[Treeve]

No mention of temperature, and you can still put your hand on a commodore exhaust if you're an idiot.

Previous versions of this ADR mention no left side, but that version went out in 2005.

Several motorcycles operate under this ADR with exposed headers that the rider can put their hands on and will be the first thing that impacts a pedestrian, with no heat shields or anything else.

You are over thinking it and coming up with things that don't exist. Make sure you comply with what is actually there and you'll be fine.

Treeve