According to Reimer and Seed 1997(Factors Affecting Apparent Position of Steady-State Line), ICU

tests were used as a standard / control against which other results were compared. It is the
recommended method of determining the steady-state line of a sand. Poulos 1985 because it is the
recommended method for determining the steady-state line for a sand.
Chern 1985 Thesis
The undrained loading behaviour of sands is an area of particular interest as such materials can be
subject to deformations and cause to flow like a frictional fluid. Undrained shearing can be due to
rapid static loading, which results in an undrained response in the sand.