The ADN experts have a big task on their hands trying to maintain modal harmonisation while keeping up with developments in the maritime industry
The Joint Meeting of Experts on the Regulations annexed to the European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN) – the ADN Safety Committee - held its 27th session in Geneva from 24 to 28 August 2015, with Helmut Rein (Germany) as chairman and Bernd Birklhuber (Austria) as vice-chairman.
The meeting was attended by representatives from 11 countries, the Central Commission for the Navigation of the Rhine (CCNR), the Danube Commission (DC) and the European Union (EU), and nine non-governmental organisations.
Before starting on discussions of the working and informal documents, the Committee noted a number of issues pending since the previous session that were either being progressed by informal working groups or would be held over to the subsequent session pending further information. These covered such issues as:
- the use of LNG as fuel
- special authorisations in respect of UN 2187 and 3298
- the qualification of persons responsible for carrying out various tasks under ADN
- transhipment operations
- the carriage of coal
- the issuance of a new substances list after renewal of the certificate of approval.
The Committee also noted that the UN Economic Commission for Europe (ECE) Inland Transport Committee (ITC) had encouraged member states to provide data for the accident database pilot project developed by the RID/ADR/ADN Joint Meeting in respect of incident reports involving dangerous goods under 1.8.5 of the Regulations annexed to ADN.
It was also noted that the ECE secretariat was in the process of conducting an assessment of the global and regional impact of the UNECE Regulations and the UN Recommendations on the Transport of Dangerous Goods. A questionnaire had been sent to all those who took part in the Committee’s work, and they were asked to complete it as quickly as possible so that the responses could be analysed by a consultant in September 2015.
The Safety Committee noted that three multilateral agreements (M013, M014 and M015) had entered into force since the previous session. Belgium was asked if it intended to counter-sign M014 and M015, dealing with the proof of sufficient intact stability, which other delegates considered important for the Rhine fleet. Belgium explained that the competence for ADN had recently been delegated to the three regions in Belgium and it was in the process of determining the internal procedure for the signing of multilateral agreements. It expected that the signature would be forthcoming during September 2015.
Belgium was reminded that each Contracting Party must provide the ECE secretariat with the relevant list of authorities and designated bodies competent under national law for the application of ADN.
LNG AS FUEL
The Safety Committee recommended that the Administrative Committee adopt a decision on a derogation for the use of LNG as a fuel on the tank vessel Argos-GL.
The Netherlands also submitted an informal document seeking a derogation to allow the use of membrane cargo tanks on this vessel. After some discussion, a revised document was accepted and the Safety Committee recommended that the Administrative Committee do the same.
The Netherlands noted that the intention was that the vessel would operate only in the Amsterdam-Rotterdam-Antwerp region but it is possible that it may come back at a later point for an extension.
INTERPRETATION OF ADN
Germany noted that, in the French and English versions of ADN 2015, the provisions concerning the obligations of the filler and unloader of a tank vessel contain expressions referring to piping that are not defined in section 1.2.1 and requested clarification as to which types of piping are referred to in 220.127.116.11 (s) and 18.104.22.168.1 (j) and which language version ought therefore to be corrected or amended.
After discussion, the Committee recognised that there are a number of inconsistencies in the sections related to the obligations of the loader and the unloader of a tank vessel. Germany promised to draw up a revised proposal for the next session.
Germany also queried the definitions of “gas detector” and “toximeter” in 1.2.1. These pieces of equipment are crucial in determining whether dangerous concentrations of flammable or toxic gases still remain in a given area of a vessel, or to measure oxygen concentration. Yet there are no requirements as to the design or performance of gas detectors and taximeters.
The Safety Committee was of the opinion that available standards, even those used for maritime transport, should be used, with references to them introduced into the text of ADN. Further discussions could be held to decide whether the use of those standards should be made mandatory for portable appliances. The informal working group on explosion protection on board tank vessels was asked to study the matter, to identify applicable standards and to assess the impact of references to those standards.
At the previous session, the Netherlands initiated a discussion on the publication of national interpretations of ADN provisions. It now presented three domestic interpretations and sought the Committee’s opinion as to whether these should be reflected in the ADN text.
The Committee accepted the Dutch interpretation of 22.214.171.124.5, dealing with vapour return piping, to wit that it is the properties of a gas/air mixture that is released during loading operations that determines whether or not such piping has to be used. It was also mentioned that the gas-freeing process should at the same time cover piping and shore facilities. The interpretation does not apply to vessels with gas-free certificates or open vessels.
The Committee considered that, in principle, interpretations should be reflected in the text of the Regulations. To that end, the representatives of France and the Netherlands would submit a proposal for the particular case in question.
The Committee also agreed with the Dutch interpretation of question 10 in 8.6.3 regarding the supervision of loading and unloading operations. In this case it was felt that no amendment was necessary.
A German paper containing its interpretation of 126.96.36.199 was also accepted. As a result, 188.8.131.52(u) will be amended in the 2017 text by deleting “or unloading”, since this deals with the responsibilities of the filler.
The Committee did not concur with the Dutch interpretation of text dealing with vacuum valves and pressure relief devices. The Netherlands delegate said these national interpretations would be withdrawn but that a proposal would be made at the next session to amend the text of ADN.
The Recommended ADN Classification Societies sought the Committee’s opinion on the question of bulkheads on Type G vessels. For Type C or N tankers, an A-60 bulkhead is deemed equivalent to a cofferdam but the same is not the case for Type G vessels according to 184.108.40.206.3(a).
The Safety Committee noted that cofferdams provide fire protection and the Recommended ADN Classification Societies were asked to see if they can establish an equivalence between cofferdams and Class A-60 bulkheads on Type G vessels. If that is the case, an amendment may be considered.
The Netherlands sought interpretation of the transitional provision for small single-hull tank, supply and oil separator vessels in 220.127.116.11.1. This provision allows those vessels to continue to carry the substances they were authorised to carry on 31 December 2008 until 31 December 2018 or, for supply and oil separator vessels, 31 December 2038. So much is clear; however, it is less clear how the provision should be applied in respect of substances that have been added to the Dangerous Goods List since 1 January 2009 and the Netherlands was most concerned about heavy heating oil shipped under UN 3082, which was added to the List in 2013.
Other delegations did not see this as a problem. Heavy heating oil might have been added as a named substance in 2013 but UN 3082 was already on the list and the flowchart in 18.104.22.168 is applicable for the classification of heavy heating oil.
The Recommended ADN Classification Societies returned to an earlier discussion about stability calculation and the qualification of openings. It offered revised interpretations for goosenecks of limited diameter and automatic closing devices with floating balls. Both were accepted by the Safety Committee, the latter on condition that the devices are included in the class inspection every 2.5 years.
TRAINING OF EXPERTS
CCNR provided a report on the 14th meeting of the informal working group on the training of experts. The Safety Committee invited the various delegations to continue to exchange information on their criteria for the recognition of training and on the format of the certificate.
The Committee endorsed the conclusion that training provided in an ADN contracting party other than that of the examination should be recognised by the State where the examination was administered.
The next session of the informal working group was scheduled for 14 and 15 March 2016.
The Recommended ADN Classification Societies provided a report on their ninth meeting, which raised a number of questions for the Committee to discuss. For a start, the Committee reviewed documents provided by Bureau Veritas, Lloyd’s Register of Shipping, the Russian Maritime Register of Shipping and the Shipping Register of Ukraine attesting to their certification in accordance with
EN ISO/IEC 17020:2012.
There was some discussion on this topic. Are certifications that refer to the International Association of Classification Societies (IACS) quality system certification scheme for maritime vessels acceptable in the field of inland waterway transport? Do certifications apply to offices in all countries or only those listed? For example, Bureau Vertias’ certificate only mentioned its Belgian subsidiary. In this context, it was also recalled that a classification society must have experts in at least two countries that are Contracting Parties to ADN.
Those recommended ADN Classification Societies that had not yet provided a certificate were requested to do so before the next session.
The 2017 edition of the regulations annexed to the ADN Agreement will reflect amendments agreed by the RID/ADR/ADN Joint Meeting. The Committee requested that the secretariat compile a consolidated document with all those changes adopted at the session in spring 2015, as well as those agreed by the Working Party on the Transport of Dangerous Goods (WP15) at its 98th session, for consideration at the next session.
In the meantime, a number of other proposals had been made, which were considered by the Safety Committee. Many of these came from Germany, including a proposal to amend 22.214.171.124.2.7(a) and 9.3.x.40.2.7(a) so that pressurised tanks, fittings and piping in fire-extinguishing systems can be built in conformity with the rules of a recognised classification society, as an alternative to the rules of a competent authority. The Committee agreed to the proposal and the change by adding “or, if there are no such requirements, to those of a recognized classification society" to the end of the four relevant paragraphs.
The Committee also accepted another suggestion from Germany, namely to amend the heading in column 4 of table 126.96.36.199 on possible means of evacuation in the event of an emergency, which should provide greater clarity. This will now read: "3 packing group III (UN No. 1202: second and third entries in table C), 4.1".
A third proposal from Germany, to bring forward the end of the transitional period in 9.3.x.51.3 by 16 years to 31 December 2018, fared less well, with several delegations concerned about the possible economic impact. The chair suggested that industry and the classification societies should provide further information before a decision is taken.
Germany also referred back to the 25th session of the Safety Committee, when it had emerged that there are discrepancies in the design of the certificates issued to ADN experts by the various contracting parties. While not aiming to ensure conformity, Germany felt it would be beneficial to safety if each contracting party were required to advise the secretariat of the design of their certificate and those designs were made available through the UN ECE website, as is the case with ADR. The Committee agreed and adopted text for a new 188.8.131.52.2.
Yet another proposal from Germany noted that, in the certificate of approval for tank vessels that comprise various types of tank, it is not possible to state whether inerting facilities are available only for some of the tanks. The Committee agreed that a change would be useful and inserted a new row for inerting facilities on page 3 of the certificate of approval and the provisional certificate of approval in 184.108.40.206 and 220.127.116.11.
FuelsEurope returned to the impending problem caused by the reclassification of home heating oils under UN 3082, specifically the issue of emissions of vapours emitted during barge loading. In August 2012 the ADN Safety Committee provided a temporary derogation from the requirement in 18.104.22.168.5 to return gas/air mixtures ashore during loading operations, pending a detailed evaluation of the associated risks.
FuelsEurope provided the Committee with the report published by CONCAWE in January 2015 on the topic, seeking a permanent derogation through the agreement of a new special provision. The representative of the Netherlands pointed out that his technical experts had been unable to verify the CONCAWE report, which the chair found regrettable, as it will take at least a year for ports and shore facilities to put in place the equipment necessary to handle the return gases and the temporary derogation expires at the end of 2016.
It was decided that those delegations with doubts about the validity of the CONCAWE risk assessment should consult FuelsEurope as soon as possible so that a new proposal could be prepared in time for the next session.
Belgium sought modification of the fire alarm system requirements in 22.214.171.124.2.3 on the grounds that the current text is not appropriate for all types of vessel. The Committee felt it necessary to consult with other relevant bodies dealing with technical provisions for inland navigation before making the change.
In a similar vein, Belgium sought modification of 9.3.x.21.5(a) regarding high level sensors to require a permanent device to make it possible to shut down the shore facility independently of the electrical signal. Numerous comments were made by the experts and Belgium will return with a revised proposal at the next session.
The Recommended ADN Classification Societies addressed intact stability of Type N tank barges that use double-hull compartments for ballasting. While the longitudinal bulkhead in the cargo tanks mitigates against the effect of sloshing, the same is not the case in the ballast tanks and this can cause stability problems. The Societies proposed an amendment to 126.96.36.199.2.
The Committee noted that the argument applicable to Type N tank vessels would also be valid for those of Type C, and that it would be appropriate to provide for transitional measures. A new proposal would thus be submitted at the next session.
A related paper from the Societies noted that, since the 2013 version of ADN, it is no longer explicitly mentioned in 9.3.x.13.3 that the intermediate stage of flooding must be verified. The Committee agreed that this was an error and agreed to adopt a new 9.3.x.13.4:
Floatability after damage shall be proved for the most unfavourable loading condition. For this purpose, calculated proof of sufficient stability shall be established for critical intermediate stages of flooding and for the final stage of flooding.
Another paper from the Recommended ADN Classification Societies argued that the provision of compressed air on deck is analogous to firefighting systems and, therefore, similar provisions should be adopted to ensure that no gases can escape into accommodation or service spaces outside the cargo area. The proposal was endorsed in principle but a revised proposal was requested following comments made.
The Societies also proposed deletion of 188.8.131.52.1, the transitional provisions concerning the modification of a tank vessel to a Type N double-hull vessel. These contain a requirement for accommodation and wheelhouses to be equipped with a fire alarm system, something that the Societies believed was unnecessary. It was pointed out that the sub-paragraph in question compensates for the previous sub-paragraph, which allows the use of non-flame-retardant materials in the accommodation and wheelhouse, and the proposal was withdrawn.
Belgium queried the term “vessel certificate” in 1.16.5, saying that it is vague and could refer to various certificates. It preferred the term “technical vessel certificate” and the addition of a definition. The Committee agreed with the argument but it was noted that there might be other terms in use. Belgium was asked to submit a new proposal taking into consideration the terminology in use in countries outside the EU.
A paper from the European Barge Union (EBU), the European River-Sea-Transport Union (ERSTU) and the European Skippers Organization (ESU) noted that the use of wood, aluminium alloys or plastic materials within the cargo area is prohibited, except where explicitly permitted in 9.3.x.0.3 or in the certificate of approval. However, some modern construction materials offer advantages over steel in some applications and there is a growing demand for derogations to be issued. The joint proposal included a revised text for 9.3.x.0.3.
Several delegations supported the proposed inclusion of provisions that would take account of the increasing use of modern materials on vessels, but wished to see them presented in a more user-friendly form, for instance, as a table. A new proposal would be submitted to the next session.
In an informal document, the same three organisations described the way in which cargo sampling is carried out and many of the operational problems that are regularly encountered, together with the risk of cargo contamination posed by the process. They argued that it would be better to allow open sampling, rather than the use of a partially enclosed or enclosed sampling device, and to require the use of personal protection equipment to ensure occupational safety.
The European Chemical Industry Council (Cefic), in another informal document, said reverting to open sampling would be a retrograde step in terms of environmental protection and worker safety and said a better solution would be to create a means by which sampling devices could be cleaned onboard. It also offered a schematic of an improved sampling system.
The Safety Committee considered this to be an operational issue and that legislation would not be appropriate. Cefic offered to organise an informal working group to discuss the issue. The group was invited to submit proposed amendments to ADN if it considered that the inclusion of more detailed requirements on ways of working could address the problem.
The report of the informal correspondence working group looking at the possible amendment of Chapter 1.16 (inspection procedures) and 9.3.x.8.1 (classification) was supplied by France. The report included a number of specific proposals for re-wording the provisions and some points for discussion.
The Committee considered and adopted the proposals, on the condition that a few items be discussed further in the correspondence group and an official proposal submitted to the next session.
The report of the third meeting of the informal working group on degassing of cargo tanks was presented by the Netherlands. Work is continuing and the Committee was invited to make comments.
It was stressed that degassing should apply to all gases contained in tanks, including asphyxiant, oxidising or corrosive gases, and not just to flammable or toxic gases. The certification of the condition of being gas-free by a person approved by the competent authority should be considered in more detail. In the context of the gas-freeing of empty cargo tanks to the atmosphere, it would be advisable to study the procedures, in particular to take into consideration possible regulations relating to the prevention of air pollution. Lastly, some residues are considered to be dangerous wastes and that the latest developments on that subject must be taken into consideration.
CCNR provided a report on the eighth meeting of the informal working group on explosion protection on tank vessels, which is close to making formal proposals. A final report will respond to comments made by the Committee.
The Netherlands reported on progress made by the informal working group on means of evacuation. The Committee noted that some issues still need to be addressed and invited the Recommended ADN Classification Societies to prepare proposals to be discussed at a second meeting.
CCNR provided a report on the informal working group on substances but, as it was only available in German, it was not possible to take a decision on the proposals to be submitted formally at the next session. The Committee did, however, endorse the comments on ammonia in Table C and the interpretation of the informal working group that there is no need for additional ventilation requirements for BK3 containers.
In an informal document, the Netherlands reported on the development of the DockLock system of magnetic mooring for bunkering barges. Over the past two years the system has been extensively tested in practice. The whole system meets the ATEX standard and is in compliance with the ADN on explosion safety. Lloyds Register, as the class society involved, recently issued an Approval in Principle. 5. The Netherlands delegation supported the introduction of this system as a safe and reliable alternative to the use of ropes for mooring and suggested an amendment to 184.108.40.206 to allow its use under ADN.
The Safety Committee felt that the system should be presented to the competent bodies for inland navigation in general, since it can be used on all sorts of vessels. If it meets their approval, then it should be checked whether their use on vessels for the transport of dangerous goods required modifications of ADN.
The European Bulk Oil Traders' Association (EBOTA) had submitted a request for consultative status but it arrived late and did not include all the necessary documentation. Its representative was asked to provide such documentation for the next session.
The ADN Administrative Committee met immediately after the Safety Committee and, by and large, endorsed its decisions. It agreed a derogation for the LNG-powered tank vessel Argos-GL.
The Administrative Committee noted that the Czech Republic had provided information on the recognition of an inspection body within the framework of the ADN in accordance with 1.16.4 and suggested that this body could be invited to participate at a future meeting of the Recommended ADN Classification Societies.
The next session of the ADN Safety Committee was scheduled for 25 to 29 January 2016 and would finalise the amendments due to enter into force on 1 January 2017.[post_title] => Float that boat [post_excerpt] =>
The ADN experts have a big task on their hands trying to maintain modal harmonisation while keeping up with developments in the maritime industry
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