Vision Hero - Lighting Kit

Initiative details

The Vision Hero initiative highlights an area where VM are compliant using Para 5.21 (5.21.2) of the European R48 Lighting Regulations in such cases where the rear lights are blocked by more than 50% by moving components (i.e. Rear Doors). Placing a notice AND communication in the vehicle (owners handbook) therefore gives the VM full compliance. However, the liability then reverts to the owners / operators to notify other road users of the presence of the vehicle. The initiative using Para 5.21 but 5.21.1 of the said mentioned regulation to result in the vehicle being seen with the rear door/s open - therefore the owners / operators have no requirement to notify other road users of the presence of the vehicle because the vehicle can be seen under these conditions. Major efforts were made to ensure that full compliance in accordance with 5.21.1 including Gaining E.U. Type Approval, all position, geometric visibility, colorimetric and photometric requirements were addressed. Both EU and National (Irish) legislation was fully adhered to when putting the kit together. The support slides and videos demonstrate the current situation and also shows a vast improvement when using the initiative kit proposed. This results in a massive road safety improvement pertaining to involved units in Europe.

Initiative date

to

Who was/is your target audience?

Policy makers
Public authorities
Company employees
Fleet operators
Emergency services
Van drivers
Cyclists
Pedestrians

Topic

Create awareness
Improve vehicles and infrastructure
Provide alternative solutions

Organisation details

Auto Regulations Ltd
Enterprise
Ireland
Kildare Town, County Kildare Ireland

Contact name

Jim Mulholland

Telephone number

00353862349676

Project activities

If you work together with external partners, list the most important partners and briefly describe their role.

The project requires the support of the governing / implementing authorities in Ireland. Acceptance of Para 5.21.1 within the true spirit of the regulations and therefore enhancing the rear of the units involved for a better and safer road practice for all. In Ireland this would be RSA – It is vital that support is gained from them and also agreement that it is just not as easy as fitting additional lights to the rear – as compliance must be within the parameters of the regulations & legislation. This issue is European wide and again support from RSA is vital.
If this submission was successful, that would be a major boost for the initiative and indeed support to implement such an improvement.
Ideally having a Brand Champion and / or several Fleet Champions on board would be perfect to showcase the initiative and portray them as being active and progressive. Support from RSA and indeed any recognition from the European Road Safety Charter would really provide encouragement to implement our initiative.
This is also the case with the remainder of the relevant authorities in E.U. Member States.
Auto Regulations would like to partner with Road Victims Associations in any country that it sells / installs the initiative kit.

Please describe the project activities you carried/are carrying out and the time period over which these were implemented.

Vision Hero Initiative – 2023 European Road Safety Charter Awards

Introduction: Several years ago, I noticed a safety related issue pertaining to N1, some M1 and rear drop tailgate trailer units. On studying these units in operation, it soon became very apparent in my opinion that this was a very serious road safety issue. An issue that involves the safety of not only those with “Reduced Mobility” but all road users (Cyclists, Pedestrians, Oncoming traffic and in particular the operators of N1 units).
Issue in Hand:
European Regulation – R48 Lighting. Approval of vehicles regarding the installation of lighting and light signaling devices. (Para(s): 5.21 / 5.21.1 / 5.21.2 & 5.21.3)
* Attention should be given to the direction - in the event that the rear lamps are obstructed (>50%) – Placing of a warning triangle to notify other road users.

The Irish Road Traffic Act further confirms and supports the wording / direction within the European Lighting Regulation.

** Various national legislations within each EU Member State. Example above is that for Ireland.

Important Note: All vehicle manufacturers having model variants that the rear doors (moveable components) block the rear lights when opened to 90’ or more are Fully Compliant by implementing Para 5.21.2 = Place a remark in the communication form AND a notice in the vehicle. * Not ALL VM’s comply with 5.21.2. ** Para 5.21.3 confirms 5.21.2 does not apply to retro-reflectors.

Current Situation: 1. Units that the rear doors when open block the rear lights result in Zero Vision of the rear of the vehicle (Please refer to the attached support presentation(s)). 2. I researched and concluded that ALL operators spoken with were not aware of the issue in hand also were totally unaware of what the notice means. (Please refer to the attached presentation and samples of various notices displayed – I think you will agree that while there is a notice (on most but not all units) it is not very clear as to the message portrayed however, the notice AND remark if placed on the vehicle provides coverage but leaves an “in the dark” outcome.

Solution Reached: Presently VM’s avail of Para 5.21.2 Auto Regulations have zoned into Para 5.21.1 which in accordance with the Regulation R48 (pg28) is a clear option (wording states 521.1 OR 5.21.2 and are part of 5.21).
It is vital that ALL requirements of 5.21.1 are met - such as stipulated with the complete Para and indeed definitions of what is a “Lamp”. Auto Regulations developed a specific Lamp and secured European Type Approval. There was no lamp with EU type approval suitable to fit between the rear doors and it was vital that any solution was / is fully compliant. Developed a wire harness which allows easy fitment and also use a photoelectric sensor and relay box to allow full coverage within Para 5.21.1.

* Research concluded on all light commercial vehicles (N1).
* Issue arises on current models UIO on the road & new model variants.
* Detailed design and prototyping of solutions concluded / Design and ECE Compliant *
* Working prototype completed and is compliant with all necessary design requirements.
* Is applicable to N1 vehicle types (**270’ Rear French / Barn Doors) + some M1 units.
* Easy to manufacture (as a kit form – **x2 + Accessories)
Low unit cost to produce -Is a proprietary “plug and play” electrical harness module with lighting.

Results in: Compliance, Governess and Safety Improvement in accordance with Para 5.21.1. It has the effect of improvement from “Zero Vision” to “Vision Hero”.

** This initiative if supported and encouraged would provide such an improvement from a road safety point of view and it would allow the operators of involved units to not be required to place a warning triangle when parked and rear doors block >50% of the rear lights.

*** Disclaimer: The sample vehicles shown with the attached slides are only for reference and not intended to appoint any blame or indeed expose the manufacturer or operators in anyway.

**** Several slides show vehicles that transport/ carry people with reduced mobility and when taken in conjunction with other slides really highlights the seriousness of the actual situation and demonstrates the need for the initiative proposed.


Please click on the slides in the attached support documents which show video proof of the severity and zero vision of the rear when the rear doors are open, and the rear lights are blocked by more than 50%.

Evaluation

What has been the effect of the activities?

The project / initiative is currently at the roll out stage. A lot of preparation work, investment in obtaining EU Type Approval and developing a fully compliant kit that covers all areas required under both European and National legislation. There is the perception that once both the requirements of 5.21.2 means coverage however, currently this means that ALL of the obligations are on the operators. By submitting this initiative to the European Road Safety Charter Awards would really support the benefits and improvements of such a kit. It will allow for a massive improvement in safety of all involved and in fact it is with keeping within the framework of the regulations / legislation. It will make the units more visible when used under the conditions outlined, it should allow for not having to place a warning triangle and the requirements of using same. Not all manufacturers / distributors meet the requirements of 5.21.2 – some have only one of the requirements and they are either not aware of their obligations or they accept to leave things as is theory. This is truly frightening in my opinion but actual.

Please briefly explain why your initiative is a good example of improving road safety.

Excellent example of improving / enhancing the rear of the vehicle (with one or both rear doors open to 90’ and obstructing the rear lights). The examples shown within the supporting documents coupled with the regulations / legislation provided make for the massive road safety improvement by this kit / initiative. The initiative goes to extreme lengths to ensure that each requirement is covered and using the 5.21.1 of Regulation R48 Lighting provides full compliance, it also ensures that every area has been investigated and results in the initiative will have a major improvement on road safety in this area. The initiative highlights the importance of developing a kit that ticks all the necessary requirements in meeting the stringent contents of the regulations – the kit is compliant in every way and is not just placing additional lights on the units involved. This is a very good example and one that is vital because any such kit MUST meet the compliance of the EU.

How have you shared information about your project and its results?

The project is currently at the roll out stage and I feel by submitting this application to the European Road Safety Awards should have a massive backing to the project / initiative going forward. This will have an impact when seeking the input and involvement of fleet, Government and NGOs coupled with owners of involved units installing the initiative to their units.
The participation of the awards will be used to promote the initiative / kit going forward. Increase the sales / fitment of the initiative / kit.

Supporting materials

Attachments