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RID experts agree changes
CATCH THE LAST TRAIN
RAIL • THEY WERE NOT TO KNOW IT AT THE TIME, BUT THE RID STANDING WORKING GROUP’S NOVEMBER 2019 SESSION WAS THE LAST OPPORTUNITY TO MAKE CHANGES TO THE 2021 TEXT
THE RID COMMITTEE of Experts’ standing working group held its 11th session in Vienna this past 25 to 28 November. Its main task was to progress with agreement of the amendments that will appear in the 2021 text of RID, the regulations governing the transport of dangerous goods by rail in much of Europe, taking account of the amendments included in the 21st revised edition of the UN Model Regulations and the decisions made by the RID/ADR/ADN Joint Meeting of experts. The session was chaired by Caroline Bailleux (Belgium) with Othmar Krammer (Austria) as vice-chair. It was attended by delegations from 19 RID contracting states and representatives from Russia (as an OTIF member state that does not apply RID), the European Commission, the EU Agency for Railways (ERA), the Organisation for Cooperation of Railways (OSJD) and five non-governmental organisations.
UN HARMONISATION The Secretariat provided the meeting with a consolidated list of the amendments agreed at its session in November 2018 and those adopted by the Joint Meeting in 2018 and 2019. The meeting confirmed the changes, correcting a few errors along the way. [HCB will report in more detail on the amendments adopted once the final text has been approved later in the year.]
Russia picked up on the use of different formats in the presentation of alphanumeric codes: in the Dangerous Goods List these are shown without blank spaces but in the texts of the provisions they are shown with blank spaces. This could cause problems when using IT systems. Austria pointed out that the UN Model Regulations also use alphanumeric codes without blank spaces throughout.
Belgium followed up on a proposal made by the International Tank Container Organisation (ITCO) at the Joint Meeting in September 2019 to refine the definition of ‘tank-container or portable tank operator’, which had been adopted. ITCO had not made any proposal to amend the definition of ‘operator of a tank-wagon’, which Belgium now offered, on the basis that the term ‘operator’ in this context is equivalent to the term ‘keeper’ as used in other rail-related legislation and regulations.
The standing working group did not accept the rewording of the definition of ‘operator of a tank-wagon’, as it felt it is correct as it stands. However, it did amend footnote 5 to that definition, to update the references to EU directives on railway safety and interoperability.
The Secretariat provided a paper detailing the necessary updates to some of the transitional provisions, which were all adopted. The general provisions in 1.6.1.1 were extended by two years, along with the documentation details in 5.4.1.1.12. The existing transitional provisions in 1.6.1.30 and 1.6.3.3.2 were deleted, as they will be out of date by 2021, as was the final paragraph in 1.6.3.27(a). The UK noted that the transitional provisions in 1.6.3.16 and 1.6.4.18 will still have to be amended.
The Secretariat also provided the meeting with an extract from the draft report of the 107th session of the Working Party on the Transport of Dangerous Goods (WP15), held from 11 to 15 November (and reported on in HCB in the March 2020 issue, beginning on page 66), concentrating on those items with relevance to the rail transport sector. The paper included a list of proposed changes, mostly editorial in nature and not all applicable to the English language version of RID, which were carried over into RID.
One exception was made. An amendment to footnote 5 to 6.8.2.1.18 was proposed but the standing working group noticed that this footnote appears in the tank container column in RID but not in ADR; in order to align RID and ADR in terms of tank container operations, footnote 5 and reference to it in 6.8.2.1.18 and 6.8.2.1.19 were deleted.
Switzerland sought the opinion of the standing working group on the issue of the type of inspection to be performed on tanks covered by Chapter 6.8 of RID/ADR in cases where the three-month period provided for by 6.8.2.4.3 has expired. It felt that discussion was necessary as there is now confusion among both inspection bodies and users, which derives from changes adopted by the Joint Meeting in September 2019 based on the text in the 21st revised edition of the UN Model Regulations.
In response, Belgium and the International Union of Wagon Keepers (UIP) both were of the opinion that the matter is clear: if the three-month period is exceeded the intermediate inspection must still be carried out, though there is no need for a periodic inspection, as is the case with portable tanks. For subsequent inspections, the date originally specified remains unaltered. Austria concurred and pointed out that 4.3.2.4.4 allows the carriage of empty uncleaned tanks after the expiry of the three-month period, for the purpose of undergoing the inspection.
The Secretariat also circulated a list of corrections to the 2019 text of RID; again, many of these did not apply to the English language version and, of those that did, most were editorial in nature. One that might have been causing problems is found in paragraph (b)(ii) of special provision 670, where “333 g” is corrected to read “333 kg”.
PROPOSALS FOR AMENDMENT Belgium pointed out that the Joint Meeting’s informal working group on the testing and certification of tanks was developing proposals for amendments to RID/ADR Chapter 6.8, 1.8.6 and 1.8.7. Belgium’s opinion was that there were no amendments concerning the approval and registration process for tank-wagons, so there was no need for specific amendments to RID.
UIP noted that the mutual recognition of inspections had been introduced into RID ten years ago so as to avoid the need for a tank-wagon to return to the country in which it was approved for its inspection. The texts proposed to the Joint Meeting would reflect the existing RID text. However, it should be made clearer that approvals from the country of manufacture must always be recognised and UIP felt that the newly introduced ‘entry into service verification’ should be dispensed with when registering in another country.
ERA pointed out that, in the context of the vehicle approval, an administrative check of the tank’s design type approval certificate and the initial inspection certificate is carried out, without re-checking the technical content of the certification. The keeper decides which country to register the vehicle in, which must be within the area in which the vehicle is intended to be used. ERA also confirmed that the registration of a vehicle is an independent step, coming after the authorisation of the vehicle. ERA was of the view that the entry into service verification could not call the approval procedure into question.
There was clearly some disagreement on these questions and the chair pointed out that the next meeting of the informal working group on the testing and certification of tanks was due to take place in December 2019; delegations were urged to send any comments to the chair of that group as soon as possible.
THE RID COMMITTEE OF EXPERTS’ STANDING WORKING
GROUP HAS TO TAKE ACCOUNT OF THE FACT THAT MANY
TRANSPORT UNITS USED IN RAIL OPERATIONS ARE
The European Commission also pointed out that it was preparing a decision of the Council of the EU on the 2021 amendments to RID and only minor decisions made by the March 2020 Joint Meeting or the May 2020 session of the standing working group [both of which were, in any case, cancelled due to the Covid-19 crisis] would be included. As such, the amendments proposed would not enter into force until 2023.
Russia proposed that the definition of ‘fine grain steel’ in 6.7.2.1 should be clarified, with reference to ISO 643:2012, and that it should be moved to 1.2.1 as it also applies to Chapter 6.8. The standing working group was sympathetic to the paper and several delegations were in favour of Russia’s suggestion to use the term ‘grain number’ in the definition. Russia was asked to submit a proposal to the UN Sub-committee of Experts, taking the comments made into account.
TANK AND VEHICLE TECHNOLOGY The Secretariat provided a paper with the report of the 17th session of the RID working group on tank and vehicle technology, which had taken place in Ludwigshafen on 14 and 15 October under the chairmanship of Rainer Kogelheide (Germany).
Attendees at the session had the opportunity to tour the BASF plant in Ludwigshafen and see for themselves the new generation of extra-large tank containers in action at the site. These tanks are transported around the facility on driverless vehicles and there is a storage area for 600 tanks. Professor Hecht of the Technical University of Berlin explained the risk assessment that had been carried out on behalf of BASF, which compared the new arrangement with the use of 20-foot tank containers on conventional carrying vehicles and with the use of tank-wagons. In terms of rail transport, the risk assessment concluded that, in all respects, such extra-large tank containers are at least as safe as conventional tanks, provided that the existing provisions are applied, although the protective aims of special provisions TE22 and TE25 could be achieved by significantly increasing the distance between the buffers and the end of the tank.
UIP pointed out that the extra-large tankcontainers and innovative carrying wagons and the operational conditions under which they are currently running had been taken as a basis for the risk assessment. In particular, only humps with automatic retarders had been travelled over and the extra-large tank-containers had only been loaded at certain transhipment terminals whose staff had been trained accordingly so that extra-large tank-containers were only loaded onto suitable carrying wagons. It was therefore necessary to adapt the provisions to avoid the system being used in operating environments for which the safety of the system had not been checked.
The European Chemical Industry Council (Cefic), which has been involved in the project, explained that the new tanks are optimised for rail transport but have also been approved for road and inland waterway use. At the BASF site, they are already carried intermodally before and after carriage by rail on automated guided vehicles. For these vehicles, approval for their use on selected public roads around intermodal terminals was currently being examined with the ministries and authorities responsible for approval in Germany. As the
automated guided vehicles only travel at 25 km/h, travelling by road over distances of more than 30 km is not economically viable. It is the intention that, for distances of more than 30 km, the railways should be used.
Uncleaned, empty extra-large tank-containers are already carried without restriction on conventional road vehicles on public roads, when tanks are being carried for cleaning or to workshops. Carriage of such tanks in a loaded condition, when they can weigh 75 tonnes, on conventional road vehicles requires special approval from the competent authorities. BASF had not at the time applied for any such special approvals. There are plans to use the tank containers in maritime transport (e.g. for carriage to the US and China), but this has not yet been done, as terminal infrastructure (cranes) would be needed and it would take several years to build such infrastructure.
Germany thought that, as the tanks are being used in multimodal transport, it may be necessary to discuss a definition at the RID/ADR/ADN Joint Meeting so as to distinguish between different types of tank.
Germany also presented a preliminary assessment of certain questions arising from the risk assessment. While the extra-large tank containers and innovative carrying wagons meet the current requirements, it cannot be taken that the provisions do not need to be adapted, particularly as stricter requirements had been taken into account with these new tanks and this would have to be documented to ensure that future projects follow the same degree of safety.
Cefic did not agree. It pointed out that tank containers, including the new tanks, had proven to be safe in the tests and simulations that had been carried out. The existing provisions therefore cover the extra-large tank containers very well. Some modifications are necessary to the provisions for the carrying wagons, so that all participants in the transport operation can select wagons that are suitable for the new tanks.
One other topic was raised by UIP, which sought an amendment to the text of footnote 1 to 6.8.2.1.2 that deals with the checking of stress resistance in tank-wagons. ERA was against the idea, as it would have to be cross-checked with EU directives, and other experts were also dubious. However, after discussion, a revised version was submitted which, with a few amendments, was adopted. Owing to ERA’s reservation, the text has been left in square brackets. Germany and UIP said they would use the adopted text as a basis for a proposal to amend the standards EN 12663-2:2010 and EN 14025.
RID/SMGS HARMONISATION Russia updated the standing working group on the progress of work on the new Chapter 6.20 of Annex 2 of the Agreement on International Freight (SMGS), which includes the construction and testing of tank-wagons for use on 1,520-mm gauge tracks. This work has raised some questions about the corresponding provisions in RID for standardgauge tank-wagons.
One issue is the difference in the requirements concerning the non-destructive testing of welds, where the Russian national standard (GOST) takes a different approach to ISO. The standing working group did not feel it was in a position to assess the implications of this difference and asked Russia to consider submitting a paper to the Joint Meeting’s working group on tanks.
The paper also explained that 1,520-mm gauge tank-wagons in Class 2 use may be filled to a maximum level of 83 to 85 per cent, in addition to the maximum mass of filling per litre of capacity. This is achieved by the use of a shut-off valve. UIP said that, while this method of filling is not used for standard gauge tank-wagons, it did not pose a safety risk.
RID AIMS TO ALIGN AS MUCH AS POSSIBLE WITH THE
SMGS RULES IN FORCE FOR THE WIDE-GAUGE RAIL
Russia also informed the group that there is a plan to extend the periodic inspection deadline for tank-wagons for the carriage of liquefied gases from eight years to ten. The standing working group did not see any safety-related problems. UIP was of the opinion that, bearing in mind the low corrosiveness of liquefied gases, it might make sense to make the same change in RID.
Russia also proposed an amendment to special provision TE14 to take account of tankwagons equipped with thermal insulation and a heating system, which are used for the carriage of molten sulphur or liquid pitch, for example. On such tank-wagons, the thermal insulation is not in contact with the tank shell but with the heating system. This proposal was welcomed but, as TE14 appears in both RID and ADR, Russia was asked to submit the proposal to the Joint Meeting.
Russia also felt that the provisions in RID for calculating the minimum wall thickness of the shell are not clear and could be misinterpreted. UIP confirmed that the provision for permissible stress values in 6.8.2.16 should be checked. Again, Russia was asked to submit a paper to the Joint Meeting’s working group on tanks.
Russia further reported on some research and testing that had been carried out to investigate the corrosion rate of concentrated nitric acid (UN 2031) on aluminium alloy. At present, it is only allowed to be carried in high-purity (at least 99.5 per cent) aluminium but the testing found no difference when aluminium alloy was used. Russia proposed an amendment to permit the carriage of UN 2031 nitric acid in tank-wagons with shells made of aluminium alloy. The proposal was supported by UIP and the UK but it was felt that, again, this was a topic that needed to be dealt with by the Joint Meeting’s working group on tanks.
ERA INFORMATION On the request of the European Commission, ERA now provides the standing working group with a regular update of its activities, which at this session included some valuable feedback from its work in the vehicle authorisation process. It raised the point that the ‘entry into service verification’ step, that is to be included in the 2021 text of RID, covers among other things the conditions to be applied for the use of the tanks; this ERA considers to be outside the scope of the authorisation process. The responsibility of performing the configuration management of vehicles lies with the keeper or an entity entrusted by the keeper.
Following the publication of the guides to the Inland Risk Management Framework and the positive response of the Joint Meeting at its autumn 2019 session, ERA believed that the guides should be referenced in footnotes in Chapter 1.9. This idea was welcomed by many delegations and ERA was to present a formal proposal to the Joint Meeting.
OTHER BUSINESS The Secretariat informed the standing working group that Gulf Cooperation Council (GCC) member states were intending to accede to the Convention concerning International Carriage by Rail (COTIF) and, hence, to RID. It also highlighted the fact that Saudi Arabian Railways (SAR) had
THE WORKING GROUP WAS INVITED TO CONSIDER
EQUIVALENCE BETWEEN RID AND US TANK
already signed contracts for 1,500 tankwagons built in accordance with North American provisions.
UIP explained that there are fundamental differences between North American and European tank-wagons; if SAR intends to use these tanks purely on its own network it is not a problem but they cannot be used in international transport with other RID states. Austria observed that, within the GCC states, this could be achieved through the use of derogations in 1.5.1 but SAR will need to consider how the tank-wagons are to be employed.
As part of the investigation into this issue, it was observed that RID does not contain any provisions dealing with equivalence between those standards referenced in RID and other standards. The Secretariat invited the standing working group to consider the subject, noting that it was in discussion with GCC with the aim of commissioning a study to compare the relevant standards.
Some delegations questioned the use of such a study, with the Netherlands being of the opinion that, if one were to be carried out, it should be the responsibility of candidates for accession to RID. The standing working group also confirmed the conclusion reached by the working group on tank and vehicle technology, that regionally applicable CEN standards should not be replaced by globally applicable ISO standards.
The Secretariat also presented a paper containing the guidelines for the use of RID/ ADR/ADN 5.4.0.2 on the use of electronic data exchange to satisfy the documentation requirements of Chapter 5.4, which had been adopted by the Joint Meeting. The standing working group confirmed it was happy to adopt the guidelines and asked the Secretariat to make them available on the OTIF website.
The 12th session of the RID Committee of Experts’ standing working group was due to be held in Bern on 25 and 26 May; however, due to the Covid-19 pandemic and the restrictions on travel and gatherings, this session was postponed until late November. The planned session of the RID Committee of Experts, scheduled for 27 May, was cancelled. That session was due to confirm the amendments adopted by the standing working group for publications in the 2021 text of RID. It is understood that the 2021 text will include only those changes adopted at the 10th and 11th sessions, with any consequential amendments and corrections. The final draft version of RID 2021 will be circulated to states and adopted using the written procedures.
