[ID] => 9601
[post_author] => 34
[post_date] => 2018-05-11 13:50:45
[post_date_gmt] => 2018-05-11 12:50:45
[post_content] => The Joint Meeting of the RID Committee of Experts and the Working Party on the Transport of Dangerous Goods (WP 15) of the UN Economic Commission for Europe (ECE) held its spring 2018 session in Bern from 12 to 16 March 2018. The meeting was chaired by Claude Pfauvadel (France) with Helmut Rein (Germany) as vice-chairman.
The session was attended by representatives of 22 states, the European Commission, the EU Agency for Railways (ERA), the Organisation for Cooperation between Railways (OSJD) and 12 non-governmental organisations.
The main business of the Joint Meeting is to discuss matters of relevance to the transport of dangerous goods by road, rail and inland waterway in those countries that are party to the regulations under the RID (rail), ADR (road) and/or ADN (inland waterway) agreements. That work largely, though not exclusively, involves transposition of the amendments made to the UN Model Regulations that are common across transport modes, leaving the modal bodies to deal with issues of particular relevance.
By this stage in the biennium, the changes featured in the 20th revised edition of the UN Model Regulations had largely been dealt with. There were, though, plenty of other matters to clear up before the amendments that will appear in the texts of RID, ADR and ADN that will enter into force in 2019 can be finalised.
Documents relating to tanks were, as usual, entrusted to the Working Group on Tanks, which was chaired by Arne Bale (UK).
Poland had a question on the qualification of welding procedures, noting that EN ISO 15614-1:2017 offers two levels. Level 1 is based on the ASME standard, while Level 2, which is more severe, was contained in earlier versions of the standard. The Pressure Equipment Directive and Simple Pressure Vessel Directive mandate use of Level 2, but does this also apply to tanks of RID/ADR?
It was noted that Level 2 is more comprehensive and therefore more expensive; however, both give sufficient proof that welding procedures are accurate. EN 12972:2018 allows Level 1 to be used for portable tanks. There was a feeling among several experts that Level 2 should apply, which should not be difficult to achieve as manufacturers and repair shops have had to meet that standard in the past. It was decided to await a comparison document from France for consideration at a future session.
The UK returned to the Working Group with a proposal to amend the provisions covering the information to be provided on the tank plate. This was based on previous discussions but at this point some experts had second thoughts, questioning what value would be provided by the change. The general feeling was that a standard would provide a good basis; EN 12561-1 already exists but is only applicable to tank wagons. It was suggested that the European Committee for Standardisation (CEN) could develop a more generally applicable standard.
The International Union of Private Wagons (UIP) proposed an amendment to 220.127.116.11.23 to clarify that, while competent authorities need to approve tank manufacturers’ welding procedures, maintenance and repair shops should be approved by an inspection body. The idea was sound but the experts felt the wording could be better. A revised version proved acceptable, leading to the first sentence of the first paragraph of 18.104.22.168.23 being changed to:
The ability of the manufacturer to perform welding operations shall be verified and confirmed by either the competent authority or by the body designated by this authority. The ability of the maintenance or repair shop to perform welding operations shall be verified and confirmed by the inspection body according to 22.214.171.124.5. A weld quality assurance system shall be operated by the manufacturer or the maintenance or repair shop.
The use of austenitic-ferritic stainless steel was introduced in 126.96.36.199.2(a) for the 2019 texts of RID and ADR at the autumn 2017 session. At the time, the proposed lower temperature limit of -40˚C was placed in square brackets as further consideration was thought necessary in order to reflect the use of such tanks to carry refrigerated liquefied carbon dioxide.
France had investigated the issue and recommended a lower limit of -60˚C. While there were some questions and not all experts were totally happy, the change was adopted.
France also returned to the issue of gravity-discharge tanks and the decision made for RID/ADR 2017 that the maximum working pressure does not apply to such tanks, according to 188.8.131.52(a). However, the promised revision of EN 13094 had not yet been published, leading to an incompatibility between the standard and the regulations. It was proposed that guidance be introduced for the 2017 and 2019 editions of RID and ADR.
This has been done through the addition of some notes. The existing notes in column (2) of 184.108.40.206.1 against EN 14432:2014 and EN 14433:2014 are both amended to read:
NOTE: This standard may also be used for gravity-discharge tanks.
A new note is added in column (2) against EN 13094:2015, for ADR only:
NOTE: See also the guideline on the website of the secretariat of the United Nations Economic Commission for Europe (https://www.unece.org/trans/danger/danger.html).
That guideline for the application of EN 13094:2015 for compliance with ADR 2017 and 2019 was also agreed; it lists the amendments to the standard that are necessary. It will be posted on the UN ECE website in due course.
Germany proposed that the square brackets in footnote 4/2 to 220.127.116.11 could be removed for the 2021 editions of RID and ADR, as the latest draft for revision of EN 13094 provides for safe construction. It was not necessary to make the change for the 2019 texts as 18.104.22.168 allows the standard’s early use. The footnote now reads:
However the cross section of shells according to 22.214.171.124.14 (a) may contain recesses or protrusions such as sumps, cut-outs or recessed manhole constructions. They may be constructed of flat or shaped (concave or convex) sheet metal. Dents and other unintended deformations shall not be regarded as recesses or protrusions.
France provided some legal information on the acceptance of electronic documents and signatures for tank inspection certificates, a topic that had been raised at the autumn 2017 session; several experts noted that their authorities already accept electronic documents, a position the working group supports.
A further paper from France provided more information on bursting pressure at working temperature, allowing a revision provisionally adopted at an earlier session to be completed and adopted. The second sub-paragraph in 126.96.36.199.10 is amended to read:
Except for tanks intended for the carriage of compressed, liquefied or dissolved gases where the arrangement of the bursting disc and safety valve shall be such as to satisfy the competent authority, burst pressures of the bursting disc shall satisfy the following requirements:
- the minimum burst pressure at 20°C, tolerances included, shall be greater than or equal to 0.8 times the test pressure,
- the maximum burst pressure at 20°C, tolerances included, shall be less than or equal to 1.1 times the test pressure, and
- the burst pressure at the maximum service temperature shall be greater than the maximum working pressure.
A pressure gauge or another suitable indicator shall be provided in the space between the bursting disc and the safety valve, to enable detection of any rupture, perforation or leakage of the disc.
In the new transitional measures in 188.8.131.52 and 184.108.40.206, “nominal pressure of the bursting disc” is replaced by “burst pressure of the bursting disc”.
The Netherlands queried the interpretation of the marking requirements in 220.127.116.11.2 and 18.104.22.168.6 and whether they should be visible during carriage; the paper also thought 22.214.171.124.2 should be reviewed, particularly the requirement to cover up the names of gases not being carried. The experts felt that the first part of the query was not an issue, as folding panels are fixed to the sides of tank wagons. However, it was agreed that 126.96.36.199.2 should be looked at and the Netherlands offered to draw up an official document.
The UK presented the report of the seventh meeting of the informal working group on the inspection and certification of tanks, which was held in London in December 2017. The group had covered a lot of ground and it was expected that formal proposals for the revision of 1.8.6 and 1.8.7 would be available in time for the eighth meeting in early May. The group was advised to concentrate on those revisions, and the revision to 6.8.
The International Union of Railways (UIC) asked whether the requirement to mark the actual holding time in the transport document, as prescribed in 188.8.131.52.2(d), applies to empty uncleaned tanks. The experts felt that it is important to do so but realised the problems faced. The European Industrial Gases Association (EIGA) is already working on issues relating to empty tanks and it was asked to take UIC’s question into account.
UIC also brought to the table discussion of the new breed of extra-large tank containers, which are designed primarily for use in rail transport. The matter had already been discussed by the RID standing working group but the advice of the Joint Meeting was sought. The size of such tanks – capacities of up to 73,000 litres, as opposed to 36,000 litres for standard tanks – means that they are subject to increased pressures from liquid surge. It was agreed to introduce a new footnote in 184.108.40.206.2, cross-referencing 7.1.3, but the experts felt that other matters needed to be looked at in greater detail. The experts felt that this work should be carried out by the RID working group on tank and vehicle technology.
The UK raised two questions on the use of vacuum-operated waste tanks in respect of ADR but the experts were of the opinion that no action was needed.
The International Tank Container Organisation (ITCO) queried the definition of ‘operator’ in 1.2.1, which creates difficulties with leased tanks. In some countries, penalties are levied on the tank owner, which may not be the actual operator. ITCO was invited to consider a formal proposal for amendment.
CEN advised the Joint Meeting of progress made with new and revised EN and EN ISO standards that are or are intended to be referenced in RID, ADR and/or RID. The working group on standards considered the document and proposed several changes to the 2019 texts, on condition that the 2018 editions of the standards concerned were available by 1 June 2018.
- In 220.127.116.11, reference to EN 1252-2:2001 Cryogenic vessels – Materials – Part 2: Toughness requirements for temperatures between -80˚C and -20˚C is replaced by reference to EN ISO 21028-2:
- In 18.104.22.168, the table will include EN ISO 14246:2014+A1:2017 Gas cylinders – Cylinder valves – Manufacturing test and examinations; applicability of the 2014 text will expire on 31 December 2020
- In 22.214.171.124.1, the table will include EN 12972: Tanks for transport of dangerous goods – Testing, inspection and marking of metallic tanks, mandatory from 1 January 2021; the same revised standard is added in 126.96.36.199.2, with the existing 2007 standard only applicable to 30 June 2019 and the new version mandatory from that date
- In 188.8.131.52.1, EN 13317: Tanks for transport of dangerous goods – Service equipment for tanks – Manhole cover assembly is added after the reference to EN 13317:2002 + A1:2006, applicability of which will expire on 31 December 2020
- In the same table, EN 14025: Tanks for the transport of dangerous goods – Metallic pressure tanks – Design and construction is added after the 2013 edition, applicability of which will expire on 31 December 2020
- In the table in 184.108.40.206, EN 1442:2017 LPG equipment and accessories – Transportable refillable welded steel cylinders for LPG – Design and construction is added after the existing 2006 version, which expires on 31 December 2020.
New notes are added for EN 12245 in 220.127.116.11, one in column (2):
NOTE: This standard shall not be used for cylinders and tubes without a liner, manufactured from two parts joined together.
And a second in column (5):
31 December 2019, for cylinders and tubes without a liner, manufactured in two parts joined together.
These notes have been added to address an issue identified by the European LPG Association (AEGPL) after a number of incidents involving two-piece composite LPG cylinders. AEGPL noted that there is a withdrawal programme in place for such cylinders and the Association was invited to keep the Joint Meeting updated on progress.
INTERPRETATION OF RID/ADR/ADN
Poland sought clarification of the meaning of ‘readily flammable material’ in special provision CW24/CV24 in 7.5.11 and its allocation to substances of Class 8 with a Division 5.1 subsidiary hazard. In particular, its paper asked if organic peroxides of Division 5.2, packed in accordance with packing instruction P 520/IBC 520, can be transported on wooden pallets.
The Joint Meeting agreed that the use of wooden pallets is allowed; the term ‘readily flammable material’ is intended to address filling or cushioning materials such as a hay, paper and vegetable fibres. The European Chemical Industry Council (Cefic) offered a revised text for CW24/CV24, which received some support. Cefic and Poland were invited to work on the text and submit an official proposal at the next session.
The Joint Meeting agreed with Poland’s observation that there are discrepancies in the application of CW24/CV24 in RID and ADR. It felt that CW24 should be deleted for UN 1796 and 1826, PG II in RID and recommended the RID Committee of Experts confirm this. It also felt that CW24/CV24 should be added in column (18) of the Dangerous Goods List for the second entry under UN 2031 and invited both the RID Committee of Experts and WP15 to confirm that.
An informal document from France raised a question about the use of used packagings for the carriage of dangerous goods wastes, which it said can facilitate the waste management process by allowing incineration of the packaging along with its contents. However, in such cases it is impossible to assess the chemical compatibility of the packaging and its contents, although the risk involved is, France said, small.
It appeared that this type of operation is addressed differently in different countries. France offered to circulate a questionnaire to all contracting parties with a view to harmonising practices at international level.
UIC asked for alignment of the specifications for hazard labels and placard. At present, labels are allowed to deviate from the models, with the addition of next or numerals in the lower half. However, the same is not true for placards. It proposed some text to be added at the end of 18.104.22.168.1, which the Joint Meeting found agreeable:
The deviations specified in 22.214.171.124.1, second sentence, 126.96.36.199.1.3, third sentence and 188.8.131.52.1.5 for danger labels also apply to placards.
Referring back to discussions at the previous session, Germany came forward with a proposal to clarify the provisions regarding the language to be used on the transport document. As it stands, problems are being experienced, particularly in the return transport chain and with Class 1 articles.
The Joint Meeting adopted the text, noting that it does not prohibit the use of other languages so long as one of French, German or English is also used. The change is found in a revised second sentence in 184.108.40.206:
The mark, which shall be clearly legible and indelible, shall be in one or more languages, one of which shall be French, German or English, unless any agreements concluded between the countries concerned in the transport operation provide otherwise.
Another proposal from Germany also found favour. It spotted that UN 3132 had been omitted from the table in 220.127.116.11.3 under transport category 0, Class 4.3. The experts agreed and inserted “3132” after “3131”.
The secretariats of UN ECE and the Intergovernmental Organisation for International Carriage by Rail (OTIF) had supplied a brief list of amendments to recently adopted changes, and these were adopted by the Joint Meeting. The main changes are the addition of “bulk containers” after “large containers” in the title to 18.104.22.168. The first sentence of 22.214.171.124 in RID and the first paragraph after the Note to 126.96.36.199 in ADR are amended with similar language. That in ADR reads:
The placards shall be affixed to both sides and at each end of the container, bulk container, MEGC, tank-container or portable tank and to two opposite sides in the case of flexible bulk containers.
Germany proposed a transitional period for the new provisions that require manufacturers and distributors to make the lithium battery test summary available, as recommended by the UN Sub-committee of Experts. This was readily adopted as a new 188.8.131.52:
Lithium cells and batteries not meeting the requirements of 184.108.40.206.7 (g) may continue to be carried until 31 December 2019.
Germany also followed up on discussions at the autumn 2017 session on the protection of valves on gas cylinders fitted with handling devices or other components. Its proposal was amended during discussion and, on the basis of a text drawn up by EIGA, 220.127.116.11 was amended with the addition of “and other components which are to remain connected to the valve during carriage (e.g. handling devices or adaptors)” in the first sentence after “Valves”.
The International Road Transport Union (IRU) proposed allowing refresher training for drivers of dangerous goods to be conducted by online means. This proposal divided opinion: some delegations felt there was no need for provisions on the topic, while others felt that ADR/ADN should at least provide minimum requirements. No agreement could be reached and IRU was asked to work intersessionally with interested parties with a view to presenting a revised proposal at the next session.
Sweden proposed requiring wagons and containers carrying more than 8 tonnes of dangerous goods in limited quantities along with other fully regulated dangerous goods to bear the limited quantity mark. Sweden felt this would increase safety by alerting responders when there were significant amounts of limited quantity material and could be of interest on journeys passing through road tunnels. Again, opinion was divided and, after discussion, Sweden said it would take account of comments made and return with a revised proposal.
The European Aerosol Federation (FEA) proposed aligning RID/ADR/ADN with the new provisions of the EU Aerosol Dispensers Directive, 75/234/EEC, relating to the maximum allowed internal pressure. The Joint Meeting was ready to adopt the change until it was pointed out that such a move would cause disharmony and that the matter should really be taken up to the UN Sub-committee of Experts.
Spain noted that UN 2683 ammonium sulphide solution is assigned the hazard identification number 86 in column (20) of the Dangerous Goods List. This substance is corrosive, flammable and toxic; its flammability warrants the use of an FL vehicle. It should, therefore, have the hazard identification number 836 – except this does not exist. Spain identified two other UN entries – UN 2029 hydrazine, anhydrous and UN 3484 hydrazine, aqueous solution, flammable, that have a similar list of hazards.
Opinion was once more divided; some welcomed the observation and felt that a more thorough investigation of existing hazard identification numbers would reveal further cases, while others felt that the system has been in place for a long time and should not be tinkered with. Spain was invited to submit a revised proposal, taking into account the comments made, and delegations that had identified other cases where action might be useful were invited to contact the Spanish delegate.
Germany reported that the ADN Safety Committee had agreed changes to the definition of ‘flash-point’ and suggested the same changes for RID and ADR. There was, though, no support for the proposal. Again, it was noted that any proposal for change should be taken to the UN Sub-committee of Experts.
Switzerland had had some success at the modal level with its proposal to amend CW36/CV36 to take account of the need for ventilation during the transport of gases in sheeted vehicles and those where the load compartment is not separated from the driver’s compartment. It had been asked, however, to take the proposal to the Joint Meeting, where it met with less enthusiasm. Germany noted that stakeholders can envisage problems with parcel services, and both EIGA and AEGPL wanted to seek advice from their members. Switzerland will come back with a revised version once those issues have been investigated.
Italy had been through the three official language texts and come up with a long list of discrepancies. The document was welcomed by the Joint Meeting but felt that more time would be needed to address all the issues raised; it would also be useful if the work could encompass ADN as well as RID and ADR. Delegations were invited to provide written comments to the representative of Italy.
WORKING GROUP REPORTS
EIGA updated the Joint Meeting on moves to harmonise provisions for UN pressure receptacles, particularly between RID/ADR signatories and the US. It was noted that regulatory procedures in the US are still ongoing. EIGA will continue to work with its counterparts in the US and will provide more feedback at the next session.
An informal working group led by Romania and UIC had been working on new definitions for ‘danger/hazard’ and ‘risk’ and offered its suggestions. The Joint Meeting could not agree and advised the group to continue, firstly identifying ways in which those terms can be avoided throughout the regulatory texts. The results of that work will be presented at the autumn 2018 session.
The Joint Meeting also heard from the informal working group to update the architecture for dangerous goods telematics and the informal working group on the reduction of the risk of a BLEVE during transport of dangerous goods. Both groups will continue with their work.
ACCIDENTS AND RISK MANAGEMENT
ERA informed the Joint Meeting that the first edition of the framework guides on inland transport of dangerous goods risk management had been finalised and will be published shortly on the ERA website. Both Spain and the UK felt that further work was needed before the guides could be applied, not least since the volume of data is as yet insufficient to be reliable. ERA is to set up a group of experts that will be involved in taking the project forward.
ERA also reported on the list of parameters to be used in the harmonised risk estimation method and on the development of a Railway Common Occurrence Reporting (COR) System, something that is still at the conceptual stage. This work, ERA said, should coordinate with the work of the Joint Meeting on section 1.8.5 of RID/ADR/ADN; if not, any action ERA takes may not be fully aligned.
The amendments adopted by the Joint Meeting for entry into force in 2019 require confirmation by the modal bodies, which was to take place at their respective meetings in May. HCB will report on those sessions in a forthcoming issue.
The next session of the Joint Meeting will take place in Geneva from 17 to 21 September.
[post_title] => RID/ADR/ADN: Crunch time
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[post_modified] => 2018-05-24 12:36:46
[post_modified_gmt] => 2018-05-24 11:36:46
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