[ID] => 9263
[post_author] => 34
[post_date] => 2018-03-02 13:57:12
[post_date_gmt] => 2018-03-02 13:57:12
[post_content] => The RID Committee of Experts’ standing working group held its eighth session in Utrecht, the Netherlands, from 20 to 24 November 2017. Its main task was to review the amendments adopted by the earlier Joint Meeting of RID/ADR/ADN experts and to transpose them into the 2019 text of RID, which regulates the transport of dangerous goods by rail in Europe and neighbouring regions.
The meeting was attended by representatives of 22 RID Contracting Parties and Russia, which is a member state of the Intergovernmental Organisation for International Carriage by Rail (OTIF) but does not apply RID. Also in attendance were the European Commission (EC), the EU Agency for Railways (ERA), the Organisation for Cooperation between Railways (OSJD) and four non-governmental organisations. The meeting was chaired by Caroline Bailleux (Belgium) with Colin Bonnet (Switzerland) as vice-chair.
The Secretariat had prepared a document listing the texts adopted by the Joint Meeting during 2016 and 2017 and by the standing working group at its November 2016 meeting. A few errors were noticed and corrected. A few matters remained to be finalised by the Joint Meeting and these were left in square brackets for the time being.
The representative of the International Union of Railways (UIC) was asked to provide the NHM codes for the substances that have been added in Table B at the next session.
Russia pointed out that the introductory text of 22.214.171.124 refers to “standards”, whereas at the beginning of the table there is a reference to three European Community directives dating to 1984, which were presumably no longer applicable. Indeed, as the EC representative confirmed, these have been superseded by the Transportable Pressure Equipment Directive (TPED), 2010/35/EU. As the same text is found in ADR, Russia was asked to submit a proposal to the Joint Meeting.
The Secretariat presented another document, this containing the changes adopted by WP.15 at its session earlier in the month (HCB
March 2018, page 78). In order to maintain modal harmonisation between RID and ADR, it would be necessary to adopt those relevant to rail transport into RID. This was done, with a few minor changes. The UIC representative said a proposal would be submitted for the next session to include a reference to the relevant EN standard in the footnote to 126.96.36.199. It was agreed that the transitional provision in 188.8.131.52.1 should be deleted.
A third document from the Secretariat contained proposed corrections to the 2017 edition of RID. Those substantive corrections applicable to the English text are:
Wagons or large containers in which substances of this Class have been carried as full loads, or small containers in which these substances have been carried, shall be checked, after unloading, for any residues of the load.
- In 184.108.40.206.1(e), “empty uncleaned wagons and bulk containers” is replaced by “empty uncleaned wagons and containers for carriage in bulk”
- In Table A of Chapter 3.2, “V8” is deleted from column (16) against UN 1185; “368” is added in column (6) against UN 2908; “325” is inserted instead of “336” in column (6) against UN 2913; and “326” is inserted instead of “336” in column (6) against UN 3326
- In the last paragraph of 220.127.116.11.2, “or suitable contrasting background” is added after “black on white”
- In 18.104.22.168, on the third page of the ‘Instructions in writing according to RID’, the heading of column (2) is replaced with “Hazard characteristics” and that of column (3) is replaced with “Additional guidance”
- In 7.5.11, CW 31 is amended to read:
The International Union of Wagon Keepers (UIP) sought amendment of the text of 22.214.171.124.23 adopted for the 2019 text. This change states that the competent authority or a body designated by the competent authority must verify and confirm the ability not only of the manufacturer but also of the maintenance or repair shop to perform welding operations. UIP felt that this should be extended to inspection bodies according to 126.96.36.199.5.
The standing working group did not share this concern, particularly as the amended text does not limit the role to the competent authority that issued the design type approval. Further, as 188.8.131.52.23 applies only to newbuild wagons, 184.108.40.206.5 is not relevant. The UIP representative was invited to consider the comments made and, if the issue is to be pursued, it should be taken to the informal working group on the testing and certification of tanks, due to meet in mid-December 2017.
Russia has a problem with the references to “ECE” regulations in the new special provision 392 as this abbreviation can also (in Russian translation) refer to the Eurasian Economic Commission, whose members are Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia. As ‘ECE Regulation’ is a standard term used in various places in the modal regulations and other legal provisions, Russia was asked to take the issue to the UN Sub-committee of Experts on the Transport of Dangerous Goods (TDG).
INTERPRETATION OF RID
The Secretariat asked for the working group’s view on an apparent conflict between special provision 319, packing instruction P650 and special provision CE 14 for carriage in express parcels, relating to the carriage of UN 3373 biological substance, category B, packed with dry ice. In particular, P650 requires the primary and secondary packagings to maintain their integrity at the temperature at which the refrigerant is used, while CE 14 says that substances that have to be carried at a specific temperature cannot be forwarded as express parcels.
The standing working group was of the view that such substances may be moved as express parcels, as the coolant used is there to ensure biological integrity rather than to ensure safety during transport.
PROPOSALS FOR AMENDMENT
UIC returned to the issue of the provision of information to the infrastructure manager in cases involving the transport of dangerous goods in limited quantities. Depending on the arrangement of a particular consignment, the infrastructure manager may have no information at all. UIC proposed that a transport document should be provided when limited quantities are being carried, or that the UN numbers should be shown on the transport document.
The working group preferred the first option, especially as this would correspond to the provisions of the International Maritime Dangerous Goods (IMDG) Code and to the UN Model Regulations. However, some questioned why UIC had not considered the interests of consignors or the emergency services alongside those of carriers. In any event, the proposal should in the first instance be put before the Joint Meeting and UIC was advised to substantiate its argument that the requirements of 220.127.116.11 are not sufficient.
A paper from Sweden prompted discussion of two points: the placarding of wagons containing dangerous goods in limited quantities along with other dangerous goods; and the provisions for protective distances in 7.5.3, which are influenced by the placarding. Sweden felt that the current placarding requirements can mislead emergency responders, by not giving notice of all the hazards present, and that perhaps the approach in ADR, which uses a generic orange-coloured plate, would help.
The standing working group felt some sympathy with the idea but it was of the view that this was another matter that should go to the Joint Meeting first. As to amending the separation provisions, the working group admitted that the current system is not totally satisfactory but felt that the more complicated system proposed by Sweden could lead to an increase in the number of shunting movements, hence increasing risk in the transport operation. A new proposal may be presented to the next session.
Italy presented the result of an informal working group that had met in Milan in late October 2017 to develop checklists for the filling and emptying of tank-wagons for the carriage of gases, analogous to those already in place for the carriage of liquids. Italy has been leading this topic ever since the fatal explosion of a tank wagon carrying LPG in Viareggio in June 2009.
The standing working group adopted the checklists and they will be made available on the OTIF website. Notes will be added to 18.104.22.168 (for fillers) and 22.214.171.124.1 (for unloaders) to direct dutyholders to the checklists.
The new checklists for gas tank-wagons in fact go further than those already in place for liquids and the working group agreed to expand those in a similar manner. The Netherlands will lead a working group, which was due to meet at the end of February 2018 to undertake the necessary work.
Austria reported that, during 2015 and 2016, targeted checks had been carried out on gas tank-wagons that may continue to be used under the transitional provisions 126.96.36.199.2 to 188.8.131.52.5. Serious defects had been found in the closing devices of more than 10 per cent of those wagons checked. Austria called for the duration of the transitional provisions in 184.108.40.206.4 and 220.127.116.11.5 to be limited to 31 December 2021.
The standing working group was of the opinion that the defects being found were a result of a failure of participants to comply with the safety obligations in Chapter 1.4 and that shortening the duration of the transitional provisions would not resolve the problem.
On the other hand, the working group felt that increasing the number of checks on gas tank-wagons across all Contracting Parties would be useful. There also needs to be greater dialogue between states and market players. It invited all states and industry organisations to report at the next session on the measures being taken already, after which a decision will be taken as to how best to proceed.
The Secretariat proposed deletion of the hazard identification number ‘90’ from column (20) in Table A of Chapter 3.2 against UN 3166 and 3171. This is to avoid contradiction with special provision 666. The working group agreed.
The Secretariat had also noticed that, since 18.104.22.168(b) and (c) were deleted in the 2017 text, there is no longer a need to reference 22.214.171.124 in 126.96.36.199, so that reference too was deleted.
UIC informed the standing working group that UIC leaflet 201, referenced in Chapter 1.11 of RID, was in the process of being converted into an ‘International Railway Solution’, IRS 20201. This will be submitted to the next session so that the reference can be updated.
UIC leaflet 471-3 O is also currently being converted. The content of point 5 in this leaflet, referenced in 188.8.131.52.1 of RID, is not being modified. However, the reference in that paragraph will need to be updated; again, this will be presented at the next session.
Poland queried whether wooden pallets may be used for the stowage of organic peroxides and whether there is a need to clarify special provision CW 24/CV 24. There is also some difference in the allocation of those special provisions between ADR and RID. Delegates saw no problem in using wooden pallets – after all, if the dangerous goods are not on wooden pallets they may well be on the wooden floor of a container. However, it seemed that this was another issue that should be taken to the Joint Meeting, which could also look at the differences in ADR and RID.
Also remitted to the Joint Meeting were another Polish query, on the qualification of welding procedures, and a proposal from Russia to delete the derogation for the lithium battery label (model 9A) in 184.108.40.206.1.3.
HARMONISATION OF RID AND SMGS
Readers may recall that Russia had refused to adopt the 2017 amendments to RID into SMGS Annex 2, on the basis that they included references to EU directives and EN standards, over which neither Russia nor some other OSJD states (including China, Mongolia and Tajikistan) have any influence.
The Secretariat informed the standing working group that no progress had been made on this problem over the past year and it seemed inevitable that the same situation would be faced when the 2019 text of RID comes into force. Latvia reported that there have been problems in the Baltic states with the transport of engines, since they are carried as dangerous goods under RID 2017 but are exempt under SMGS Annex 2.
Russia now reported that it was prepared to adopt the 2017 text of RID, except for the references to EU directives and EN standards. Once official translations of the new standards are available, it will carry out analysis in conjunction with the Russian Federal Agency for Technical Regulation and Metrology (Rosstandart). The Russian representative also stated that, given the transcontinental nature of rail transport, it would be more appropriate to use globally applicable ISO standards in the text of SMGS Annex 2.
The OTIF Secretariat reminded the meeting that closer harmonisation between RID and SMGS Annex 2 was something that the UN Economic Commission for Europe’s (ECE) Inland Transport Committee had been seeking for some years; it was OTIF’s attention to bring the current unsatisfactory situation to the notice of the Committee.
Germany informed the standing working group of an incident involving a tank container carrying liquid waste that was found to be leaking from the bottom valve during a random inspection at Offenburg station in October 2016. Further investigation found that the information in the transport document and the marking on the tank container were incorrect, and there were other serious defects in the tank itself. Switzerland reported that similar defects had been found on a tank container belonging to the same Italian operator during an inspection in Basel.
Both representatives stressed that no new provisions were needed but that the incidents highlighted the need to ensure that existing provisions are being observed.
The Netherlands reported on an incident at the Kijfhoek marshalling yard near Zwijndrecht in January 2011, when a tank wagon with ethanol caught fire. Information needed by the emergency services concerning the contents of other nearby tank wagons, was not immediately available and it only emerged later that there were some empty, uncleaned LPG tank wagons in close proximity.
An investigation was undertaken into the registration of dangerous goods wagons at the marshalling yard, which found that accurate information is regularly unavailable. ProRail, the Dutch infrastructure manager, is now applying new technologies to automatically track freight wagons. The Belgian representative reported that a similar system is now in use in the country.
Belgium also notified the standing working group of an incident in Antwerp during hump shunting. One tank wagon with isobutane (UN 1055) had been severely damaged as a result of the buffers over-riding, although there were no leaks.
Another incident reported by the Netherlands involved two tank-wagons carrying 1,2-dichloropropane (UN 1279) last October; leaks had been discovered, caused by rust particles in the valve and damage to the ball valve and Teflon seals. This seemed to be a problem that could happen at any time but, it was hoped, the new checklists for gas tank-wagons could help resolve it.
CHLORINE IN SWITZERLAND
The representative of Switzerland discussed an issue that has become a problem for shippers and carriers: the additional risk-reduction measures imposed in the country on rail shipments of chlorine. The presentation explained that the measures, contained in Common Declaration II, had been agreed by the chemical industry, the Swiss Federal Railways (SBB), the Association of Freight Carriers, the Federal Office of Transport and the Federal Office for the Environment, and so have broad support within the country.
The measures include the use of tank-wagons with enhanced safety features, speed and route restrictions, and greater oversight by the authorities. In the future, a design study will be undertaken with a view to developing a new generation of chlorine tank-wagons and it is possible that funding will be arranged to enable the production of chlorine locally and obviate the need to transport it in large volumes.
UIC noted that, while these measures are voluntary and relate to local interests, they can effectively be imposed on foreign suppliers. UIC felt that the measures should be notified in accordance with Chapter 1.9. The ERA representative said that the provisions of RID should guarantee safe transport and, in principle at least, additional measures should not be necessary. If the Swiss government feels that RID does not fully address safety in the transport of chlorine, then this should be put to the standing working group. If the safety of chlorine transport were to be called into question, then the same could apply to other very dangerous substances.
The representative of the Netherlands said that, in that country, the entire supply chain is taken into account; the aim is to avoid transport as much as possible by manufacturing chlorine near the point of use. Indeed, the European Chemical Industry Council (Cefic) representative reported that the Dutch government has made funds available to allow industry to build chlorine production plants, although he said that the level of demand in Switzerland was probably too low to make this a viable option.
Overall, the mood of the standing working group was that national variations from the provisions of RID are to be avoided wherever possible. On a similar topic, UIC presented studies that the body has undertaken on national requirements that apply in addition to RID. This work is continuing and will be communicated to the standing working group. ERA reminded the meeting that the definition of ‘national rule’ is very clear and that EU member states must inform the European Commission of any such rules. ERA felt that UIC presentation may be misleading, as some of the variations noted do not meet that definition. However, it was agreed that reducing national rules is a priority within the EU.
EXTRA-LARGE TANK CONTAINERS
Switzerland provided information on a new 40-foot tank container developed by BASF and the Belgian tank container manufacturer van Hool (HCB
June 2017, page 46). These tank containers have a capacity of up to 73,500 litres and a payload of 66 tonnes. The load capacity is therefore equivalent to two conventional tank-containers or one bogie tank-wagon. The representative of Switzerland raised various questions in connection with the consequences of this new technological development for safety in the carriage of dangerous goods.
It so happened that Dr Bieker from BASF was at the meeting as part of the Cefic delegation. He explained that the tank containers in question have tank condes L4BH and L4DH; 50 are currently being built with a calculation pressure of 10 bar. The will be used for substances for which a calculation pressure of 4 bar is prescribed. The new tank-containers are being carried on new wagons, of which around 150 are planned; they will be fitted with crash-buffers and devices to protect against the over-riding of buffers. They are not fitted with surge plates as they will be carried either filled to at least 80 per cent or empty and uncleaned.
Within the context of Responsible Care, BASF is applying special provisions TE 22 and TE 25 to carriage in these tank-containers. The Austrian representative felt that was all well and good but that it cannot be assumed that other users would be so assiduous. In addition, both Germany and UIP noted that there has been a lot of market interest in these new tanks and it would be a good idea to clarify the legal position as soon as possible.
The standing working group agreed to hold detailed technical discussions at the working group on tank and vehicle technology, due to take place at the end of January in Hamburg. Part of those discussions would be a comparison of the current provisions applicable to tank-containers and tank-wagons. It might prove desirable to draw up a list of questions to be put before the Joint Meeting.
The ERA representative said that a risk analysis would have to be carried out before any of the measures so far applied on a voluntary basis by BASF were included in the text of RID.
In its new regular slot, ERA had been invited to give an update on developments. Of particular interest was the work on derailment detectors, after the first edition of new ERA guidelines had been presented at the previous session of the standing working group. The European Commission had asked ERA to give priority to developing the necessary specifications and gave it a 2020 date for the work. This drew some criticism from the standing working group, with the Swiss representative reminding the working group that the RIC Committee of Experts’ working group on derailment detection had planned that this work would be carried out in 2017/18.
ERA explained that its activities are determined by the European Commission and that it had been asked to give priority to activities necessary for the implementation of the fourth Railway package. On the upside, the request did clearly indicate the need to work on derailment detection.
The ninth session of the RID standing working group will take place in Berne, Switzerland from 28 to 30 May 2018; the RID Committee of Experts will meet at the end of that session to approve the amendments that will appear in the 2019 edition of RID. HCB will provide a list of those amendments once they have been finalised.
The tenth session of the standing working group will take place in Poland in the week beginning 19 November 2018.
[post_title] => RID: Don't get side-tracked
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[post_name] => rid-dont-get-side-tracked
[post_modified] => 2018-03-02 13:57:12
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