ADN 2023 nears completion

RIVER CLEANUP

INLAND WATERWAYS • WHILE THE ADN SAFETY COMMITTEE ADHERES WHERE POSSIBLE TO HARMONISATION WITH RID AND ADR, IT HAS PLENTY OF OTHER MATTERS TO CONSIDER

THE JOINT MEETING of Experts on the Regulations annexed to the European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways – the ADN Safety Committee – held its 39th session this past 24 to 28 January. It was chaired by Henk Langenberg (Netherlands) with Bernd Birklhuber (Austria) as vice-chair. The meeting was attended by representatives of 13 countries, the Central Commission for the Navigation of the Rhine (CCNR), the Danube Commission, the European Commission and Transport Community, and nine non-governmental organisations.

Once more, the session was hampered by ongoing Covid-19 response measures and the UN’s financial constraints. The UN Economic Commission for Europe (ECE) is optimistic of being able to return to normal business in the second half of the year. Pending that normalisation, the Safety Committee held its January session in hybrid format.

At its July 2021 session, the ECE Executive Committee had asked for input from its subsidiary bodies on the development of measures that will promote a circular economy and the sustainable use of natural resources; the Safety Committee invited delegations with information on these issues to present it at the next session.

The Danube Commission reported on trends in navigation in 2021; there was a sharp drop in cruise passenger vessels as a result of Covid-19 restrictions, although the decline in cargo vessels seen in 2020 had levelled off.

IMPLEMENTATION AND INTERPRETATION The Netherlands followed up on discussions at the previous session with a formal proposal to include specific provisions for the carriage of UN 1288 Shale oil in tank vessels, following a request for special authorisation in its own country. The Safety Committee found this agreeable, after being assured by FuelsEurope that shale oil with a high water content is not normally transported as it is uneconomic to do so.

The main changes agreed are the insertion of ‘T’ in column (8) of Table A in Chapter 3.2 for both UN 1288 entries (packing groups II and III), and the addition of corresponding entries in Table C in Chapter 3.2.

The Recommended ADN Classification Societies had been asked to review the Safety Committee’s interpretations, given at the 35th session, on acceptable ventilation systems specified in 9.3.3.12.2. Having done so, the group took issue with the idea that hatch covers can be used as a ventilation system, since class rules require a ventilation pipe for void spaces and also that an opened hatch cover is regarded as an ‘undefined opening’ with respect to stability calculations.

The Safety Committee agreed to amend its interpretation in line with the Societies’ comments and to publish that interpretation on the UN ECE website. It felt there was no need to amend the current transitional provisions in 1.6.7.2.2.2.

The European Barge Union (EBU) and European Skippers Organisation (ESO) appealed for a rationalisation of the provisions for the transport of carbon dioxide, ethylene and methane (LNG) – all gases carried as refrigerated liquids. All require a barge type G,1,1 with refrigeration system but, whereas UN 1038 Ethylene and UN 1972 Methane are assigned transport provisions 2, 31 and 42, UN 2187 Carbon dioxide is assigned 31 and 39.

The Safety Committee welcomed the

proposal and asked the informal working group on substances to consider whether transport provision 42 should be added against UN 2187, which would mean that no refrigerating system is required so long as the holding time in relation to temperature elevation and boil-off is sufficient and guaranteed. The Safety Committee will aim to continue discussion at the next session based on the feedback from the informal working group.

The Netherlands revealed that it intends to perform a study on whether flame arresters that are not certified for withstanding a steady burning of 30 minutes or longer but which can withstand detonations and deflagrations are suitable to ensure safety during degassing operations. Members of the Safety Committee were invited to share their experience of relevance with the Dutch authorities. The Netherlands may revert with a proposal, depending on the outcome of the study.

Germany opened a discussion on the list of interpretations of ADN published on the UN ECE website, noting that the Recommended ADN Classification Societies also have their own list; the Safety Committee asked that this list could also be published by UN ECE. It also noted some comments on possible unified interpretations similar to those in the International Maritime Dangerous Goods (IMDG) Code, although there was concern that these texts are voluminous and, were there to be a similar section in ADN it should be as concise and clear as possible. It was agreed that the Safety Committee should consider publishing its interpretations on a case by case basis.

PROPOSALS FOR AMENDMENT The Secretariat had prepared a list of those amendments agreed by the RID/ADR/ADN Joint Meeting in 2020 and 2021 that were of relevance to ADN, which the Safety Committee adopted with some changes. It also adopted amendments relevant to ADN that had been agreed by the UN ECE Working Party on the Transport of Dangerous Goods (WP15) at its 110th session, as amended. WP15 may agree more changes at its 111th session, which will be considered at the Safety Committee’s 40th session.

CCNR had been doing some work on the different language versions of ADN, proposing to align the texts in 9.1.0.40.2.5(c) and 9.3.x.40.2.5(c) on triggering devices, though the Safety Committee was concerned that this might conflict with the European Standard on Technical Requirements for Inland Navigation Vessels (ES-TRIN). CCNR may review the proposal. It also proposed aligning the various linguistic versions in the terminology used to describe ‘protective suit’, ‘protective equipment’ and ‘personal protective equipment’, which was accepted by the Safety Committee.

CCNR also sought to harmonise the terminology used in the sections on the berthing of vessels and their location during loading, unloading and degassing. There were some concerns expressed at the vagueness of terms such as “nearby” and “in the immediate vicinity”, though it was felt that some latitude was necessary and it is up to the relevant competent authority to determine how to interpret those terms. The changes, which are textual of nature, were adopted and appear in 1.9.3(c), 8.1.2.2(f) and 8.1.2.3(s).

Another paper from CCNR sought to align the various language versions of 9.3.4.3.1.2.2.1.3, the Germany version being seen as the most comprehensive. This section deals with the vertical collision locations. The Safety Committee agreed with the proposal and adopted changes to the English and French versions.

Germany noted that the content of 1.8.3.17 on safety advisers had been deleted from ADR and RID since the 2011 editions; the Safety Committee recognised the issue and decided to also delete this sub-section.

Germany also followed up on earlier discussions on the training and examination of experts and the harmonisation of procedures among the ADN Contracting Parties. While there were some concerns noted, particularly regarding the length of time needed to organise recurrent examinations, it was agreed to make some changes.

In 8.2.2.3.3, the description of ‘Prior training’ for specialisation courses on gases and chemicals is changed to read:

Examination passed after “tank vessels” or combined “dry cargo vessels/tank vessels” ADN basic training. 8.2.2.7.1.1 is amended to read:

After basic training, an examination shall be taken within six months following the completion of such training. If a candidate fails the examination, he or she may retake it twice during this six-month period without attending another basic training course.

The last sentence of the second paragraph of 8.2.2.7.2.5 is amended to read:

If a candidate fails the examination, he or she

may retake it, fully or partially, twice during this six-month period without attending another specialization course. If the 44 marks are not achieved, the exam may be taken again in its entirety. If the candidate obtains 44 but does not achieve 20 in one part, only the part in question may be taken again.

France proposed to amend Chapter 1.16 to exempt seagoing vessels from the requirement to hold a certificate of approval for navigating on inland waterways, provided that such vessels are in possession of the relevant certificates applicable to maritime navigation. There was some support for the proposal but most experts felt that such vessels should conform to the specific construction requirements for inland waterway vessels. On the other hand, it was mentioned that ADN should be careful not to include contradictory requirements. The proposal was not adopted.

Germany arrived with a lengthy list of proposed updates to the referenced standards. .Although there was some opposition to the paper, on the basis that there had not been time to check the revised standards thoroughly and that some were unavailable to the meeting, the Safety Committee did adopt a number of the proposed changes. There was a question as to whether onboard equipment should be replaced after a transitional period, which will be discussed at a future meeting of interested delegates. FuelsEurope pointed out that 2.2.3.1.5 of ADN references the UN Manual of Tests and Criteria where it refers to ISO 2431:1984; this is to be updated to ISO 2431:2019 in ADN and the secretariat was asked to notify the UN Sub-committee of Experts on the Transport of Dangerous Goods to ask whether the Manual should be similarly updated.

The changes affect in particular a number of definitions in 1.2.1, with updated standards referenced against ‘Equipment category’, ‘Equipment protection level’, ‘Electrical apparatus protected against water jets’, ‘Explosion group/subgroup’, ‘Gas detection system’, ‘Oxygen measuring system’, ‘Oxygen meter’, ‘Protective suit’ and ‘Types of protection – electrical equipment’. Those are also reflected in the Table of general transitional provisions in 1.6.7.2.2.2.

One new transitional provision is provided in 1.6.8.3:

Certificates of specific knowledge of ADN referred to in 8.2.2.8 issued before 1 January 2023 and which conform to the format laid down in ISO/IEC 7810:2003 shall remain valid until the expiry date indicated therein.

There are also changes in the Application form for special authorisations in 3.2.4.2 and in the standards referenced in 8.1.6.2, 8.2.2.8.2 and 9.1.0.53.4(f).

Another paper from Germany identified a contradiction between ADN and ES-TRIN regarding fixed fire extinguishing systems, particularly relating to the protection of lithium batteries placed in the vicinity of dangerous goods. After some discussion, it was agreed to amend 9.3.x.40.2.16 (where x is 1, 2 and 3) with the following text:

Permanently installed fire-extinguishing systems for protecting objects (a) Permanently installed fire-extinguishing systems for protecting objects are permitted for the protection of installations and equipment.

The action of the fire-extinguishing systems must be aimed directly at the objects to be protected. The range of action of fireextinguishing systems may be limited in space by means of structural measures.

Permanently installed fire-extinguishing systems for protecting objects may already be structurally integrated into the objects concerned.

Permanently installed fire-extinguishing systems for protecting objects must be independent of the systems referred to in 9.3.x.40.2.2 to 9.3.x.40.2.16 in respect of their supply of extinguishing agent. (b) The following requirements apply to permanently installed fire-extinguishing systems for protecting objects: (i) 9.3.x.40.2.2, if the extinguishing agent used requires the range of action to be limited by structural measures; (ii) 9.3.x.40.2.3 and 9.3.x.40.2.4; (iii) 9.3.x.40.2.5 (b) and (c), in addition to the provisions of (c) of the present section; (iv) 9.3.x.40.2.6, (a) to (e), and at each entrance to a room or in the immediate vicinity of an encapsulated object, a suitable sign for the fire-extinguishing system for physical protection must be prominently displayed; (v) 9.3.x.40.2.7 to 9.3.x.40.2.13; (vi) Reserved; (vii) 9.3.x.40.2.15, (b) to (e).

Only extinguishing agents suitable for extinguishing a fire on or in the object to be protected and which are mentioned in 9.3.x.40.2.1 may be used in permanently installed fire-extinguishing systems for protecting objects.

The competent authority may authorize exemptions concerning the extinguishing agent for permanently installed fire-extinguishing systems for protecting objects which are based on a fire protection concept. (c) Permanently installed fire-extinguishing systems for protecting objects must be capable of being triggered manually. Manual triggering must be possible in the immediate vicinity of the protected object. They may be triggered automatically if the triggering signal is emitted by two fire detectors with different means of detection. The triggering must occur without delay. If the fire-extinguishing system is intended to protect several spaces, it shall comprise a separate and clearly-marked triggering device for each space.

The activation of the fire-extinguishing system shall be displayed in the wheelhouse and at the entrance to the room in which the object to be protected is located. In the case of encapsulated objects, the display at the room entrance can be omitted if another display is attached to the object itself.

For manual activation, operating instructions in accordance with 9.3.x.40.2.5 (e) shall be displayed next to each triggering device, taking into account the location and nature of the object. (d) The type and place of installation of permanently installed fire-extinguishing systems for protecting objects shall be entered in the ship’s certificate. (e) The provisions of this section do not apply to water spray systems in accordance with 9.3.1.28, 9.3.2.28 and 9.3.3.28.

This report on the ADN Safety Committee’s January session will continue in next month’s HCB.