[ID] => 8534
[post_author] => 34
[post_date] => 2017-09-20 12:28:38
[post_date_gmt] => 2017-09-20 11:28:38
[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.
Detailed technical proposals relating to tanks and standards were passed on to dedicated working groups and the plenary session adopted most of their conclusions. The Joint Meeting also faced a number of ongoing and new proposals for amendment. These issues were covered in the first part of this report (HCB October 2017, page 120). Discussion then turned to reports from other informal working groups.
The European LPG Association (AEGPL) presented an informal document with an update on the progress being made by the informal working group on alternative methods for periodic inspections of refillable pressure receptacles, which had met in Paris in January 2017. The paper included three proposals for amendments to RID/ADR/ADN in response to comments made at the autumn 2016 session of the Joint Meeting.
The paper first proposed addition of a new 220.127.116.11.3 with general provisions for the substitution of dedicated checks for periodic inspections required by 18.104.22.168.1, when the receptacle’s design prevents one or more of the checks in the periodic inspection from being successfully applied or providing meaningful results.
A second proposal laid out general provisions for destructive tests and the evaluation of their results. Finally, a more specific proposal related to over-moulded cylinders included a new definition, a new special provision and details of the required tests and acceptable results.
The paper drew many comments. In particular, some experts were worried about the mixture of guidelines and procedures that the proposals would add to the regulations, in addition to the actual technical requirements. There are also questions remaining on sampling rules and the definition of a possible service life in light of potential degradation and ageing characteristics. Some detail on acceptable confidence and risk levels should also be included.
In addition, the informal working group was invited to develop technical guidelines for the implementation of alternative control methods. As opinions differed regarding the incorporation of these guidelines into the regulations, the issue will be considered by the informal working group for a later decision by the Joint Meeting.
BLEVE RISK REDUCTION
France presented a report on work carried out by the National Institute for Environmental Technology and Risks (Ineris) on boiling liquid evaporating vapour explosions (BLEVEs) in the context of the informal working group on reducing the risk of a BLEVE during the transport of dangerous goods.
Ineris has developed a predictive tool to forecast the behaviour of LPG tanks when exposed to fire and the effects of the use of safety valves and thermal coatings in different tank geometries. The results of the Ineris model are consistent with experimental tests carried out in 2013 and 2014 by Germany’s Federal Institute for Materials Research and Testing (BAM) and offer a way of covering a broad range of scenarios without the need for expensive destructive tests. However, the French paper said, more tests might be necessary before final validation of the model. A number of delegates said they could provide experimental data to help with this process.
A technical discussion followed on the respective merits of the different ways of preventing BLEVEs, with some delegations expressing reservations about the use of thermal insulation, given both the possible economic drawbacks (cost and reduction in carrying capacity) and the safety concerns (risk of damage, corrosion, etc). It was, however, recalled that all the relevant elements need to be taken into account in the context of risk assessment and it would be preferable for the technical discussions to take place within the informal working group.
Interested delegates were invited to inform the representative of France of any simulations that they would like to see carried out. Results of those simulations would be presented at the autumn 2017 Joint Meeting, at which point a new mandate would be decided on for the continuation of the informal working group’s activities.
The European Railways Agency (ERA) presented a report on the eighth and ninth workshops on the roadmap for risk management in the inland transport of dangerous goods by road, rail and inland waterways, which were held in October 2016 and February 2017, respectively.
The eighth meeting was largely devoted to reviewing progress and determining further direction. It was noted that, while there is a lot of work still to be done to finalise the three guides and two user manuals that are envisaged, the principles and content of these documents has been agreed. It was anticipated that first versions of the documents could be ready by the end of 2017 and ERA was asked to consider how their ongoing maintenance would be arranged.
The ninth workshop provided an opportunity for those groups working on the three guides to discuss the interaction of the guides and to solve potential gaps and inconsistencies. It was agreed that a combination of the risk estimation method and the decision-making process will establish a versatile and transparent risk-based decision-making standard that could be applied to a variety of risk situations in the transport of dangerous goods, including those foreseen in Chapter 1.9 of RID/ADR/ADN.
During the discussions, it was noted that the framework of the guides will clearly describe the independent roles and responsibilities of the risk estimators and decision-makers in order to avoid biased risk estimations/decisions. As a principle, it was agreed that the user of the risk estimation guide will be responsible for delivering good quality risk estimations to the decision-maker, and that the decision-maker should not intervene directly in the practical risk estimation tasks.
It was also stressed that, while the decision-making process will make use of risk estimation indicators, the decision-making guide will not define risk acceptance criteria in its first version. This will allow for more flexible use of the first version of the guide and for making stock of user experience before this need is reconsidered.
Other discussions revolved around the need for a high-profile launch event early in 2018, the need for publication in various languages, and ownership of the guides.
ERA noted that the tenth workshop, which was to be held in June 2017, would consider a plan of action for the period 2018-2021. Delegates at the Joint Meeting were invited to attend.
The Joint Meeting recalled that the whole process had been set up in response to a need for harmonisation of risk management procedures within the EU, and that their results could be reflected in a European directive. Also, in order to allow the Joint Meeting to the discuss the potential implementation of the procedures contained in the guides, it was suggested that ERA give a presentation of the guides under development at the autumn 2017 session.
The European Industrial Gases Association (EIGA) returned to the troubled issue of the mutual recognition of pressure receptacles between the US and those states party to RID, ADR and ADN. It reported that work has been slow in drawing up a petition for rulemaking in the US to allow for reciprocity but that it was anticipated that a submission would be made soon. EIGA promised to keep the Joint Meeting informed and, should the petition be successful, felt it would then be appropriate to include a new 22.214.171.124 in RID/ADR/ADN to mirror the text in multilateral agreement M299.
The International Union of Railways (UIC), the International Road Transport Union (IRU) and the European Chemical Industry Council (Cefic) reported on developments in Poland, where a new law to indicate the owner of the dangerous goods being carried on documents required in Chapter 5.4 has entered into force. This is causing problems as it introduces a disharmony in documentation, which runs counter to the aims and terms of the ADR Agreement and other transport agreements. The Polish government had noted industry concerns and that investigations would take place to find the best solution both for the industry and to facilitate international trade. The EU has also promised to initiate an official procedure.
Subsequently, as part of its Transportation Package of fiscal measures, Poland is planning further measures for certain dangerous goods for tax reasons, such as special reporting and monitoring obligations for consignors, carriers and consignees, using global positioning system, among other things.
The Joint Meeting noted that the requirement to indicate the owner of dangerous goods in transport documents in Poland was linked to a tax regulation and that the government of Poland did not consider it to be in contradiction with ADR, in view of article 4(1). It also noted that the European Commission was considering the legal aspects.
The Secretariat of the Intergovernmental Organisation for International Carriage by Rail (OTIF) provided an update on problems with harmonisation of RID with SMGS Annex 2, the corresponding provisions used by the Organisation for Cooperation Between Railways (OSJD). The 2017 amendments to RID have not been adopted into SMGS Annex 2, largely because of Russia’s insistence that all new and existing references to EU Directives and EN Standards should be deleted. As OSJD organs work on the principle of unanimity, this has prevented adoption of the latest amendments.
The OSJD Group of Experts on Provisions for the Carriage of Dangerous Goods and the OSJD Commission for Transport Law both met in February 2017 but once more no decision could be taken. Both Russia and China were – perhaps with some justification – concerned by the fact that EN standards do not cover the entire range of issues and urged reference to globally acceptable ISO standards. Russia also pointed out that, along with Belarus, Kazakhstan and Kyrgyzstan, it is part of a trade bloc where there are different provisions for pressure receptacles and it would be necessary to check whether the newly referenced EN standards accord with the provisions in place in those countries.
A number of options were investigated but, as of 1 July 2017, there is disharmony between the two sets of provisions. This is of particular concern to those countries that are party to both RID/ADR/ADN and OSJD but also to those that apply ADR for road transport and SMGS for rail transport. The Joint Meeting hoped that the OSJD member states would be able to adopt at least those amendments not related to the CEN standardisation work and EU directives. Some OSJD stated had requested that the next meeting of the OSJD Commission for Transport Law, planned for October 2017, could be brought forward to allow the issue to be discussed.
The Council on Safe Transportation of Hazardous Articles (COSTHA) had applied for consultative status at the Joint Meeting. After some discussion that request was granted.
The autumn session of the Joint Meeting took place in late September 2017; a report on that session will appear in a forthcoming issue of HCB.
[post_title] => RID/ADR/ADN: Border controls
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[post_name] => ridadradn-border-controls
[post_modified] => 2017-09-20 12:28:38
[post_modified_gmt] => 2017-09-20 11:28:38
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RID/ADR/ADN: Border controls
The Joint Meeting was happy to hear of progress with ongoing issues but relations with regulators in Eastern Europe and Asia are causing problems