of  deviations  and  the 
rate of correction.  

o  Systems can integrate with other vehicle telematics to transfer information about 

driver state and the number of alerts (e.g. to a fleet operator).  

o  Some  camera  based  products  can  utilise  the  cameras  and  hardware  in  mobile 
phones  to  provide  drowsiness  monitoring  without  the  acquisition  of  additional 
hardware dedicated to this purpose. 

5. 

FURTHER STUDIES IN THE FIELD OF VEHICLE SAFETY 

In light of regulatory actions in other regions of the world, notably that of the USA and Japan, 
the Commission deems it appropriate to outline further steps to be taken to initiate studies on 
the effects of specific accident types occurring in the EU to obtain an up-to-date overview and 
to  identify  countermeasures  that  may  need  to  be  taken.  These  accidents  concern  frontal 
crashes, side crashes, roll-over accidents and rear crashes, notably with a focus on the effects 
due to the proliferation of SUVs with higher centres of gravity, higher masses and aggressive 
front-end design, linked to injuries to diverse and vulnerable occupants as well as to vehicle 
fires resulting from crashes. 

5.1. 

FRONTAL CRASHES 

 

 

 

 

High speed oblique frontal impacts, causing occupants to striking vehicle interior 
parts due to ‘striking in a glancing blow’ or entirely ‘missing’ the frontal airbags; 
Lower  speed  frontal  impacts  and  its  effect  on  vulnerable  occupants,  such  as  the 
elderly,  small  females  and  children,  with  the  aim  to  promote  adaptive  restraint 
systems; 
The effects of proliferation of SUVs with higher masses colliding with passenger 
cars;  
Car fires resulting from frontal crashes; and 

34 

 
 
 

Frontal impacts in  general and its effect on passengers seated in the rear, also  to 
promote adaptive restraints for those seating positions. 

5.2. 

SIDE CRASHES 

 

 

The effects of proliferation of SUVs with higher masses colliding with passenger 
cars; and 
Side  crashes  in  general  and  its  effect  on  passengers  seated  in  the  rear,  including 
vulnerable occupants. 

5.3. 

ROLL-OVER ACCIDENTS 

 

The effects of proliferation of SUVs with higher centres of gravity and tendency to 
roll-over, causing (partial) ejection of occupants. 

5.4. 

REAR CRASHES 

 
 

Assessment of rear impacts, with partial or full overlap; and 
Car fires resulting from rear impacts. 

6. 

CONCLUSIONS 

The  Commission  has  undertaken  an  elaborate  assessment  of  a  range  of  existing  and  mature 
safety technologies for passenger vehicles, trucks and buses that have great safety potential in 
terms of improving passive safety and mitigating crash consequences as well as active crash 
avoidance potential, with a particular focus on the protection of vulnerable road users.  

Furthermore,  to  bridge  the  safety  performance  gap  between  different  regions  as  well  as 
vehicle  segments  and  categories,  the  listed  enhanced  safety  provisions  are  indeed  proposed 
for light to heavy vehicles across the board to ensure that those involved in an accident benefit 
of the technical progress in road and vehicle safety. 

It  is  noted  that  in  order  to  ensure  competitiveness  of  the  automotive  sector,  it  is  of  high 
importance that the issue of technology neutrality on specific solutions is respected. 

Finally,  technical  progress  in  terms  of  advanced  vehicle  safety  does  not  stop  here.  For  this 
reason  the  European  Union  should  be  committed  to  continuous  monitoring  and  to  further 
analysis as well as to other relevant actions to improve this important work. 

35 

 
 
 
ANNEX 1: LIST OF PROPOSED MEASURES BY INTRODUCTION DATE 

New vehicle type-approvals 

New vehicle registrations 

1 September 2020 

  Automatic Emergency Braking (AEB) 
with Moving Obstacle Detection 

o  M1 and N1 (derived from M1) 

  Emergency Braking Display  
 
Intelligent Speed Adaptation 
  Lane Keep Assistance 

o  M1 and N1 (derived from M1) 

  Driver Drowiness and Distraction 

Monitoring 

o  M1, N1 (derived from M1), M2, 

M3, N2 and N3 
  Safety Belt Reminders 
  Frontal Crash Full Width Test 

o  M1 and N1 

  Side Crash elimination of exemptions 

o  M1 and N1 

  Side Crash Pole Side Impact 

o  M1 and N1 

  Rear Crash Test 

o  M1 and N1 

  Alcohol Interlock Devices interface 
  Crash Event Data Recorder 
o  M1 and N1 
  Tyre Pressure Monitoring 

o  M, N, O3 and O4 

  Truck and Bus Front End Cameras 

and Detection 

o  M2, M3, N2 and N3 

  Truck Lateral Protection elimination 

of exemptions 

o  N2 and N3 
  Fire Safety for CNG Buses 
o  M2 and M3 
  Fire Suppression for Buses 
o  M2 and M3 

  Reversing Detection 

o  M, N, O3 and O4 

1 September 2022 

36 

 
 
 
 
New vehicle type-approvals 

New vehicle registrations 

  Automatic Emergency Braking (AEB) 
with Moving Obstacle Detection 

  Automatic Emergency Braking (AEB) 
with Moving Obstacle Detection 

o  N1 

o  M1 and N1 (derived from M1) 

  Automatic Emergency Braking (AEB) 
with Stationary Obstacle Detection 

o  M1 and N1 (derived from M1) 

  Emergency Braking Display  
 
Intelligent Speed Adaptation 
  Lane Keep Assistance 

  Lane Keep Assistance 

o  N1 

o  M1 and N1 (derived from M1) 

  Driver Drowiness and Distraction 

  Driver Drowiness and Distraction 

Monitoring 

Monitoring 
o  N1 

  Frontal Crash inclusion up to 3,500 kg 

o  M1 and N1 

o  M1, N1 (derived from M1), M2, 

M3, N2 and N3 
  Safety Belt Reminders 
  Frontal Crash Full Width Test 

  Frontal Crash Small Overlap Test 

o  M1 and N1 

o  M1 

  Side Crash elimination of exemptions 

  Side Crash Far-Side Occupant Test 

o  M1 and N1 

o  M1 and N1 

  Side Crash Pole Side Impact 
M1 and N1 

  Rear Crash Test 

o  M1 and N1 

  Alcohol Interlock Devices interface 
  Crash Event Data Recorder 
o  M1 and N1 
  Tyre Pressure Monitoring 

o  M, N, O3 and O4 

  Truck and Bus Front End Cameras 

and Detection 

o  M2, M3, N2 and N3 

  Truck Lateral Protection elimination 

of exemptions 

N2 and N3 
  Fire Safety for CNG Buses 
o  M2 and M3 
  Fire Suppression for Buses 
o  M2 and M3 

  Reversing Detection 

o  M, N, O3 and O4 

1 September 2024 

New vehicle type-approvals 

New vehicle registrations 

  Automatic Emergency Braking (AEB) 
with Stationary Obstacle Detection 

  Automatic Emergency Braking (AEB) 
with Moving Obstacle Detection 

37 

 
 
 
o  N1 

o  N1 

  Automatic Emergency Braking (AEB) 

with Pedestrian Detection 

  Automatic Emergency Braking (AEB) 
with Stationary Obstacle Detection 

o  M1 and N1 (derived from M1) 

o  M1 and N1 (derived from M1) 

  Pedestrian Safety A-Pillar and 
Windscreen Head Impact Test 

  Lane Keep Assistance 

o  N1 

o  M1 and N1 (derived from M1) 

  Driver Drowiness and Distraction 

Monitoring 
o  N1 

  Frontal Crash inclusion up to 3,500 kg 

o  M1 and N1 

  Frontal Crash Small Overlap Test 

o  M1 

  Side Crash Far-Side Occupant Test 

o  M1 and N1 

38 

 
 
 
1 September 2026 

New vehicle type-approvals 

New vehicle registrations 

  Automatic Emergency Braking (AEB) 

with Pedestrian Detection 

  Automatic Emergency Braking (AEB) 
with Stationary Obstacle Detection 

o  N1 

o  N1 

  Automatic Emergency Braking (AEB) 

  Automatic Emergency Braking (AEB) 

with Cyclist Detection 

with Pedestrian Detection 

o  M1 and N1 (derived from M1) 

o  M1 and N1 (derived from M1) 

  Driver Drowiness and Distraction 

Monitoring 

o  N2, N3, M2, M3 
  Pedestrian Safety A-Pillar and 
Windscreen Head Impact Test 

o  M1 and N1 (derived from M1) 

New vehicle type-approvals 

New vehicle registrations 

  Automatic Emergency Braking (AEB) 

  Automatic Emergency Braking (AEB) 

1 September 2028 

with Cyclist Detection 

o  N1 

  Truck and Bus Front End Direct 

Vision 

o  M2, M3, N2 and N3 

with Cyclist Detection 

o  M1 and N1 (derived from M1) 

New vehicle type-approvals 

New vehicle registrations 

1 September 2030 

  Automatic Emergency Braking (AEB) 

with Cyclist Detection 

o  N1 

39 

 
 
 
   
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 2: FULL LIST OF POTENTIAL MEASURES AS ESTABLISHED FOR THE FEASIBILITY AND 

COST-BENEFIT STUDY (PUBLISHED IN MARCH 2015) 

Retained for further assessment 

Has not been further assessed53 

Legend: 

A2.1.  ACTIVE SAFETY 

Measure 

Description 

Automatic emergency braking 
systems (AEBS) 

Combine sensing of the environment ahead of the vehicle with the automatic 
activation of the brakes (without driver input) in order to mitigate or avoid an 
accident. The level of automatic braking varies, but may be up to full ABS braking 
capability. First generation AEBS are in production on a number of current vehicles at 
the top end of the market and are capable of automatically mitigating the severity of 
two-vehicle, front to rear shunt accidents (on straight roads and curves dependent on 
sensor line of sight and environment “clutter”) as well as some collisions with fixed 
objects and motorcycles 

Lane Departure Warning system 
(LDWS) 

A lane departure warning (LDW) system is an in-vehicle system that provides a 
warning to the driver of an unintended lane departure. Warning only, no corrective 
action 

Automatic Cruise Control (ACC) 

Lane Keeping Warning system 
(LKS) 

Lane Change Assist (LCA) 

Automatic Lighting 

Advanced Front-lighting Systems 
(AFS) 

Side marker lamps on passenger 
cars and vans to improve 
conspicuity 

In an extension to the speed management capability of conventional cruise control 
systems, Automatic or Adaptive Cruise Control (ACC) maintains a desired road speed 
if the roadway ahead is unobstructed and a constant time gap from a moving vehicle 
ahead 

Monitoring the position of the vehicle with respect to the lane boundary and applying 
a torque to the steering wheel, or pressure to the brakes, when a lane departure is 
about to occur. In current systems, the level of torque varies from one system to 
another. In some cases, the intervention is intended to suggest the corrective action to 
the driver, without altering the vehicle trajectory. In other cases, the intervention is 
sufficient to prevent the vehicle leaving the lane 

Lane change assistance systems warn the driver when it is unsafe to change lanes. The 
system will not take any direct action to prevent a possible collision; hence the driver 
remains responsible for the safe operation of the vehicle. They function by monitoring 
the area around the vehicle during a lane change manoeuvre and issuing a warning if 
certain criteria are met. These criteria usually relate to the proximity of other vehicles 
in the driver’s intended lane of travel 

The fully automatic switching on/off of dipped beam headlamps depending on 
ambient light level,  in conjunction with DRLs and always-illuminated speedometers 
(which may confuse drivers, who subsequently forget to put on their dipped beam). 
Not automatic dip and main beam nor directional lighting 

An Advanced Front-lighting System (AFS) is a technology which varies the pattern of 
light produced by headlamps to maximise clarity of the roadway at night whilst 
minimising the glare posed to oncoming vehicles. AFSs are designed to provide 
drivers with a better field of view when driving at night 

Dedicated lights on the sides of passenger cars/small vans that remain illuminated 
when the headlights are on to improve the lateral conspicuity of the vehicle 

53   Hynd, D., McCarthy, M., Carroll, J., Seidl, M., Edwards, M., Visvikis, C., Tress, M., Reed, N. and Stevens, 
A. (2015). Benefit and feasibility of a range of new technologies and unregulated measures in the fields for 
occupant safety and protection of vulnerable road users. Final Report. Brussels: European Commission. 
http://bookshop.europa.eu/en/benefit-and-feasibility-of-a-range-of-new-technologies-and-unregulated-
measures-in-the-field-of-vehicle-occupant-safety-and-protection-of-vulnerable-road-users-
pbNB0714108/;pgid=Iq1Ekni0.1lSR0OOK4MycO9B0000BAJ9tQVy;sid=OT_-Ap3uO3P-
V8j2wGFgpf_Lm_yCUpo9P-w= 

40 

 
 
 
                                                 
 
 
Measure 

Description 

Emergency Brake Lights (EBL) 

Intelligent Speed Adaptation 
(ISA) 

Triggered by the strength of brake activation the rear brake lights are illuminated in 
different ways to indicate emergency braking manoeuvres to the following vehicles; 
possibly also activated by stability control system 

Intelligent Speed Adaptation (ISA) describes a range of technologies which are 
designed to aid drivers in observing the appropriate speed for the road environment. 
Two levels of control were considered: advisory (alert the driver when their speed is 
too great) and voluntary (the driver chooses whether the system can restrict their 
vehicle speed and/or the speed it is restricted to). Mandatory systems (where the 
driver’s speed selection is physically limited by an ISA system that cannot be 
switched off) were not considered 

Ambient temperature sensors 

Both sensors to warn of external temperatures and V2V/I2V communications to warn 
following traffic of ice (or fog, or accident etc.) were considered 

Blind spot detection systems 

Application to turning HGVs only 

Pedestrian/cyclists detection 
systems 

Pedestrian detection may employ video, laser, radar or infrared sensors to detect the 
presence of pedestrians/cyclists in the path or periphery of the vehicle. Systems can 
either warn the driver and/or apply AEBS (both to be considered) 

Improved visibility from vehicles 

Traffic sign recognition 

Night vision systems 

Better driver visibility all around the driver in terms of reduced visual obstruction 
caused by size and position of vehicle structure. To include vehicles not already 
covered by R125 (i.e. M2, M3, N), e.g. Japanese requirement for additional 
mirror/camera on the front of SUVs 

The system (normally via a camera and optical recognition) detects road signs and 
provides in-vehicle information to the driver 

Night vision systems are designed to increase detection performance of critical targets 
such as pedestrians, cyclists, animals, and other objects. They extend the visibility of 
objects during poor visibility conditions by projecting improved or higher contrast 
images using infrared (IR) cameras on a display 

Junction camera system 

Camera(s) on the side of the front of a vehicle provide an unobstructed view each side 
of vehicles at a junction 

Reversing detection and 
reversing camera system 

Camera (or sensor) on the rear of a car to alert drivers to pedestrians behind cars, in 
particular to prevent accidents involving children behind reversing cars 

Integrated cleaning system 

Cleaning water is emitted from the wiper blades rather than nozzles on the bonnet 

41 

 
 
 
 
A2.2.  CAR OCCUPANT AND PEDESTRIAN SAFETY 

Measure 

Description 

Improved protection of seniors 
and small stature occupants 
through the adoption of 
advanced anthropometric test 
devices 

In response to the potential for modifications to current safety requirements (e.g. R.94, 
R.95), upcoming requirements (e.g. Pole Side Impact, Full-Width frontal) and 
potential requirements (e.g. rear seat occupants in adult belt); safety measures, 
including the possibility of additional tests within each measure, to improve the safety 
of seniors and small stature occupants 

Protection of far-side occupants 
in side impact collisions 

In a side impact with both driver and front seat passenger (FSP) occupants, the struck-
side occupant is protected by multiple airbags. However, the far-side occupant tends to 
slip out of the seat-belt and collide with the struck-side occupant, which may result in 
significant injuries to either occupant 

Side impact protection for 
occupants of all sizes and 
prevention of ejection 

Implementation of systems to protect the heads of occupants of all sizes and to prevent 
ejection of occupants as a result of a side impact crash (which would most likely mean 
the use of full-size side window airbags) 

Rear impact protection 
requirements for rear seated 
occupants 

Improvement of protection for occupants of rear-row seats in a rear impact, 
particularly focused on protection of occupants seated very close to the rear of the 
vehicle e.g. third row seats 

Pre-crash seat-belt tensioners 
and occupant position 
adjustments 

Improvement of occupant safety in case of an inevitable impact. Mandated measures 
could include pre-crash seat-belt pre-tensioning, adjustment of the seat position prior 
to the start of the collision (in both the occupant would be approximately stationary 
relative to the vehicle at the start of the collision), or dynamically moving the occupant 
just prior to and at the start of the collision 

Seat-belt reminder systems  

In front and rear passenger seating positions 

Pedestrian upper leg and pelvis 
to bonnet leading edge protection 

Adult head to windscreen 
protection 

Influence of front registration 
plates on pedestrian protection 

Influence on safety of third-party 
(non-OEM) replacement parts 
(e.g. bonnet, front bumper, 
wings) on pedestrian protection 

Strength of ISOFIX connectors 
installed in vehicles 

Safety of children in hot cars 

When the legislation for pedestrian protection was implemented there were concerns 
from the automotive industry that it was not feasible to meet the upper legform 
protection criteria proposed by EEVC Working Groups alongside that test. As a result 
these tests were included for monitoring purposes only. . Investigated whether or not 
sufficient progress has been made to make these tests feasible for mandating 

When the legislation for pedestrian protection was implemented there were concerns 
from the automotive industry that the centre of the windscreen was ‘safe’ and not 
within the control of the vehicle manufacturer. As a result these tests were included for 
monitoring purposes only. Investigated whether or not sufficient progress has been 
made to make these tests feasible for mandating 

The bumper test components of vehicle type-approval are conducted without the front 
registration plates being present. However, when a vehicle is involved in an accident 
these will be in place. Therefore it is possible that the real world safety levels are 
different from those assessed at the time of type-approval. Testing with the registration 
plates in place would remove this discrepancy but may offer very limited benefit and 
be subject to variations in plate design 

For styling or accident repair purposes, aftermarket vehicle components can be 
purchased. These parts can be sourced from the original manufacturer or from a third 
party. Third party parts may not have been assessed for safety performance in the same 
way as the original parts and therefore safety could be degraded through the fitting of 
such parts. In principle it could be required for all automotive parts to have been 
assessed and certified to make sure that safety levels are maintained or will still meet 
type-approval requirements. Alternatively, the fitting of third party parts that may 
affect pedestrian safety could be tracked and their effect monitored. 

To ensure appropriate protection of heavier children. 

Systems to raise the alarm or to cool the vehicle if the interior temperature exceeds a 
threshold and the presence of a child occupant is detected. 

42 

 
 
 
 
 
A2.3.  CRASHWORTHINESS, HGV SAFETY AND FUEL SYSTEMS 

Measure 

Description 

Crashworthiness in case of small-
overlap frontal crashes 

Car occupant protection for small overlap frontal crashes, i.e. those with less than 20 
to 25% overlap and no direct loading of longitudinal rails. 

Compatibility with crash 
partners 

Better compatibility in crashes with other vehicles to minimise injuries in the accident 
overall.  Includes compatibility with other cars (M1) and rear-under-run protection on 
HGVs and their trailers. 

Increased offset-frontal crash test 
speed 

Increased test speed in the current regulatory frontal impact test R.94 for cars (M1). 
Either increasing the speed of the current test or the addition of another test. 

Crashworthiness in case of full-
overlap frontal crashes 

Car occupant protection for full overlap frontal crashes, i.e. those with more than 
about 80% overlap and with direct loading of both longitudinal rails, to better assess 
occupant restraint systems. 

Roof strength testing to protect 
occupants in case of roll-over 
accidents 

Static roof strength testing similar to FMVSS216 to ensure minimum roof strength to 
reduce roof crush in rollover accidents. Ejection mitigation testing similar to 
FMVSS226 to ensure side airbags offer help to prevent ejection is also included 
because it is closely related. 

Vehicle submersion requirements 
to ensure that vehicle occupants 
are always capable of escaping a 
vehicle in water 

Measures to ensure things such that electric windows can be opened when/if a vehicle 
rolls/falls into water to allow occupants to escape. For example, that central locking 
does not short-circuit or fail to disengage, and power windows remain operable and do 
not close automatically due to water immersion, etc. Equipment such as a hammer is 
not included, except devices that automatically trigger and shatter the windows. 

HGV side guards 

Safer HGV front end design 

To consider the removal of some or all of the current exemptions for lateral protection 
side guards on trailers/trucks, which are designed to protect cyclists against over-run 
injuries. 

Assuming that the weights and dimension of heavy goods vehicles will be changed for 
fuel efficiency reasons, are there measures that should be considered that make use of 
the additional cab length to improve cab safety. To include self-protection, partner 
(car) protection and improved direct vision for vulnerable road users. 

Light and heavy duty fuel 
systems 

Comprehensive testing of fuel systems to avoid vehicle fires and possible inclusion of 
automatic fire extinguishers 

CNG fire requirements 

Specific enhanced requirement for CNG vehicles in case of fire (as proposed by the 
Dutch delegation in GRSG of UNECE) 

Rear impact protection of the 
fuel tank 

Crash test requirements for the integrity of the fuel tank of M1 vehicles in a rear 
impact (e.g. US, Canadian and Japanese requirements) 

Tyre pressure monitoring system  Electronic system designed to monitor the air pressure inside the pneumatic tyres on 

various types of vehicles. TPMS report real-time tyre-pressure information to the 
driver of the vehicle, either via a gauge, a pictogram display, or a simple low-pressure 
warning light. TPMS can be divided into two different types, direct (dTPMS) and 
indirect (iTPMS). TPMS are provided both at an OEM (factory) level as well as an 
aftermarket solution. 

43 

 
 
 
 
A2.4.  DRIVER INTERFACE, DISTRACTION AND INTELLIGENT TRANSPORT SYSTEMS 

Measure 

Description 

Standardisation of uniform 
vehicle controls 

Improving the intuitive 
operation of vehicles 

Standards exist for some aspects of vehicle control interfaces. However, with new 
ADAS functions emerging, manufacturers differ in the way in which they implement 
the new functions available to the driver. This measure relates to the standardisation of 
new vehicle controls to ensure that drivers moving from one vehicle to another have a 
consistent driving experience and reduce the likelihood of control misuse. Also 
considering the standard location of emergency buttons (horn, hazards) parking brake, 
gear shift patterns, indicator stalk/wiper stalk location, etc. 

The way in which vehicles are driven is evolving. New active safety and comfort 
systems are changing the ways in which drivers interact with their vehicles. Additional 
vehicle functionality can bring additional complexity to the vehicle interface. Controls 
that are not intuitive to use are more likely to be misused resulting in a potential 
increase in collision risk or disused such that the driver fails to take advantage of the 
potential safety/comfort benefits that such systems may deliver. This measure would 
improve the intuitive operation of vehicle systems to minimise these risks and 
maximise the benefit of the systems. Considering the definition of performance 
requirements for intuitive vehicle operation encouraging industry standardisation. To 
explore the need and opportunities, closely linked to the point above 

Driver interface provisions and 
restrictions for on-board 
infotainment systems 

In-vehicle display, communication and computing technologies are advancing rapidly. 
There is the potential for drivers to access complex functionality through native vehicle 
systems and/or smartphone connectivity. This measure examines provisions and 
restrictions for on-board infotainment systems that may deliver this functionality 

Reducing driver distractions 

Driver distraction and 
drowsiness recognition 

Cameras to replace all the rear 
view mirrors 

Alcohol interlock devices to 
prevent drink driving 

Interlock to prevent the use of 
non ‘hands free’ mobile 
telephone systems while driving 

Crash event data recorders 
(EDR) 

Driver distraction is the diversion of attention from activities critical for safe driving to 
a competing activity. Competing activities come in an increasing variety of forms and 
can be within the vehicle or external. Reducing distraction to improve drivers’ 
attention to the activities required for safe driving should reduce collision risk 

Sensor technology is advancing such that it is becoming possible for technology to 
provide a reasonably accurate estimate of driver alertness in relation to distraction or 
fatigue, with some vehicle manufacturers already offering systems that deliver 
warnings if they detect that the driver is showing signs of fatigue. This measure relates 
to the effectiveness of potential interventions for measuring driver distraction or 
drowsiness 

Rear view mirrors do not always offer an ideal rearward view for the driver. Cameras 
could be situated to ensure that drivers always have optimal rearward vision. This 
measure is the use of cameras and in-vehicle screens to provide the driver with rear 
view information in place of the typical driving and wing mirrors 

Alcohol interlock devices require a vehicle operator to provide a breath sample and 
prevent the vehicle ignition from operating if the detected alcohol level is above a pre-
defined threshold. This measure may reduce collision risk by restricting the 
opportunity for drivers to operate vehicles when under the influence of alcohol. 

Ignition interlocks for mobile phones prevent a car from starting until the device is 
placed in a specific cradle. This cradle prevents the driver from manually interacting 
with the phone but Bluetooth connectivity enables some functions to be accessed 
‘hands-free’. This measure may reduce the level of driver distraction by limiting the 
opportunity for a driver to be distracted by manual interaction with a mobile 
communication device. For instance, a system that senses speech, GSM transmission 
activity, and use of controls, i.e. a smart system that can detect that the driver is 
texting, talking etc. while holding a phone 

Crash event data recorders are devices that can record data about vehicle status and 
dynamic behaviour in the event of the detection of sudden, rapid acceleration (as 
would be expected in a collision). The presence of a data recorder supports drivers in 
providing objective information about the collision and may encourage better driving 
behaviour since drivers will be aware that unsafe driving practices may be recorded. 
EDR may enhance knowledge about accident causes and facilitate the development of 
safer vehicles 

Car to Car communication 
(C2C) 

Capability for vehicles to rapidly exchange digital messages to support a range of 
services/function for safety, efficiency and environmental benefits including, 
importantly, time critical messages to help avoid collisions or mitigate their effects. 

44 

 
 
 
Measure 

Description 

Car to Infrastructure speed and 
hazard warning (C2I) 

Called “connected car” in the US. Also V2V although here it is understood that the 
primary focus is passenger cars and light trucks 

C2I is a technology that can support many functions/services involving transfer of 
information from vehicles to the infrastructure (roadside) and from infrastructure to 
vehicle. Here only cars and light vans are considered as the relevant vehicles.  Also, 
just two functions/services are considered - warning of hazards on the road ahead and 
warning of speed limits (which might be variable depending on traffic and weather 
conditions) 

Enhanced Navigation Systems 

Enhanced navigation functionality to a) dynamically route around accidents and 
congestion hot-spots, b) ensure routes are appropriate for the class of vehicle 

45 

 
 
 
 
ANNEX 3: FOR CANDIDATE MEASURES, SUMMARY OF FEASIBILITY AND COST BENEFIT ASSESSMENT REPORTED INITIALLY54 

?
e
l
b
i
s
a
e
F

 

 

Code 

Measure 

AEB 

EBD 

Autonomous 
emergency braking: 
Expansion and 
enhancement of AEB, 
BAS and LDW to 
avoid or mitigate 
collisions, including 
inter-urban, city and 
those involving VRUs 

Emergency brake 
light display: 
Standard fitment of 
the emergency brake 
light display (i.e. 
rapidly blinking brake 
lamps) in case of hard 
braking 

s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

Prediction that AEB would bring about a  
reduction  in casualties of approximately 
11% (based  on reported casualties). 

Retrospective insurance data show between 
10-20% fewer claims in US (these include 
whiplash accidents under-recorded in 
reported road accidents). 

Current consumer costs for urban 
AEBS are as low as £200 (Ford, 
VW), although some manufacturers 
package this with other functions 
(e.g. Audi) where the options pack 
is £2,320 (but includes AEBS, Park 
assist and other functions). 

BCR≥1, especially for 
urban systems (esp 
including damage and 
whiplash). 

Summary: ~1 

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s
i
g
e
L

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b
a
c
i
l
p
p
a

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o
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a
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h
e
v

t
s
o
M

M1, N1 

German data shows EBD estimated to affect 
25% of rear-end crashes in moving traffic 
and 15% in stationary traffic, resulting in a 
14% reduction in these crashes. These 
estimates were based on the assumption of 
an EBLD penetration rate of 70% of the 
German passenger vehicle fleet. 

Not identified although considered 
to be  low (linked to ABS or other 
braking systems) 

No formation BCR 
identified, but 
considered ≤1 because 
costs low and tangible 
safety benefit (although 
TP overlap with AEB). 

Summary: >1 

M1, N1 

M2, M3 

N2, N3 

Recommendations/Notes 

Greatest casualty benefit for AEBS is 
for M1 then N1 vehicles, although cost-
benefit less clear than for N2/N3. 
System cost estimates suggest ‘city 
safety’ systems may be reaching the 
breakeven cost point 

AEBS on M2/M3 and N2/N3 mandated 
from 2013 (new types) and 2015(new 
vehicles) 

No formal BCR for EBD were 
identified, but costs likely to be very 
low and collision and injury benefits 
expected - therefore BCR may be >1 

54   Hynd, D., McCarthy, M., Carroll, J., Seidl, M., Edwards, M., Visvikis, C., Tress, M., Reed, N. and Stevens, A. (2015). Benefit and feasibility of a range of new technologies 

and unregulated measures in the fields for occupant safety and protection of vulnerable road users. Final Report. Brussels: European Commission. 
http://bookshop.europa.eu/en/benefit-and-feasibility-of-a-range-of-new-technologies-and-unregulated-measures-in-the-field-of-vehicle-occupant-safety-and-protection-of-
vulnerable-road-users-pbNB0714108/;pgid=Iq1Ekni0.1lSR0OOK4MycO9B0000BAJ9tQVy;sid=OT_-Ap3uO3P-V8j2wGFgpf_Lm_yCUpo9P-w= 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
 
 
Code 

Measure 

?
e
l
b
i
s
a
e
F

s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

ISA 

Speed support/speed 
assist (ISA): Speed 
limiters controlled by 
road speed limit 
(speed assist, 
intelligent speed 
adaptation) 

Greatest benefits for mandatory systems 

Potential reductions of 20% injury 
accidents, 37% fatal accidents (based on 
European studies) implying savings of over  
€20 Billion per annum in the EU28. 

 

System that responds to network and 
weather conditions = 36% reduction in 
injury accidents; 59% fatal accidents 

€350 to €450 (Carsten and Tate, 
2005) plus one-off costs £8-£43 
million for mapping system and 
£2.25-£4.5 million plus £1-£5 per 
vehicle. 

BCR estimates 7.9-15.4 
(Carsten and Tate) 

Estimates for 6 EU 
countires (Belgium, GB, 
France, NL, Spain, 
Sweden) 

BCRs 2.8-4.8 

Depend on 
implementation scenario 
(market driven or 
regulation) 

Summary: >1 

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s
i
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L

e
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a
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a

s
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i
r
o
g
e
t
a
c

e
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c
i
h
e
v

t
s
o
M

M1, N1 

M2, M3 

N2, N3 

Recommendations/Notes 

BCR>1 for 6 Member States, for 
voluntary activation (switched on/off by 
the driver) and mandatory activation, 
and public acceptability of the systems 
considered to be growing. BCR higher 
for mandatory activation system, but 
both have positive BCR 

Note that studies focused on M1 
vehicles and commercial operations 
mean that N2/N3 vehicles are speed 
limited, but not with ISA systems. 

Page 47 

 
 
 
 
 
 
 
 
 
 
 
 
 
Code 

Measure 

?
e
l
b
i
s
a
e
F

s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

LKA 

Lane keeping system   

Towards upper end (or above) estimate for 
LDW (Same TP; greater system 
effectiveness) 

M1/N1 – Fatal 166-3,447, Serious 846-
17,108, Slight 2,055-22,309 

M2/M3 – Fatal 1-96, Serious 6-408, Slight 
26-255 

N2/N3 – Fatal 4-87, Serious 19-468, Slight 
42-490 

LKA are optional systems and 
typically packaged with other 
related systems. For example, Ford 
offer LKA packaged with LDW, 
Traffic sign recognition, Driver 
Alert and Auto High Beam for 
£550 (approximately €660) as a 
cost to the consumer. Other 
manufacturers offer lane departure 
warning functionality as part of a 
more advanced lane keeping 
system. For example, Audi offer 
LDW functionality as part of Lane 
Assist (which also include LKD) 
for £400 (approximately €480) cost 
to the consumer. 

DDR 

Driver distraction 
and drowsiness 
recognition 

? 

Likely to reduce collisions caused by driver 
distraction or drowsiness. 

Range of costs vary substantially 
depending on the system (€100-
€10,000). 

1.7-2.1 predicted by 
European studies 
(COWI and Abele et al.) 

M1/N1: 0.13-4.18 
(Visvikis et al., 2008); 
0.25-2.12 (Robinson et 
al., 2011) 

M2/M3: 0.47-23.47 
(Visvikis et al., 2008) 

N2/N3: 0.18-6.56 
(Visvikis et al., 2008) 

TRL consider that BCR 
for LKA likely to be 
above 1 and is toward 
the upper end of the 
BCR range predicted by 
Robinson et al. (2011) 
and possibly as high as 
the upper range 
predicted by Visvikis et 
al. (2008). 

Summary: >1 

BCR >1 for commercial 
and public service 
fleets. 

Summary: >1 

Recommendations/Notes 

?
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a
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s
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L

e
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a
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i
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p
p
a

s
e
i
r
o
g
e
t
a
c

e
l
c
i
h
e
v

t
s
o
M

M1, N1 

M2/M3 

N2, N3 

Costs higher than LDW and similar to 
LCA, but benefits higher because higher 
expected effectiveness than LDW/LCA 

LDWS on M2/M3 and N2/N3 mandated 
from 2013 (new types) and 2015(new 
vehicles). 

Consideartion could also be given to 
incorporation of functionality in system 
to aid detection of VRU in close 
peroimity in lower speed manoeuvres 
(VIS). 

M1, N1 

M2, M3 

N2, N3 

BCR likely >1 for private cars and 
commercial vehicles, due to the large 
number of collisions involving 
distraction as a causative factor. 
However, further work required to 
determine how to define and test 
effectiveness of distraction/drowsiness 
monitoring systems and to define what 
action the system should take if 
inattention is detected 

Page 48 

 
 
 
 
 
 
 
 
 
 
 
 
 
?
e
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b
i
s
a
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F

 

Code 

Measure 

SBR 

Seat belt reminder 
systems: Seat-belt 
reminder systems in 
front and rear 
passenger seating 
positions 

FFW 

Frontal Impact 
Crash Programme 

Crashworthiness in 
full-overlap frontal 
crashes to better 
assess occupant 
restraint systems 

s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

Overall benefit in Europe estimated  to be 
between: 

Predicted component costs: 

M1/N1: €68-117/24-65 million 

M2&M3: €4-337 million  

N2¬&N3: €33-88 million 

M1/N1: $4-$6 

M2/M3: $6-? 

N2/N3: $6 

 

Adaptive restraints: 5 – 11% of KSI car 
occupant casualties 

No specific information could be 
found but: 

€32 to improve restraint system to 
meet R94 limits in full-width test 
(Edwards and Tanucci 2008) 

€182 - €280 to add 2 or 4 sensor 
cutain airbag system (NHTSA 
2007) 

Fitment costs are 
comparable with, or 
lower than the break-
even estimates, with the 
exception of M1 rear 
seat passenger systems. 

Summary: >1 

Break-even costs 
estimated of between 
€84 and €175 

Therefore BCR could be 
>1 

Summary: 1 

FSO 

Frontal Impact 
Crash Programme 

Crashworthiness in 
small-overlap frontal 
crashes 

No benefit estimates found for Europe or 
US  

 

However, could be significant because 
although target population is not that large, 
effectiveness may be high because 
countermeasures likely to reduce high cost 
head and lower extremity injuries 

No specific cost information 
identified, but manufacturers have 
and are responding with design 
modifications to meet IIHS test, so 
costs assumed reasonable 

Could possibly be > 1 – 
possible significant 
benefits and reasonable 
costs 

Summary: 1? 

?
e
t
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s
i
g
e
L

e
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a
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p
p
a

s
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i
r
o
g
e
t
a
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e
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i
h
e
v

t
s
o
M

M1, N1 

M2, M3 

N2, N3 

M1 

M1 

Recommendations/Notes 

Cost-beneficial for M1 driver and 
outboard passenger seat, M2 and M3 
passengers, all seat positions for N1, 
N2, N3. Could consider legislation for 
M1 second and other row seats on basis 
of safety equality and being nearly cost 
effective 

Current proposal to amend R94 unlikely 
to lead to improved restraint systems, so 
minimal cost and minimal benefit. 
Further work needed in order to define 
requirements that would ensure 
improved restraint systems for a wider 
range of occupants in a wider range of 
collision severities. This will, most 
likely, require adoption of advanced 
anthropometric test devices. 

Maximum benefit likely from NHTSA-
style low overlap, for which there is less 
info available on likely EU benefits and 
particularly costs. Further work may be 
required 

Page 49 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Code 

Measure 

?
e
l
b
i
s
a
e
F

s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

SIP 

Side Impact Crash 
Programme 

Side impact 
protection for 
occupants of all sizes 
and prevention of 
ejection (e.g. using 
full-size window 
airbags) 

SFS 

Side Impact Crash 
Programme 

Far-side occupant 
protection: 
Protection of far-side 
occupants in side 
impact collisions 

 

Monetary benefits for testing options 
between £9-£162 million. 

Testing options vary between €70 - 
€505.   

 M1 vehicles between 
1:5.2 and 1:6.2 in 
France 

 N1 vehicles between 
1:17.3 and 1:20.8 

Summary: <1 

Scoping studies with far-side testing give 
benefit estimates. 

Casualty reductions of 30% for fatalities 
and 18 to 57% for serious injuries. 

Also beneficial in some rollover scenarios 
and predominantly in the types of side 
impact cases involving older occupants. 

 

Benefit estimated to be between €1.2 to €1.9 
billion each year in Europe.  

Cost information not available, 
used old information. 

Comparable side impact airbags 
cost about $200  in  2004. 

Anticipated that the unit cost would 
be lower than this. 

To equip the 12 million new 
vehicles registered each year in 
Europe with similar airbags (at 
$200 per unit) would cost about 
€1.8 billion. 

?
e
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a
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s
i
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L

e
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a
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i
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o
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e
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a
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e
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e
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t
s
o
M

M1, N1 

M1 

Recommendations/Notes 

Costs would have to be re-evaluated if a 
small overlap test procedure was 
introduced because this may encourage 
improved side airbags for front seat 
occupants and thus benefit from 
technology bunching. Legislation could 
also be considered on the basis of 
providing equality of protection for all 
occupants, including rear seat 
occupants.  

Also note that costs estimated in 
literature likely to be too high and also 
benefits low because no benefit for 
ejection mitigation in rollover taken into 
account, hence BCR likely to be > 1. 

Cost benefit ratio could 
be in the range of 0.6 to 
1.1. 

Summary: >1 

Likely to be cost-beneficial (spans 1, 
and cost estimate considered to be high) 
and already in production vehicles. 
Work would be required to define 
suitable test and assessment procedures 

Page 50 

 
 
 
 
 
 
 
 
 
 
 
 
 
s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

?
e
t
a
l
s
i
g
e
L

e
l
b
a
c
i
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p
p
a

s
e
i
r
o
g
e
t
a
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e
l
c
i
h
e
v

t
s
o
M

Recommendations/Notes 

?
e
l
b
i
s
a
e
F

 

Code 

Measure 

RFT 

Rear Impact Crash 
Programme 

Rear impact 
protection of the 
tank (e.g. US, 
Canadian and 
Japanese 
requirements) 

No information previously reported 

No information previously reported 

More detailed analysis required to quantify 
benefits 

More detailed analysis required to 
quantify costs 

Unknown at present 

Summary: t.b.d. 

Estimated safety benefit across Europe: 

ALC 

Alcohol interlock 
devices: Alcohol 
interlock devices to 
prevent drink driving 

Offenders: €88-€1600 million 

 

Goods vehicles: €1500 million 

Buses and coaches: €60 million 

All passenger cars: €42-€62 million 

Basic alcohol interlock systems 
cost in the region of  €1,000. 

Offenders: 1.0-2.8 

Goods vehicles: 1.4 

Buses and coaches: 0.3 

All passenger cars: 0.8-
1.3 

Summary:  t.b.d. 

Further cost and benefit information to 
be identified. Scope for international 
harmonization. Fuel tanks are tested on 
component level and the fuel system 
installation is verified through EU 
legislation, however, good performance 
in the field likely only due to best 
practise of manufacturers whereas this 
critical safety issue may need to be 
formalized in a more appropriate 
manner. This test is however lacking for 
post-crash checking of electrical safety. 

Legislate to ensure that it remains 
possible to connect an alcohol interlock 
to the vehicle in the future (not for 
fitment of the interlock), e.g. via a 
standard interface 

M1, N1  

M1, N1 

M2, M3 

N2, N3 

Page 51 

 
 
 
 
 
 
 
 
 
 
 
 
 
Code 

Measure 

?
e
l
b
i
s
a
e
F

s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

EDR 

Possible 
psychological 
stimulant to safe 
driving: EDR acting 
as a possible 
psychological 
stimulant to safe 
driving (from DG 
MOVE study) 

Improvement of road safety by improving 
the data on the performance of current 
safety systems  

Access to justice using accurate and 
verifiable collision and pre-collision data 

 

Possible effects on driver behaviour 

The purchase price of EDR 
download tools ranges from €2,200 
to €6,500  

DG MOVE study based EDR cost 
information primarily on that 
previously published by NHTSA 

M1 vehicles estimated 
at between 0 to 5.7, 
central estimate 0.1; 

N1 vehicles was 
estimated at between 0 
to 6.6, central estimate 
1.0; 

M2/M3 vehicles was 
estimated at between 0 
to 4.0, central estimate 
2.0;  

N2/N3 vehicles was 
estimated at between 0 
to 4.6, central estimate 
2.3. 

Summary: >1 

?
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s
o
M

M1, N1 

M2, M3 

N2, N3 

Recommendations/Notes 

Real benefits identified, although 
difficult to monetise. However, most 
new European vehicles have EDR 
functionality (although currently not 
accessible in most), so most of the cost 
has already been spent. Recommend 
legislating to standardise specification 
for EDR and standardising technical 
protocols for access to the information  
(the latter most likely to be harmonised 
with US Part 563) 

Page 52 

 
 
 
 
 
 
 
 
 
 
 
 
Code 

Measure 

?
e
l
b
i
s
a
e
F

s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

?
e
t
a
l
s
i
g
e
L

e
l
b
a
c
i
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p
p
a

s
e
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e
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a
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e
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s
o
M

Recommendations/Notes 

TPM 

Tyre Pressure 
Monotoring Systems   

Costs savings associated with reduced tyre 
breakdown could be generated for example 
due to increased highway safety (the effect 
of tyre blowout on the surrounding traffic). 

It is expected that the number of yearly fatal 
road accidents can be reduced which 
effectively leads to a reduction of associated 
costs of 11-58 M€ in the EU 

Costs for TPMS per vehicle 
segment (excl. VAT), truck-only 
(TO) and truck-trailer (TT) 
€5 - €146 

Prospective costs / low 
savings potential:  

Payback times for 
OEM-fitted systems are 
generally 3.5 years or 
less and abatement costs 
are negative. 

Prospective costs / high 
savings potential: 

TPMS is cost-effective 
for all considered 
applications from a 
societal as well an end-
user perspective 
irrespective of 
assumptions regarding 
the price of fuel. 

M, N, O3, O4  

When TPMS application is made 
mandatory through regulation, 
production volumes will increase 
significantly, what might lead to lower 
prices as in the “prospective cost” 
scenario. Analysis for the combination 
of the “prospective cost” scenario with 
scenarios for high resp. low fuel savings 
potential show that OEM-fitted TPMS 
could be cost effective for cases in the 
“prospective cost / high savings 
potential” scenario and in some of the 
“prospective cost / low savings 
potential” scenario. Therefore 
mandatory fitment of TPMS on new 
vehicles could lead in the described 
cost-effective scenarios to benefits for 
users as well as society. Given the 
current low market penetration of 
TPMS for HDVs, a regulation could 
accelerate mass production and reduce 
TPMS costs, and thereby could 
contribute to the materialization of 
appropriate cost benefits. 

Mandatory fitment for LCVs only could 
be considered as cost-effectiveness for 
this application is robust to all 
considered scenario variations. The 
latter is also true for long haul 
applications. 

Page 53 

 
 
 
 
 
 
 
 
 
 
 
 
Code 

Measure 

?
e
l
b
i
s
a
e
F

s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

DIM 

Safer HGV front end 
design: Safer HGV 
front end design 
(enabled by changes 
to the weights and 
dimensions 
legislation) 

Truck rear 
underrun 
programme 

FCO 

Compatibility:  

HGV rear under-run 

LAT 

Lateral protection of 
trailers and trucks: 
Lateral protection of 
trailers/trucks 
(removal of some 
exemptions) 

 

 

Potential casualty benefits across EU27; 
based on predictive estimates: 

Passenger car occupants: 128-175 

 

HGV occupants: 41-194 

VRUs: 104 – 553 

No reliable data identified; almost 
exclusively one-off costs 

Break-even cost per 
N2/N3 vehicle: €1.448-
€4,889 

Summary: >1 

Monetary benefit: 0.14-1.4 billion Euros per 
annum (from fatality savings alone) 

Car-to-HGV: Between  43 and 93 fatalities 
and 694 and 2063 serious injuries per year 
(Smith et al., 2008). 

Car-to-HGV: Range €100 to €4600 
depending on the complexity of the 
design and whether or not the 
development of the RUP was 
included in the cost (Smith et al., 
2008) 

Car-to-HGV: Between  
0.3 and 18.7, using best 
estimates between 0.6 to 
14.8 (Smith et al., 
2008). 

Summary:  >1 

Potential annual monetary benefit (from 
fatality reduction alone) across EU27: €7.8 
–€20.3 million. However, may overlap with 
other measures being considered.   

€480-1,800 for retrofit solutionsl 
cost to vehicle manufacturer 
considerably lower. 

Break even cost per 
N2/N3 vehicle: €102-
€657 

Summary: <1 to 1 

?
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a
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M

N2, N3 

N2, N3 

N2, N3 

Recommendations/Notes 

Breakeven cost per vehicle €1,448–
€4,889, so likely to be cost-beneficial. 
Further work needed to define suitable 
requirements, which will affect costs, so 
final BCR should be updated. 
Alternative active safety systems should 
also be investigated to ensure that the 
best benefit is delivered for a given cost 

Insufficient benefit from testing for 
geometric alignment of M1 frontal 
energy absorbing structures; 
consideration could be given to a 
voluntary agreement for height of 
energy absorbing structures in a similar 
way as in the US. For HGV, improved 
rear under-run guard likely to have 
BCR>1 

Cost benefit likely to be less than 1 for 
vehicles that genuinely need either an 
exemption or adjustable side guards; 
however, the classification of these 
vehicles should be improved, which will 
reduce the number of vehicles receiving 
an exemption 

Page 54 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

?
e
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a
l
s
i
g
e
L

e
l
b
a
c
i
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p
p
a

s
e
i
r
o
g
e
t
a
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e
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c
i
h
e
v

t
s
o
M

M2, M3 

Recommendations/Notes 

?
e
l
b
i
s
a
e
F

 

Code 

Measure 

AFE 

CNG 

Bus fire safety 
programme 

Comprehensive 
testing of fuel 
systems to avoid 
fires; possible 
inclusion of 
automatic fire 
extinguishers (LCV 
and HCV) 

Bus fire safety 
programme 

Specific enhanced 
requirement for 
CNG vehicles: 
Requirements in case 
of fire (as proposed 
by the Dutch 
delegation in GRSG 
of UNECE) 

No information previously reported 

More detailed analysis required to quantify 
benefits 

Type-approved system (excluding 
installation): €1,100 

Type-approval test: €17,000 

Type-approval equipment (one-
off): €12,000 - €17,000 

Unknown at present 

Summary: 

No information previously reported 

 

More detailed analysis required to quantify 
benefits 

No information previously reported 

Unknown at present 

Summary: t.b.d.  

PCD 

Pedestrian/cyclists 
detection systems 

 

Several older studies, recently ASPECSS 
estimated benefit of pedestrian AEB to be 
2.9-6.2% of fatal pedestrian casualties, 4.2-
4.4 of serious and 2.2-4.4 of slight. 

Current costs (to the consumer) are 
high 

The benefit to cost ratio 
(based on the available 
cost data) is considered 
to be less than 1, 
although the magnitude 
of the absolute casualty 
benefit is very high 

Summary <1 

M2, M3 

M1, N1 

Required by insurers for buses in some 
countries and has been effective; 
UNECE initiative well advanced. 

Recommend updates to regulation 110 
in line with hydrogen vehicle 
requirements and application of 
regulation 118 to class I vehicles with 
CNG propulsion; requirements for 
emergency responder access to the 
engine compartment may also be 
considered. Cost-benefit for automatic 
fire extinguishers not clear; these have 
been encouraged as after-market 
equipment in some markets 

No BCR studies were identified and 
breakeven costs exceed current system 
costs if considered as a stand-alone 
feature. If other systems that share 
hardware with PCD systems are 
mandated and reliable system cost 
estimates can identified, this measure 
should be re-evaluated. In case of 
technology bunching with AEB, this 
measure is expected to be cost-effective 

Page 55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Code 

Measure 

?
e
l
b
i
s
a
e
F

s
t
i
f
e
n
e
B

s
t
s
o
C

R
C
B

HED 

Adult head to 
windscreen 
protection 

 

Benefit for head to windscreen contacts is 
up to 500 fatalities and 11,000 serious 
injuries (~ € 3 billion) in M1 vehicles 

In M2/M3 and N2/N3 vehicles this could be 
up to 150 fatalities and 1,650 serious 
injuries 

REV 

Reverse detection: 
Reversing detection 
and reversing camera 
systems to prevent 
accidents involving 
children behind 
reversing cars 

 

Benefit on basis of damage-only accident 
mitigation. No clear effectiveness 
information for EU casualty reduction and 
dependent  upon  technical solution 
(camera, ultrasonic, etc).  

Pedestrian airbag assumed to be 
roughly twice the cost of a 
passenger airbag 

Pedestrian AEBS might cost 
somewhere between £ 1,000 and £ 
1,500 as an optional extra 

Costs for M1 vehicles could be 
somewhere between € 3.6 and 12 
billion each year. Stakeholders 
suggest a ten times reduction in 
cost if manufacturing large 
volumes due to economies of scale.  

In the study for the FMVSS, 
NHTSA states that the cost will be 
between $132 and $142 per vehicle 
to fit a system to meet the 
requirements. However, for 
vehicles already equipped with a 
suitable display the cost is 
estimated to be $43 to $45 
(NHTSA, 2014). 

For passive headform 
protection measures, 
anticipated to lie in the 
range <0.25 to 1 

Dependent on the real-
world effectiveness of 
the available 
countermeasures as well 
as the cost 

Summary: <1 to 1 

BCR>1 when including 
damage-only accident 
mitigation. Regulatory 
requirements are being 
introduced in the US, so 
the technology is likely 
to become 
commonplace and costs 
are likely to reduce. 

Summary: >1 

?
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L

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b
a
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a

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M

M1, N1 

M1 

Recommendations/Notes 

BCR <1  to 1, depending on real-world 
effectiveness of measures. There are 
indications that performance of the 
central area of the windscreen can be 
controlled better at negligible cost and 
this should be investigated further. 

Recent work (Edwards et al. 2015) 
indicates that benefit of providing 
protection for head impact against A-
pillars could be substantial. 

BCR>1 when including damage-only 
accident mitigation and regulatory 
requirements are being introduced in the 
US (mandated from May 2018), so the 
technology is likely to become 
commonplace and costs are likely to 
reduce further 

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