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Comments from Renault (2018-12-06)


-           §.2.2 to 2.4. to define the different levels of the device.

I know we already had a lot of discussions on this part and finally with new reading from our side it seems still not so clear.

We propose 3 levels according either the time and/or the level of the background noise.

  • Time
    • Quiet: at least 10:00 to 17:00 That means we can extend or reduce this period. According to what criteria?
    • Normal: for instance 17:00 to 10:00 only an example so we can fully change this period
    • Very loud times how to define loud? What limit?
  • Back ground noise
    • Around 40dB(A) ~40dB(A) only for a background noise around 40 – so we cannot have a low device below 40 but, according to the next criteria, we can have normal or high device below 40. Strange?
    • Not more than 60dB(A) ≤ 60dB(A) that means from 0 to 60
    • Not more than 80dB(A) ≤ 80dB(A) that means from 0 to 80


Below 40, no device.

At 40, low device.

Between 40 and 60 we can have either a normal or a high device.

Between 60 and 80, only high device.

Above 80 no device


I am not sure this was our intention …


Maybe we should introduce a table ?

Devices level















No device




-           §.2.5. Type-definition

In and we talked about “arrangement”. What does it mean? Should we have an additional definition?


-           §.6.1.1.

6.1.1.         The audible reverse warning device shall emit an intermittent sound acting automatically, activated when reverse gear is selected and the propulsion system is ON engine running .

To be consistent with §.1


-           §.6.3.2. we support 2.00 m


-           §.6.1.1. vs. §. Intermittent sound:

How can we be ‘intermittent’ with Broadband sound and 1/3 Octave band sound?  


-           §.6.3.9. we support 0.5 seconds


-           §.6.4.1.

Do we have to make the tests for all levels especially when the device is not automatically adjustable?


In a general way, for ‘automatically non-adjustable’, do we have to make all the tests for the 3 levels?


-           §.11.2.3.

11.2.3.     The position of the audible reverse warning device(s)   on the vehicle (e.g. h e ight of mounting, position to the end of the vehicle, etc.) ;


-           §.13.4. + 13.7.

What is the interest to have 2 marks? One for the device + one for its installation? Really useful?



Hoping to be almost clear …

Apologies for not being able to attend this meeting.

Kind regards.

Françoise SILVANI