Originally Posted by 
RangieBit
				
			 
			Hi Drivesafe,
As I read the ADR the FFRR/RRS/D3/D4 does comply with the provisions. Except....
The problem is that in order to do so it relies on an electro-mechanical link which is absent upon total power loss.
The specifics are in 25.2.6.2.  The key cannot be removed until the transmission is in park, and the lock shouldn't activate until the key is removed. All of which is great until you remove the source of power by which all these actions are signaled. 
Physically you can put the transmission in Park, and this should allow the key to be removed thus activating the steering lock. If all that was purely a mechanical interlock then no problem. This mechanical form of interlock is how Saab do it.
Now for the LR. Putting the transmission in park signals the key solenoid that it can release the key, removing the key signals the steering lock solenoid that it can activate. Take away the power and you can neither remove the key nor turn the steering because both of these solenoids default to LOCKED!!
The engine operates in position II, the engine stops in position I and the key comes out in position 0. All of this is in full accordance with the ADR. The rest however only complies on the condition that the battery is supplying power. 
The pyrotechnic that detaches the battery only activates if there is enough accident trauma to trigger the rest of the SRS system. In an accident situation that traumatic, locked steering is kinda the least of your troubles. The wheels may not be contacting tarmac anymore anyway.
The system design criteria for all the interlocks seems to have ignored a total power failure (outside of an accident) scenario.
So, compliance depends upon power. Therefore I see only partial compliance. The ADR has no exception or conditional clause.
That's my reading anyway.  
Good luck with the discussions with LR.
Iain