[ID] => 7520
[post_author] => 34
[post_date] => 2017-01-22 10:31:23
[post_date_gmt] => 2017-01-22 10:31:23
[post_content] => The Joint Meeting of the RID Committee of Experts and the Working Party on the Transport of Dangerous Goods of the UN Economic Commission for Europe (ECE) (WP15) was held in Geneva from 19 to 23 September 2016. Claude Pfauvadel (France) continued as chairman, with Helmut Rein (Germany) as vice-chair.
Delegations from 25 states attended the meeting, along with representatives of the EU, the Organisation for Cooperation between Railways (OSJD), 18 accredited non-governmental organisations and one other organisation seeking consultative status.
The meeting’s agenda included a few last-minute changes to the 2017 texts of the regulations governing the transport of dangerous goods by rail (RID), road (ADR) and inland waterways (ADN) between member states. The bulk of the papers, however, looked ahead to the 2019 texts, bearing in mind that the UN Sub-committee of Experts on the transport of dangerous goods (TDG) had not at the time completed its work on the revision of the UN Model Regulations.
WORKING GROUP ON TANKS
As is the tradition, papers relating to the transport of dangerous goods in tanks were passed to a specialised working group, which met under the chairmanship of Arne Bale (UK). The working group delivered to plenary a report containing 12 recommendations, each of which was adopted.
The European Committee for Standardisation (CEN) asked the working group’s opinion of the value of the standard EN 16522 on flame arresters for breathing devices. This had been discussed at the previous session, where questions had been raised about the standard’s technical accuracy and also, seeing as it largely replicates the requirements of ISO 16852, whether it had any value in ADR.
There were still questions about the wording of EN 16522 and in the end it was decided that the best course of action would be to include some requirements in 22.214.171.124.3 rather than cite the standard. A formal proposal will be worked up for the next session.
The European Industrial Gases Association (EIGA) reported that the informal working group on provisions on equipment for tanks and pressure receptacles had largely finished its work om pressure receptacles and would need the assistance of tank experts to complete its tasks. In particular, this involved an examination of the completeness of requirements on the design, conformity assessment and marking of service equipment of tanks.
It was noted that some of the relevant issues were currently under consideration by the informal working group on the inspection and certification of tanks and that it would be best to defer discussion until this group reported at the March 2017 Joint Meeting.
Russia explained that, to protect empty tank wagons for the carriage of liquefied gases against implosion during very low ambient temperatures, SMGS Annex 2 prescribes a residual pressure to be maintained after discharge. A paper on this subject had already been presented to the RID Committee of Experts, which thought it worth passing on to the Joint Meeting for consideration.
There was no support for adding a similar provision in RID; experts felt the provisions in SMGS do not offer any benefits over and above those already contained in 126.96.36.199.4 of RID/ADR.
Several experts expressed support for a Dutch proposal to include a pressure setting for bursting discs as this would improve harmonisation by removing the role of the competent authority. However, the European LPG Association (AEGPL) expressed concern regarding the possible effect on safety valves for gases and there were other issues regarding hermetically closed tanks. It was decided to ask EIGA if tanks for the carriage of gases with safety valves and bursting discs exist and if so what the set pressures are.
Another paper from the Netherlands raised several topics that had been identified during a review of older national guidelines. The first of these brought with it a proposal to include a requirement for a fire-safe design for internal stop valves in tanks for liquefied gases. Industry representatives expressed severe doubts as to the value of such a suggestion and remarked that no such valves are available. There was some confusion as to the intent of EN 12252 and EN ISO 10497 on this topic; AEGPL was asked to check with the relevant technical committee at CEN.
A second issue concerned sight glasses in LPG tankers; these are prohibited in 6.8.2 but there is an apparent exception for sight glasses on the tank shell in 6.10. It was agreed that the current situation is unclear and two changes were accepted, although both remain in square brackets pending confirmation.
A new paragraph 188.8.131.52 reads:
Glass level-gauges and level-gauges made of other fragile material, which are in direct communication with the contents of the shell, shall not be used.
In 184.108.40.206(f), second sentence, “Sight glasses” is replaced by “Glass level-gauges and level-gauges of other suitable transparent material”. The first sentence of 220.127.116.11.6 is deleted.
The Dutch paper also raised a problem with those safety valves that, because of their design, may collect rainwater and spray; in cold conditions that collected water can freeze and prevent proper operation of the valve. The working group saw the value in making a change and agreed to add a new paragraph at the end of 18.104.22.168.9, which for now remains in square brackets in order to allow EIGA to check that the protective caps would not have adverse effects on the proper functioning of the safety valves:
Safety valves that may collect water, for example due to rain or spray, which would prevent their correct functioning, for example if the water freezes, shall be provided with a protective cap. The protective cap shall not affect the performance of the valve.
It was agreed that there is a need for a transitional provision and tentative text was agreed for the new 22.214.171.124 and 126.96.36.199; these may allow tanks to continue in service with non-compliant safety valves until their next intermediate or periodic inspection.
The Netherlands also presented a report from the working group on tanks with a protective lining or coating. This had generated several specific proposals, which were mostly adopted.
While it was accepted that pH values are not the best indicator of corrosivity, the principle of regulating the use of aluminium alloy lined tanks by including a special provision TU in 4.3.5 against particular UN numbers was accepted. This solution would prevent the use in practice of tanks with an aluminium shell and a protective lining for substances with clearly identified as having a significant corrosive effect on aluminium alloy. An alternative approach based on the application of classification criteria for corrosivity could be developed in the future.
A new definition will be added in 1.2.1, together with a Note:
“Protective lining” (for tanks) means a lining or coating protecting the metallic tank material against the substances to be carried;
NOTE: This definition does not apply to a lining or coating used only to protect the substance to be carried.
Two new transitional provisions will be added:
188.8.131.52 Tank wagons/Fixed tanks (tank vehicles) and demountable tanks with a shell constructed of aluminium alloy, including those with protective lining, constructed before 1 July 2019, used for the carriage of substances which do not conform to the requirements of special provision TU42 of 4.3.5 applicable from 1 January 2019 may continue to be used for the carriage of these substances until 31 December 2022.
The second transitional provision, 184.108.40.206, provides the same details for tank containers.
In the Dangerous Goods List (Table A of Chapter 3.2), “TU42” will be added in column (13) against UN 1755 PG II and PG III, 1778 PG II, 1779 PG II, 1788 PG II and PG III, 1789 PG II and PG III, 1791 PGII and PG III, 1803 PG II, 1805 PG III, 1814 PG II and PG III, 1819 PG II and PG III, 1824 PG II and PG III, 1830 PG II, 1832 PG II, 1840 PG III, 1906 PG II, 2031 PG II, 2581 PG III, 2582 PG III, 2586 PG III, 2693 PG III, 2796 PG II, 3264 PG II and PG III.
The new special provision TU42 in 4.3.5 will read:
Tanks with a shell constructed of aluminium alloy, including those with a protective lining, shall only be used if the pH value of the substance is not less than 5.0 and not more than 8.0.
In 220.127.116.11.2, after the second set of indents, “an ebonite or thermoplastic coating” will be replaced by “a protective lining”.
A new paragraph will be added to the end of 18.104.22.168.2 and 22.214.171.124.3:
Protective linings shall be visually examined for defects. In case defects appear the condition of the lining shall be evaluated by appropriate test(s).
CEN sought clarification of the meaning of “in special cases” in footnote 10 of 126.96.36.199.1. The working group struggled to find a legal meaning and it appeared that the wording was introduced in the 1970s to allow the hydraulic pressure test to be conducted with a gas rather than water. It was noted with pleasure that CEN has initiated a new work item to develop a specific standard concerning testing with a gas for use at the discretion of the competent authority.
France sought clarification on the provisions that prohibit the carriage of tanks designed for use with UN 1744 bromine after the expiry date of the annual lining inspection. Industry appears to be of the view that there is some leeway in the provision to allow, for instance, the transport of these tanks for the purposes of inspection.
The working group confirmed that this is not the case and it was clear that some amendment is necessary to clarify the situation. The working group liked a proposal put forward by the US and, once this has been adopted for UN tanks, it may need to be similarly adopted for RID/ADR tanks.
Russia proposed the revision of 188.8.131.52.3 of RID/ADR, saying that multiple repetitions of textual and numerical data and excessive information present a serious impediment to the correct understanding and use of this information. The working group agreed with the approach and asked the Secretariat to finalise a tabular representation of the information.
Germany raised a question concerning the use of nitrogen for cooling portable tanks intended for the carriage of refrigerated liquefied gases; in particular, how do the regulations for inland and seagoing ships deal with the permanent and intended release of nitrogen?
Because of stowage regulations for sea transport (stowage category “D”) these tanks can be placed only on deck where ventilation is no problem. It was not expected that there would be any ventilation issues in road or rail transport.
A second informal paper from Germany queried the interpretation of “diameter” in 184.108.40.206.18 and 220.127.116.11.19; there can be differences in the calculation depending on whether the internal or external diameter is used. The working group confirmed that, in line with 18.104.22.168.17, the internal diameter should be used. Germany will prepare a formal proposal for revision of the text for discussion at the next session.
Portugal felt there was a conflict in the tank plate provisions in 22.214.171.124.2 and 126.96.36.199.3(c) and thought it would be useful to separate the tank plate provisions for multipurpose tanks could be separated from those for dedicated tanks.
The working party felt that Portugal’s interpretation was correct but noted that the required details should be included in the transport document. The Joint Meeting thought it would be advisable to look more closely into the problem described.
WORKING GROUP ON STANDARDS
There were only two official documents presented under the heading of ‘standards’ and these were passed to the Working Group on Standards.
CEN updated the Working Group on its activities of relevance to RID/ADR/ADN over the previous six months, also noting that changes to its procedures have been designed to speed up the standard-making process. The experts were invited to take part in some new work streams covering gas cylinders, LPG road tankers and service equipment for tanks for the transport of dangerous goods. The Working Group also reviewed progress already being made with other standards that are currently in draft form.
The Working Group made a number of specific proposals, which – with some changes – were adopted by the Joint Meeting.
In the table in packing instruction P200(11), the first two rows (EN 1919:2000 and EN 1920:2000) will be deleted and replaced by EN ISO 24431: - Gas cylinders - Seamless, welded and composite cylinders for compressed and liquefied gases (excluding acetylene) - Inspection at time of filling.
That change is reflected in a textual amendment in paragraph 2.1 of P200(13).
In the table in 188.8.131.52, under “For design and construction”, an expiry date of 31 December 2020 is added against EN ISO 11120:1999 + A1:2013 and a new entry is inserted immediately after that row for EN ISO 11120:2015 - Gas cylinders - Refillable seamless steel tubes of water capacity between 150 l and 3000 l - Design, construction and testing.
In 184.108.40.206, EN 1252-1:1998 will be replaced by EN ISO 21028-1: Cryogenic vessels - Toughness requirements for materials at cryogenic temperature - Part 1: Temperatures below -80°C.
INTERPRETATION OF RID/ADR/ADN
The International Union of Railways (UIC) asked whether the provisions of 220.127.116.11.1 also apply to a technical name that might be required to be shown on the transport document. According to 18.104.22.168.1 it seems clear that a technical name in English, French or German must be shown in the transport document. However, UIC claimed, there may well be technical names for which there is no ‘official’ designation/translation in English, French or German. Further, must a carrier be in a position to judge whether a technical name has been correctly entered in the transport document?
The Joint Meeting confirmed that 22.214.171.124.1 does apply to the technical name. It also was of the opinion that the carrier is not expected to be in a position to judge whether a technical name has been correctly entered in the transport document.
Discussions also revealed some differences between RID and ADR/ADN, which may be addressed in a future proposal.
EIGA asked for clarification on the intention of two transitional measures, 126.96.36.199 and 188.8.131.52, that were adopted along with new provisions for the marking of bundles of cylinders in the 2015 texts of RID and ADR.
The Joint Meeting acknowledged that the provisions in question were the subject of different interpretations on the part of certain operators and inspection bodies. It noted, however, that the wording of the provisions was consistent with usage and that a modification of the wording would involve reformulating many other transitional provisions.
To answer EIGA’s question, the Joint Meeting confirmed that the transitional provisions apply only to the marking of bundles of cylinders, which may continue to be used with the old marking until their next periodic inspection.
CORRECTIONS TO 2017 TEXTS
Switzerland had spotted what it thought was an error in the text of special provision 363(a); the Joint Meeting agreed and deleted “in quantities above those specified in column (7a) of Table A of Chapter 3.2”.
Germany noted that, in the table in 184.108.40.206, in the heading of the last row and of the last column, “9” should read “9, 9A”.
Both of these amendments are corrections to the 2017 texts of the regulations.
PROPOSALS FOR AMENDMENT
DGSAs The European Association of Dangerous Goods Safety Advisers (EASA) proposed the insertion of transitional measures for requirements relating to safety advisers in undertakings whose activities were limited to the consigning of dangerous goods, which were accepted by the Joint Meeting. These will read as follows:
220.127.116.11 Undertakings which participate in the carriage of dangerous goods only as consignors and which did not have to appoint a safety adviser on the basis of the provisions applicable until 31 December 2018 shall, by derogation from the provisions of 18.104.22.168 in force from 1 January 2019, appoint a safety adviser no later than 31 December 2022.
22.214.171.124 Contracting Parties/Contracting States may, until 31 December 2020, continue to issue training certificates for dangerous goods safety advisers conforming to the model applicable until 31 December 2018, instead of those conforming to the requirements of 126.96.36.199 applicable from 1 January 2019. Such certificates may continue in use to the end of their five-year validity.
Another proposal from EASA to include guidelines for harmonised annual safety adviser reports was not so well received; some countries already have mandatory formats while others believe a degree of flexibility is needed, depending on the mode of transport and the nature of the business concerned.
Discussion also turned to the purpose of the annual report – is it to inform the directors of the company about dangerous goods activities or is it for the benefit of the competent authority? EASA was asked to give the matter more thought and return with a revised proposal if it felt it is warranted.
A further proposal to extend the scope of current DGSA requirements to the handling or operation of tank containers, portable tanks and tank wagons also drew reservations from several experts. It might interfere with other operator obligations. EASA was again invited to submit a new proposal.
Refillable pressure receptacles AEGPL reported on the outcome of discussions by the working group on alternative methods for periodic inspections of refillable cylinders and put forward a proposal for a general provision covering such alternative methods. The paper also included a proposals for further work and a draft agenda for the next session of the working group, due to take place in January 2017.
EIGA proposed extending the scope of 188.8.131.52.6, which permit information relating to the periodic inspection and testing of cylinders to be “engraved on a ring of an appropriate material affixed to the cylinder when the valve is installed…” to also cover pressure drums. The Joint Meeting felt this was acceptable.
Mazut Russian raised the question as to whether mazut – a heavy heating oil – could be assigned to UN 1202 in the same way that diesel, gasoil and light heating oil may be, by virtue of Note 2 to 184.108.40.206.1. Many delegations were supportive of the idea, which may need mazut to be listed as a proper shipping name. Russia was asked to return with a more precise proposal with more detail on how the product is transported.
Traceability Having already raised the issue with the RID Committee of Experts and having been advised that this was a matter for the Joint Meeting, Italy proposed that anyone with responsibilities under the security provisions in 1.4.2 or 1.4.3 should retain for at least three months documentary evidence that all obligations under RID/ADR/ADN have been met.
Several delegations felt the proposed text was too general. Italy will present a revised version and examine whether consequential amendments will be needed.
Danger and risk In response to a paper from Romania, the Joint Meeting noted that the UN TDG Sub-committee had adopted a large number of editorial amendments aimed at harmonising the use of the terms “danger” and “risk”. Romania was asked to draw up a detailed proposal for discussion at the next session of the Joint Meeting.
Visual inspection According to 220.127.116.11.1(c), the carrier has to carry out a visual inspection of the load. At the previous session of the Joint Meeting Austria had queried how this can be done when the cargo transport unit concerned is sealed. Following those discussions it returned with a formal proposal.
After lengthy discussion it was decided to make one amendment, adding at the end of 18.104.22.168.2:
In the case of 22.214.171.124.1 (c) he may rely on what is certified in the “container/vehicle packing certificate” provided in accordance with 5.4.2.
Waste collection The European Federation of Waste Management and Environmental Services (FEAD) explained that, for waste collection, metal containers perform two roles; they are used as 4A boxes for carrying small receptacles and as IBC 11A for carrying bulk solids. They meet the requirements of both Chapter 6.1 and Chapter 6.5 and carry a double marking. However, the definition of IBC in section 1.2.1 excludes packagings specified in Chapter 6.1. An amendment to the definition was proposed.
Several delegations felt that such a change might have broader implications and that it should be put to the UN TDG Sub-committee. There might also be another way to resolve the problem as far as RID/ADR/ADN are concerned. FEAD was asked to prepare a new proposal for the next session, with more detailed explanations regarding the types of receptacles in question.
Lamps Another paper from FEAD proposed extending the exemption under 126.96.36.199(a) to TL low pressure discharge lamps collected from enterprises, and not just from individuals. Opinions were divided, with some delegations observing that the exemption exists to provide some relief for craftsmen or small enterprises that would find it difficult to comply with the full provisions and that this should not be the case with large companies.
FEAD was invited to recast the proposal in the light of comments made. The chairman observed that, considering the doubts that some delegates had expressed about the interpretation of 188.8.131.52 and special provision 366, it might be worth reviewing the intent of the measures in the UN Model Regulations.
INFORMAL WORKING GROUPS
EIGA reported on the progress it is making, in concert with the Compressed Gas Association (CGA), towards acceptance by the US authorities of RID/ADR pressure receptacles in exchange for the acceptance by the European authorities of DOT receptacles. It is hoped that such a reciprocal agreement can be in place by 2019, in which case the conditions currently contained in multilateral agreement M299 could be incorporated into RID/ADR.
Germany reported on the second meeting of the informal working group on the transport of waste electrical and electronic equipment (WEEE) containing lithium batteries. The report included a proposal to delete special provision 363(a) and to amend special provisions 363 and 363(b).
The Joint Meeting adopted the proposals pending a check on the English text by the UN ECE Secretariat. The French and German texts will also be checked. Germany will proposed a multilateral agreement once those texts have been finalised.
The EU Agency for Railways (ERA) reported on the seventh meeting of the Workshop of the roadmap on Risk Management of Inland Transport of Dangerous Goods, which had taken place in June 2017. The report described the progress made in three areas: the description of accident parameters, a harmonised approach to risk estimation, and a harmonised approach to decision making. The eighth meeting was due to take place in October 2016.
A request for consultative status from the Council on Safe Transportation of Hazardous Articles (COSTHA) received broad support but further information was requested, particularly with regard to the mechanisms of accountability to the Council’s members and how its members exercised control over its policies.
The UK followed up on informal discussion at the previous session of its idea to form a working group that could take on the job of making amendments to the regulations that are purely editorial in nature, leaving the plenary with more time to discuss substantive proposals.
Most delegations supported the idea of improving the editorial quality of the regulations but considered that the proposal underestimated the scope and complexity of the task. It has often been the case that amendments that appear to be purely editorial have in the end raised debate on substance or on the interpretation of the texts in force. Furthermore, if the group worked only in English it would still be necessary to examine the repercussions for the French, German and Russian texts. Overall, it could not be assumed that such a group would end up saving time.
The UK, recognising a lack of enthusiasm for the project, will consider alternative solutions.
The Joint Meeting was informed of the impending retirement of Steen Riis Thomsen, a longstanding member of the Danish delegation. This was to be his last time at the Geneva meetings and he was wished a long and happy retirement.
The UN ECE Inland Transport Committee (ITC), parent body of WP15, is planning to develop a strategy running up to 2030. A questionnaire had been sent to all delegates participating in the work of ITC and its subsidiary bodies, and all delegates of the Joint Meeting were invited to respond to this questionnaire since their contribution would be taken into account in the definition of the ITC strategy.
The next session of the Joint Meeting will take place in Bern from 13 to 17 March 2017.
[post_title] => Europe: Cracking on
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The Joint RID/ADR/ADN Meeting has started work on the amendments that will appear in the 2019 regulations. Stand by for some surprises