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58th Session GRSP – Geneva, 8-12/12/2015

This document discusses the need to update the references to the European standard on toxicity and flammability in child restraint systems regulations. It provides a recap of the considerations needed to discuss this topic and compares the flammability performance of materials used in current child seats. The document concludes that the proposed EN71-2 standard does not lower the overall protection for children against fire hazard.

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58th Session GRSP – Geneva, 8-12/12/2015

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  1. Informal document: GRSP-58-25 (58th GRSP, 8 - 11 December 2015, agenda items 15 and 19) 58th Session GRSP – Geneva, 8-12/12/2015 Toxicity and FlammabilityRequirements in Child Restraint Systems Regulations UN R44 and UN R129 Erik Salters Erik.salters@dorel.eu

  2. Updatingthe references to the European standard on toxicity and flammability GRSP 57th session agreedto resume discussion in the 58th session on the basis of a revisedproposaltabled by the expert from CLEPA in cooperationwith the expert from OICA. A recap of the considerationsneeded to discussthis topic: • Child safetyneeds to balance flammabilityrequirementswiththoserelated to toxicity. EN 71 standard wasspecificallywritten for thispurpose and deals withproductsthat are in close contact withchildren. • This viewisalsoshared by consumer testing, wherechemicaltestingisconducted on childrestraint parts that are likely to come into contact with the mouth of the child. • Child care productsalreadyneedto fullfill the EN71-2 standard • GRSP’sMay 2015 session favoured the EN71 standard for alignment of R129 and R44. • It isalso important to definewhichtestingmethods and criteria are used. Clepaisasking GRSP to considerthese aspects.

  3. Flammability(summary of 57th GRSP) In the last GRSP a requestwasmade to CLEPA to show that the requirements for child protection are not lowered by the proposedreference to EN71-2 2011 § 4.4 vs the R44 method. This iswhatwedid: • CLEPA compared the performance of materialsused in currentchildseats. • Accidentologydoes not show problemswith the materialsusedtoday. • A comparisonwasmade, testing the materialsagainstthe R44 standard, and the EN71-2 standard.

  4. NBR = No Burn Rate IBE = extinguished after removal of flame DNI = does not ignite SE = Self extinguishing 29 different materials Samples tested

  5. Flammability For eachmaterial, weconducted 2 tests, one to the R44 test, and another to the EN71-2 specifications. Wenormalized the burning rate results to their respective limits. To do this, weassessed how much % of the maximum allowedburning rate isused. • ExampleEN 71-2 2011 § 4.4 (Req 30 mm/sec) • Material A burned22 mm in 1 sec, of a limit of 30 mm = 73% used, 27% ‘buffer’ remaining. 22mm

  6. Flammability Comparing 2 different tests Material A burned22 mm in 1 sec. The limitis 30 mm = 73% used, 27% ‘buffer’ remaining. Samematerial (A) burned 180 mm in 1 min. The limitis 250 mm = 72% used, 28% ‘buffer’ remaining. These test show thatfor thismaterial, both tests are equal in severity(72% vs 73%) Test 1 22mm Test 2 180mm

  7. a relative comparison of R44 vs EN71-2 % • 29 materials are tested twice: • For each material 2 tests are conducted, the green rectangle indicates such a ‘pair’. • No bar means no value; “Self Extinguished” or “no burn” • Sample 3 fails EN71-2 (100% burn), but passes R44 (no burn) Session 1/2015, 24-25 February 2015

  8. a relative comparison of R44 vs EN71-2 % • Green circleindicatescomparable R44 / EN71-2 result pair (19) • Blue square indicates a difference in results; R44 is more stringent (4) • Red square indicates a difference in results; EN71 is more stringent (6) Session 1/2015, 24-25 February 2015

  9. Are requirements for child protection loweredwith the proposed EN71-2 2011 § 4.4 vs the R44 method? • 19 tests show comparable results. • 6 tests show that EN71-2 is more severe • 4 tests show that R44 is more severe

  10. How to test sandwich materials? Non composite material • When different materials are connected together intermittently (for example, by sewing, high-frequency welding, riveting), such materials shall not be considered as composite materials and therefore tested separately Composite material • “Composite material" means a material composed of several layers of similar or different materials intimately held together at their surfaces by cementing, bonding, cladding, welding, etc. In such a case the material is tested as a composite.

  11. Conclusions Althoughthe 2 tests are not a literaltranslation of eachother, they do notlower or increasethe overall protectionforchilderenagainstfirehazard. • For childsafetythereis a need to balance flammabilityrequirementswiththoserelated to toxicity • Clepaisasking GRSP to consideritsMay’sproposal in light of theseexplanatory notes

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