GSPR – Is it a four-letter word?

The General Safety Protection Regulation is a mouthful, and it’s going to be here to stay from 2022. What will it mean for independent garages in practice?

By Neil Pattermore |

Published:  04 June, 2020

The Americans love acronyms. They even have an acronym for acronyms – ‘TLA’ is a ‘three letter acronym’. Well, there is now a new acronym to remember, but this one is from the EU and has four letters (should that then be a ‘FLA’?) – ‘GSPR’, or more correctly known as the ‘General Safety Protection Regulation’. The official title is the ‘REGULATION (EU) 2019/2144 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 November 2019 on type-approval requirements for motor vehicles and their trailers, and systems, components and separate technical units intended for such vehicles, as regards their general safety and the protection of vehicle occupants and vulnerable road users’, a snappy little title that does not roll off your lips as easily as ‘GSPR’. This new Regulation has now passed into EU vehicle type approval law and will impose changes to vehicle design for all new vehicle models that are entering the market (i.e. new vehicle type approvals) from 6 July 2022.

Motivation
Let’s look at what this new Regulation is all about, and what relevance does it have to independent workshops.
    
The motivation behind this Regulation is to address the problem of 25,300 people dying on Europe’s roads in 2017; a figure that has remained constant in the previous four years. Moreover, 135,000 people are seriously injured. In addition to the safety measures to protect vehicle occupants, there are also specific measures to prevent fatalities and injuries of vulnerable road users, such as cyclists and pedestrians to protect road users outside of the vehicle.
    
By mandating these new safety systems, there should be a reduction in these figures, but equally, these vehicle systems will need diagnostics, repair and re-calibration, so there is a welcome potential for independent workshops.
    
In simple terms, the legislator has imposed new safety related systems for new vehicles, but these systems are mainly Advanced Driver Assist Systems, or ‘ADAS’ as a better-known acronym. The list of these new systems is:

  •  Advanced emergency braking (cars, vans)
  •  Alcohol interlock installation facilitation (cars, vans, trucks, buses)
  •  Drowsiness and attention detection (cars, vans, trucks, buses)
  •  Distraction recognition / prevention (cars, vans, trucks, buses)
  •  Event (accident) data recorder (cars, vans, trucks, buses)
  •  Emergency stop signal (cars, vans, trucks, buses)
  •  Full-width frontal occupant protection crash test - improved seatbelts (cars and vans)
  •  Head impact zone enlargement for pedestrians and cyclists - safety glass in case of crash (cars and vans)
  •  Intelligent speed assistance (cars, vans, trucks, buses)
  •  Lane keeping assist (cars, vans)
  •  Pole side impact occupant protection (cars, vans)
  •  Reversing camera or detection system (cars, vans, trucks, buses)
  •  Tyre pressure monitoring system - TPMS (vans, trucks, buses)
  •  Vulnerable road user detection and warning on front and side of vehicle (trucks and buses)
  •  Vulnerable road user improved direct vision from driver’s position (trucks and buses)


Some of these systems are already found on some existing vehicles (e.g. TPMS), but by far the majority are new requirements. This Regulation will therefore introduce a range of new technical test and sensor calibration requirements which will need to be handled in the workshop. So, can you avoid becoming involved? As I was recently told: “If you think that you can avoid ADAS you are kidding yourself. It should be ADAS that does the avoiding, not you!”

Hidden threat/business opportunity
These new systems will help reduce road casualties, but does this also come with a hidden threat to privacy? The event data recorders (EDR) mandated in the GSPR store a range of crucial anonymised vehicle data, including requirements for data range, accuracy, resolution and for its collection, storage and retrievability over a short timeframe before, during and immediately after collision, for example, triggered by the deployment of an airbag. It should be capable of recording and storing data in such a way that the data can only be used by member states to conduct road safety analysis, without the possibility of identifying the owner or the holder of a particular vehicle on the basis of the stored data. So, ‘Big Brother’ is not watching how you drive, yet.
    
With this new Regulation, the legislator has provided you with a great new business opportunity, but it will be up to you to decide how to exploit it. Ultimately, it comes down to three key elements – investment in training, investment in equipment and deciding when to make this investment. Obviously, there will be a cost when making this investment, but the real question will be ‘can you afford not to make this investment?”.
    
You could consider investing in two stages, such as deciding if you want to focus initially on the diagnostics of these ADAS systems, before investing in the equipment to re-calibrate the sensors. However, as many normal repairs, such as replacing a track-rod end, also require four-wheel alignment, the corresponding ADAS sensor re-calibration is already an increasing problem for the workshop. Additionally, it may be best to train your technicians first, so that they know the bigger picture of ADAS systems and avoid the ‘you don’t know what you don’t know’ syndrome.

Competent and capable
The fundamental problem is one of liability. The vehicle manufacturer needs to ensure that the ADAS systems fitted to the vehicle are working correctly and therefore, if they are repaired, that this has been done correctly and the systems re-calibrated.
    
The European Garage Equipment Association (EGEA) is developing an ADAS best practice guide to help workshops clarify what they need to consider when repairing a vehicle to better understand the test and re-calibration requirements of the ADAS systems after other parts of the vehicle have been repaired.
    
This should help counter the claim of the vehicle manufacturers that as they have a direct product liability throughout the life of the vehicle (as these ADAS systems have a direct impact on vehicle control and safety), that only their authorised repairers (i.e. main dealers) can conduct work on these ADAS systems. This is to ensure that the vehicle is repaired correctly and that they can trace who did the repair, using what replacement parts and that the re-calibration was conducted correctly. Consequently, independent workshops need to demonstrate that they are equally competent and capable to also conduct this work on ADAS systems.
  
Subsequently, although this whole new business opportunity for independent workshops, it may be a threat as well as an opportunity. Fundamentally, independent workshops need to invest to create both the competence, capabilities and an audit trail for the work that they conduct on ADAS systems. Coming back to the four letter anacronyms, you should conduct a SWOT analysis (strengths, weaknesses, opportunities and threats) and see how you can exploit the opportunities from ADAS systems that are developing due to the GSPR.
    
OTY…or should that be over to you?

xenconsultancy.com

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