[ID] => 8438
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[post_date] => 2017-08-31 15:50:08
[post_date_gmt] => 2017-08-31 14:50:08
[post_content] => The spring 2017 session of the Joint Meeting of RID/ADR/ADN Experts was held in Bern from 13 to 17 March; Claude Pfauvadel (France) took the chair with Helmut Rein (Germany) acting as vice-chairman. The meeting was attended by representatives of 22 full member states, a representative from DR Congo, the European Commission, European Railways Agency (ERA), Organisation for Cooperation between Railways (OSJD) and 16 non-governmental organisations.
The Joint Meeting deals with matters common to surface mode transport in the states party to the European agreements governing the transport of dangerous goods by rail (RID), road (ADR) and inland waterway (ADN). Observance of those regulations is, however, not limited to Europe and the use of ADR in particular is growing around the world.
The Joint Meeting’s first session of 2017 was its first chance to look at the final decisions taken by the UN Sub-committee of Experts on the Transport of Dangerous Goods (TDG) and its parent Committee in December 2016, which have determined the amendments that appear in the 20th revised edition of the UN Model Regulations. Those amendments now need to be transposed, where appropriate, into RID, ADR and ADN for entry into force (for the most part) in 2019. However, the meeting had plenty of other proposals for amendment on its plate.
As is the usual practice, those papers dealing with issue pertaining to tanks were remitted to a working group, chaired once again by Arne Bale (UK).
Germany proposed to clarify that, when the term ‘diameter of the shell’ is used, it means the internal diameter. A new definition was agreed for 1.2.1.
The European Industrial Gases Association (EIGA) returned to its idea of exempting the safety valves of cryogenic tanks from the requirement of protection against water ingress, which had been discussed at the autumn 2016 session. The working group accepted a revised text for a new paragraph at the end of 22.214.171.124.9:
Safety valves shall be designed to prevent or be protected from the entry of water or other foreign matter which may impair their correct functioning. Any protection shall not impair their performance.
Transitional measures in 126.96.36.199 and 188.8.131.52 were amended to give industry until the first intermediate or periodic inspection after 1 January 2021 to make the necessary changes to their equipment.
A paper from the Netherlands, again following up on earlier discussion, dealt with the rupture pressure of bursting discs but discussion extended to the definition of ‘hermetically closed tank’, the carriage of toxic gases in battery vehicles and multiple-element gas containers (MEGCs), the relationship between the bursting pressure and the opening pressure of the safety valve, the effect of temperature variations, and different approaches for liquids and solids.
After much discussion, a revised definition of ‘hermetically closed tank’ was agreed for 1.2.1; new transitional measures were tentatively agreed, with the cut-off date set for now as the next periodic inspection – these are at 184.108.40.206 (for tank wagons, tank vehicles and demountable tanks) and 220.127.116.11 (for tank containers). The first sentence of the second sub-paragraph in 18.104.22.168.10 is amended to read:
The bursting disc shall rupture at a nominal pressure [between 0.9 to 1.0 times the test pressure], 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.
The words “which may disrupt the action of the safety valve” are deleted from the end of that sub-paragraph.
On a similar topic, the Netherlands proposed the inclusion of provisions for flame arresters on breather devices, following upon a decision taken at the autumn 2016 session to include references to particular sections of EN ISO 16852. It was decided to include a new paragraph in 22.214.171.124.3 to specify which parts of that standard apply for different types of installation. Transitional measures were also agreed.
Another paper from the Netherlands proposed amendments to 126.96.36.199.23 to allow lap joints to be inspected by a non-destructive test other than radiography or ultrasound. While this was agreed, to appear as a footnote to that paragraph, in plenary Belgium wondered if such testing should be subject to competent authority approval. Belgium was invited to return with a proposal at the next session, if it felt it necessary.
The same paper looked at the specific area of a tank to be tested when shell ends are composed of two or more plates welded together. It was agreed to align the wording of 0.8 Lambda and 0.9 Lambda and to include specific mention of the welds in the knuckle area of the tank ends. Again, a transitional measure was added.
A paper from France queried the interpretation of 188.8.131.52.18, in particular in relation to tanks with a circular cross-section with a cut-out. Discussion led to the observation that the regulations as they stand do not really reflect industry practice and they should be modified to allow for different designs and interpretations. The UK offered to draw up a paper to prompt an initial exchange of views, with the aim of pursuing the matter at the autumn 2017 Joint Meeting.
France also presented the working group with a picture of a tank on a road vehicle and asked: is this a tank container or a demountable tank? Opinion varied, suggesting that the definitions of those types of tanks need to be looked at, bearing in mind that there are multimodal implications.
The UK has been continuing with its work on tank approval and certification, and arrived at the spring meeting with a set of fundamental principles agreed by an informal working group. The paper drew some questions and it was evident that the matter is far from complete. Another meeting of the informal working group had been arranged for June 2017 and interested parties were invited to submit their comments.
The International Union of Private Wagons (UIP) proposed to clarify that the requirements of 184.108.40.206.23 also apply to repair shops undertaking welding. However, 220.127.116.11 applies to tank construction, not repair or modification, and it was suggested that 18.104.22.168.4 might be more appropriate. This did not find favour either, the most promising option seeming to be a footnote to 22.214.171.124.23 to draw attention to the role of repair shops. UIP was invited to develop the proposal along these lines and to present an official document at a future session. In plenary, the ERA representative asked if this would affect maintenance workshops; ERA was invited to consult UIP to ensure that its concerns are taken into account.
The UK came forward with the idea of indicating the state in which a type approval for a tank was granted; some countries already do this but others thought it might be useful. The only problem is that there would have to be a transitional provision to cover tanks that have already been issued with type approvals. An amendment to 126.96.36.199.1 was provisionally agreed, pending completion of the transitional provision.
Belgium proposed extending the requirement to enter the actual holding time in the transport document to portable tanks carrying refrigerated liquefied gases. The working group queried whether this was necessary as 188.8.131.52.2 already requires the actual holding time to be marked on the portable tank itself.
An informal document from the UK proposed the inclusion of provisions for carrying out the pressure test using alternative liquids or gases. It was decided to defer consideration of the proposal until the European Committee for Standardisation (CEN) had developed a separate standard for testing with a gas. In the meantime, the UK will prepare a working document covering the fundamental principles.
The Standards Working Group, which met concurrently, discussed some unresolved issues following a teleconference in February between member states and CEN. Those discussions led to a number of amendments:
Standards EN 1252-1:1998 and EN 1626 referenced in this standard are also applicable to closed cryogenic receptacles for the carriage of UN No. 1972 (METHANE, REFRIGERATED LIQUID or NATURAL GAS, REFRIGERATED LIQUID).
- In paragraph (11) of P200, ‘EN 1439:2008’ is updated to ‘EN 1439:
- Immediately after that row, a new row is added for EN 13952: – LPG equipment and accessories – Filling operations for LPG cylinders
- In the same paragraph, the row for EN 12755:2000 is deleted
- In paragraph (12) of P200, ‘EN 1439:2008’ is replaced by ‘EN 1439: and EN 13952:’
- In the Table in 184.108.40.206.5, ‘ISO 11114-1:2002’ is replaced by ‘EN ISO 11114-1:2002 + A1:2017’
- In the same table, ‘Annex A of ISO 10297:2006 or annex A of ISO 10297:2014’ is replaced by ‘Annex A of EN ISO 10297:2006 or annex A of EN ISO 10297:2014 or annex A of EN ISO 10297:2014 + A1:’
- In the Table in 220.127.116.11 under ‘for design and construction’, the Note under the title of EN 1251-2:2000 is amended to read:
- In the same Table, under ‘for closures’, ‘(ISO/DIS 10297:2012)’ is deleted for EN ISO 10297:2014
- In the same Table, against EN ISO 10297:2014, ‘Until further notice’ is replaced by ‘Between 1 January 2015 and 31 December 2020’
- A new row is added after EN ISO 10297:2014 for EN ISO 10297:2014 + A1 – Gas cylinders – Cylinder valves – Specification and type testing
- A new Note is added under the title of EN 1626:2008, similar to that under EN 1251-2:2000 (see above)
- In ADR only, amendments are made in 18.104.22.168.1 to highlight the applicability of EN 13530-2:2002 + A1:2004 and EN 1626:2008 to UN 1972.
It was decided not to refer to EN 13807:2017 – Transportable gas cylinders – Battery vehicles and multiple-element gas containers (MEGCs) – Design, manufacture, identification and testing. This includes technical errors and divergences from RID/ADR. The relevant CEN working group will be asked to address these errors so that the amended standard can be available for referencing in time for the 2019 edition of RID/ADR.
Plenary noted that ISO 2719, referenced in 22.214.171.124.1 and 126.96.36.199.2 and which relates to the determination of flash points, is not dated; the latest published version is ISO 2719:2016.
INTERPRETATION OF RID/ADR/ADN
Following on from an interpretation confirmed at the last session, EIGA asked for more information on the provisions in 188.8.131.52.7 for the marking of bundles of cylinders. In particular, a number of competent authorities had queried the requirement to mark them with the technical standard used for design, manufacture and testing. EIGA’s opinion was that this should be the standard used at the point of original design, manufacture and testing. It also noted that there was no European standard for bundles of cylinders before 2003 and, therefore, any bundles manufactured prior to that date would have been built to a national or in-house standard.
The Joint Meeting confirmed EIGA’s interpretation. During the discussion, Finland’s representative asked whether the reference to EN 12755 in P200 still applies, as this has been replaced by EN ISO 13088. The Standards Working Group was asked to check.
A brief informal paper from France raised some important questions and a lengthy discussion. It sought clarification of the word ‘may’ in 1.8.1, where it says that competent authorities may conduct checks, either spot checks on tanks themselves or in facilities. Does that mean that the companies concerned have to accept being inspected? Further, if a national law in one state makes it impossible for the competent authority to access a facility to undertake such checks, does it mean that any relevant cargo from that facility no longer meets the requirements of RID/ADR/ADN, and what are the consequences?
The Joint Meeting noted that checks under 1.8.1 are mandatory in ADN and therefore have a legal basis; there is no similar provision in RID or ADR and it might be worth giving consideration to including something along the same lines. The ECE Secretariat said he believed that there is an informal understanding among ADR contracting parties to harmonise measures at the national level. Several delegations recognised that the checks mentioned in 1.8.1 are essential to ensure safety and said that national law should allow inspection bodies to act in conformity with the provisions of RID and ADR. Some delegations said they would follow this up with papers for the next session.
In a similar vein, Spain asked whether a safety adviser certificate issued by a country must, under RID/ADR, be accepted in another country for domestic transport and undertakings within that country. It was noted that domestic transport is not legally subject to RID, ADR and ADN and that some states might have restrictions on the recognition of certificates issued in another country. The Joint Meeting felt unable to express a position on the question, as within the EU itself it would require an interpretation of EU law and non-EU contracting parties will have their own legislation.
The European Federation of Waste Management and Environmental Services (FEAD) returned to the topic of low pressure (TL) lamps, asking for the provisions in 184.108.40.206 of ADR to be clarified with a Note to explain that such items are exempted from the regulations. Most delegations felt this unnecessary, as they are clearly exempted from the provisions by special provision 366. On the other hand, Germany noted that SP 366 requires that the mercury within the lamp is permanently enclosed, which would not be the case when lamps are being collected for recycling or disposal. Germany felt the issue should be taken up by the UN TDG Sub-committee and offered to prepare a paper. No decision was taken by the Joint Meeting at this point.
FEAD also returned with a formal proposal to allow metal intermediate bulk containers (IBCs) to be used to transport waste either loose or in small packagings. FEAD’s paper noted that the waste sector has developed containers that are built, tested and approved in accordance with Chapters 6.1 and 6.5 of ADR and that are thus approved both as a 4A box and an 11A IBC. Around 500,000 such units are currently in use in Europe, FEAD said. It sought to clarify the legal position within ADR by adding a new provision in packing instructions IBC04 and IBC08 to allow the transport of waste in small receptacles within these IBCs.
Opinions remained divided but during discussion it emerged that most delegations had reservations on one aspect or another of the proposal. Having been put to a vote, the proposal was rejected.
NEW PROPOSALS FOR AMENDMENT
Italy had spotted that, after the adoption of the code ‘LL1’ as a special packing provision specific for RID and ADR, relevant to the entry UN 3509, as part of the 2015 amendments, this should be reflected in the explanatory note for Column (9a) in Table A of Chapter 3.2. The Joint Meeting agreed and inserted “or the letters LL” after “with the letter ‘L’” in 3.2.1.
Italy also sought some changes to the provisions for large packagings, noting that, under 220.127.116.11(c), the letter ‘X’ is designated for packing groups I, II and III, whereas no packing group I substances may be transported in large packagings. Its paper asked if its three proposals should be put to the UN TDG Sub-committee, with which the Joint Meeting agreed.
Germany had noticed that, when UN 0509 powder, smokeless (Division 1.4C) was added to RID/ADR in 2011, it was not assigned to special provision MP24. Its paper said that it should be treated analogously with UN 0161 powder, smokeless (Division 1.3C) with regard to mixed packaging. The Joint Meeting agreed and made the necessary change, adding ‘MP24’ against UN 0509 in the Dangerous Goods List.
And informal document from Romania, the International Union of Railways (UIC) and the International Road Transport Union (IRU) picked up on amendments in the 20th revised edition of the UN Model Regulations in terms of the rationalisation of the terms ‘danger’, ‘hazard’ and ‘risk’. While the ad hoc Working Group on the Harmonisation of RID/ADR/ADN with the UN Model Regulations will pick up on the changes, RID/ADR/ADN have other parts that also need to be examined.
The Joint Meeting felt it would be best if the ad hoc Working Group could also cover these parts of the modal regulations, if time permits. If not, it should be left to the various modal authorities to examine their respective texts.
Sweden noted that special provision 250 in ADR and RID refers to packing instruction 623 in the ICAO Technical Instructions, pointing to S-3-8 of the Supplement. Following restructuring of the Technical Instructions, the information has been moved to a new section, S-4-8, and therefore SP 250 need s amendment. This raised the question of whether it is desirable to reference the Supplement to the Technical Instructions in RID/ADR/ADN and Sweden was asked to check whether the packing instruction in question had not been included in the 2017 texts of the land transport regulations.
An alternative proposal from Sweden suggested the deletion of the reference to the Technical Instructions and harmonising the text of SP 250 with that in the UN Model Regulations. It was agreed that the reference should be removed; more work on this issue is likely.
An informal document from Russia identified a number of places in the regulatory text where the provisions are, it felt, ambiguous or unclear and could lead to erroneous interpretation or application. The Joint Meeting felt, though, that as the Russian paper solely referred to the text of RID it should check to see if the problems apply in ADR and ADN and, if not, the matter should be taken up by the Standing Working Group at OTIF. Furthermore, as the paper had been submitted late there was no time to look at it in detail at the Joint Meeting.
Italy put forward two papers on the examination for dangerous goods safety advisers (DGSA). The first sought deletion of the allowance in 18.104.22.168.2 on the renewal of certificates for existing DGSAs not to have to undertake the case study element of the initial examination, feeling that a full examination in accordance with 22.214.171.124.4 is necessary when a certificate is renewed. Opinions were divided but, on a vote, the proposal was rejected.
Italy also sought alignment across all signatories of the required pass mark for the DGSA examination. The idea was not widely supported and the proposal was withdrawn. Italy had also proposed that, when a DGSA extends the validity of an existing certificate, for instance to cover other modes, then the new certificate should only be valid for the same period as the existing certificate. The Joint Meeting felt this was worth adopting and inserted a new 126.96.36.199 to say so.
UIC came to the session with a paper dealing with the weather resistance of placards, orange-coloured plates and marks, noting that problems regularly occur in combined transport when such hazard communication becomes degraded over time as a result of adverse conditions. It sought some toughening in the existing specifications in 188.8.131.52, 184.108.40.206.1.7 and 220.127.116.11, in line with 18.104.22.168.1.2 of the International Maritime Dangerous Goods (IMDG) Code and suggested some alternative texts. After discussion, UIC presented some abbreviated versions but no decision could be reached. A new proposal will be submitted at the next session, taking into account the comments made.
The second part of this report on the spring 2017 Joint Meeting in next month’s HCB will cover the reports of the various informal working groups and the relationship of RID/ADR/ADN with other regulatory provisions.
[post_title] => RID/ADR/ADN: Ahead of the game
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[post_modified] => 2017-08-31 15:50:08
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