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Upcoming amendments to RID
ALL TANKED OUT
RAIL • THE RID STANDING WORKING GROUP’S LATEST SESSION WAS DOMINATED BY TANK WAGON AND TANK CONTAINER ISSUES, ESPECIALLY RELATING TO EXTRA-LARGE TANKS
THE RID COMMITTEE of Experts’ Standing Working Group (SWG) held its 12th session by video conference this past 24 to 26 November. As is usual, it was chaired by Caroline Bailleux (Belgium) with Othmar Krammer as deputy chairman. The online session was attended by representatives of 20 contracting states, together with Russia (which does not apply RID), the European Commission, the EU Agency for Railways (ERA) and five non-governmental organisations.
With the 2021 text of RID, the regulations that govern the transport of dangerous goods by rail in most of Europe, having been finalised earlier, the Standing Working Group began the task of developing and agreeing the amendments that will appear in the 2023 edition.
APPROVAL AND VERIFICATION The meeting began with what seemed a fairly straightforward issue raised in a paper from the International Union of Wagon Keepers (UIP), seeking the SWG’s opinion as to whether a tank wagon’s initial inspection certificate must be available for the tank wagon to receive approval, or whether the information on the tank plate and an appropriate photographic likeness are sufficient. UIP said it has found that initial inspection certificates are often available only weeks after a tank wagon has been inspected, which can lead to costly delays in releasing new tank wagons for operation.
While some states supported UIP’s position, saying it reflects current practice, the European Commission pointed out that ERA is responsible for wagon approval, which can only be granted once all the necessary official documents are available. If this were to be relaxed in the case of tank wagons, it would also have to be allowed for other wagons and components. The chair felt that the inspection bodies should be engaged in a dialogue and urged to improve their performance.
Discussion then turned to the ongoing deliberations of the RID/ADR/ADN Joint Meeting’s informal working group on the inspection and certification of tanks in respect of entry into service verification (EISV) of tank wagons. This had delivered a proposed text for 6.8.1.5.5 in RID, which SWG felt was adequate to allay its concerns. The underlying problem is that the provision was developed in response to issues experienced with road tankers entering service but has been expanded into a multimodal provision that does not sit comfortably with rail tank wagons
DEVELOPMENT OF EXTRA-LARGE TANK CONTAINERS
HAS GIVEN THE RAIL EXPERTS SOMETHING OF
A HEADACHE, TRYING TO FIT THEM INTO THE EXISTING
nor with multimodal tank containers. Furthermore, RID has to take account of the fact that not all contracting states are EU members and, therefore, the underlying legislation is not the same for every country.
Several ways were offered to get around these potential conflicts, including additional text for the footnote to 1.8.7.5.3 and an amendment to the note to 6.8.1.5.5. Provisional agreement was reached and those changes have been placed in square brackets pending confirmation and further discussion by the informal working group. As a result, SWG agreed that an optional EISV no longer conflicts with European railway legislation. The chair asked that the outcome of discussions by SWG should be transmitted to the chair of the informal working group.
NEW PROPOSALS The Secretariat of the Intergovernmental Organisation for International Carriage by Rail (OTIF), RID’s parent body, asked for SWG’s opinion of the various language versions of the new provisions on the fixing of welded elements in 6.8.2.2.1. This was supported by a comparative document provided by Belgium and a proposal from UIP to align the text for tank wagons with that adopted for tank containers and tank vehicles. UIP also noted that the EN 14025 standard is currently under revision and the new version, scheduled for publication in 2023, will address the question of the fixing of welded elements.
It was agreed that the text should be amended to align with that for tank vehicles and tank containers, so the paragraph will begin “Welded elements shall be attached to the shell in such a way that tearing of the shell is prevented”. This establishes the aim of the requirement, without being overly prescriptive. Once the measures described in 6.8.2.2.1 are reflected in the revised version of EN 14025, they can be deleted from RID.
The Secretariat also followed up on discussions at the September 2020 Joint Meeting, where it was decided to delete the requirement in 4.3.3.3.2 that the information shown on tank vehicles, battery vehicles, multiple-element gas containers (MEGC) and tank containers should be limited to the gas loaded or just discharged, and that information concerning other gases must be covered up.
Belgium proposed that for tank wagons and battery wagons, the current folding panels used to show the name of the gas loaded and the load limits should be retained. Germany and Italy agreed, though they felt 4.3.3.3.2 should be amended. UIP, conversely, felt that all the information could be displayed for several gases in one or more load limit panels and/or on adhesive sheets.
Without agreement being reached, UIP was asked to submit a new document for the next session, taking into account the comments made and also questioning whether the existing system really needed to be changed.
The Netherlands and UIP returned to a discussion on dry break couplings that had taken place back in 2013, but had not delivered any amendments, bringing a proposal to add a footnote in 6.8.2.2.2 to confirm that, for such couplings, an ‘open/closed’ indicator is not necessary. The International Union of Railways (UIC) supported the idea in principle but offered a revised text. The Netherlands and UIP were asked to come back with a revised proposal, taking account of UIC’s comments and others made by various delegations.
Noting that substances that require temperature control are not accepted for carriage by rail as per 2.2.41.2.3, Germany felt that some clarity was needed over the situation as regards the new collective entries for polymerising substances (UN 3533 and 3534), as these can be stabilised either chemically or by temperature control. Its paper offered a clarification, adding reference to the self-accelerating polymerisation temperature (SAPT) using the model already in place for reference to the self-accelerating decomposition temperature (SADT) for self-reactive substances.
GERMANY TAKES A LEADING ROLE IN THE
DISCUSSIONS SURROUNDING THE TRANSPORT
The UK supported the idea but also proposed to include these criteria for polymerising substances of Classes 2, 3, 6.1 and 8. There was support for this idea by SWG, which amended the last indent of 2.2.41.2.3 to read: – polymerizing substances in packagings or IBCs with an SAPT ≤ 50 °C and polymerizing substances in tanks with an SAPT ≤ 45 °C, therefore requiring temperature control:
UN 3533 POLYMERIZING SUBSTANCE, SOLID, TEMPERATURE CONTROLLED, N.O.S.
UN 3534 POLYMERIZING SUBSTANCE, LIQUID, TEMPERATURE CONTROLLED, N.O.S. In addition, the following text is added at the end of 2.2.2.2.1, 2.2.3.2.2, 2.2.61.2.1 and 2.2.8.2.1: If temperature control is required to prevent polymerization of a substance (i.e. for a substance in a packaging or IBC with an SAPT of 50 °C or less, or in a tank with an SAPT of 45 °C or less) the substance shall not be accepted for carriage.
The UK also proposed a consequential amendment in 1.1.4.4.1, which applies to piggyback transport. SWG liked the idea but not the approach and instead adopted a new indent to be inserted after the third indent in 1.1.4.4.1: – polymerizing substances of classes 1 to 8 in packagings or IBCs with an SAPT ≤ 50°C and polymerizing substances in tanks with an SAPT ≤ 45 °C, therefore requiring temperature control.
The Secretariat provided a paper summarising the most important discussions at the November session of the Working Party on the Transport of Dangerous Goods (WP15), SWG’s counterpart for road transport. SWG adopted two of the amendments made by WP15, including a clarification in the transitional provision in 1.6.4.55, which now refers to 6.8.3.4.6 (b) rather than 6.8.3.4.6 in its entirety, and the addition of a new row in 1.1.3.6.3 in the entry for transport category 2 for Class 6.2, UN 3291.
Spain explained that it had drafted a multilateral special agreement under ADR to allow low specific activity LSA-III radioactive material to be spared the requirement for the immersion test in 2.2.7.2.3.1.4. If SWG wishes to follow the same route for RID, another state will have to initiate the agreement, as the material is not carried by rail in Spain.
The Secretariat also provided a corrigendum to the 2021 text of RID, which it was asked to post on the OTIF website. In the English language edition, there are some updated references to the IAEA Regulations for the Safe Transport of Radioactive Material, and corrections to the references in 5.4.1.1.11, where “6.7.2.19.6(b)” should read “6.7.2.19.6.1(b)” and the same applies to “6.7.3.15.6(b)” and “6.7.4.14.6(b)”.
UIC confirmed that the new edition of IRS 40471-3, which is referenced in 1.4.2.2.1 of RID, will contain no changes in point 5, which details the checks to be carried out for consignments of dangerous goods.
TANK AND VEHICLE TECHNOLOGY The chair of the working group on tank and vehicle technology, UIP’s Rainer Kogelheide, presented a report of its 18th session, which took place as a video conference on 6 and 7 October. Much of the meeting was taken up with discussion of the new breed of extralarge tank containers developed by BASF, initially for in-plant use at its Ludwigshafen site. These tanks will, however, need to move by road for repair and maintenance purposes, though they will have to do so empty as they will be too heavy for road regulations, and they have been approved for movement by sea.
THERE WAS DISAGREEMENT OVER THE INFORMATION
Germany presented the preliminary results of a risk assessment carried out by its competent authority on behalf of BASF, which is ongoing and will also involve the expertise of the German Centre for Rail Transport Research (DZSF). There was some disagreement about the work, especially as BASF has already undertaken a risk assessment and that the scope of the work seems to be spreading, though Germany stressed that a number of documents had not been provided.
Germany also asked whether it would be appropriate to introduce a new definition for extra-large tank containers, especially as operational experience is limited to tank containers with a maximum capacity of 40,000 litres. It was pointed out that extralarge tank containers have already gained approval as intermodal tank containers, although those approved in accordance with the International Maritime Dangerous Goods (IMDG) Code must have thicker walls (4.5 mm plus corrosion allowance). The chair noted that, since these tank containers will be used intermodally, any new definition would have to be discussed by the RID/ADR/ADN Joint Meeting and/or its working group on tanks.
The shell wall thickness of extra-large tank containers also came into question. In 6.8.2.1.18, RID prescribes a minimum shell thickness of 4.5 mm for tank wagons and 3.0 mm for tank containers; those extra-large L4BH tanks manufactured by Van Hool have a wall thickness of 3.4 mm and those made by Magyar have a wall thickness of 4.5 mm. The chair of the working group asked whether it was felt that, given the design of extra-large tank containers, they should align with tank containers or, because of their comparable size, with tank wagons.
Both Germany and UIP felt it premature to reduce the thickness requirement for extra-large tank containers, though Austria thought they should be considered together with their carrying wagons and others said that both the extra-large tanks and their carrying wagons had undergone the necessary tests. France pointed out that extra-large tank containers cannot be equated with tank wagons purely on the basis of their size, and their construction leads to completely different stresses in operation. No clear consensus was achieved and research is continuing via DZSF’s investigations. The Joint Meeting will also be involved.
Discussion moved on to the need for energy absorption elements and protection against overriding in the case of extra-large tank containers being moved by rail. It was noted that, when special provisions TE22 and TE25 were included in RID for tank wagons, it was decided not to apply them to tank containers due to their smaller size and different construction. But do extra-large tank containers present a different risk that warrants their application?
Some felt that, if that were so, it should apply to all tank containers, though it was also pointed out that tank containers do not necessary carry products subject to the provisions of RID. Overall, it was felt that some special provisions should be applied, at least for the carriage of very dangerous substances. However, it was not possible to draw the matter to a conclusion and it will be left on the agenda for the next session of the working group.
Very similar discussions took place around the issue of the pressure resistance of manlids on tank containers, started by a proposal from the Joint Meeting’s working group on tanks to require 4-bar manlids to be fitted only on tank containers with a capacity of more than 40,000 litres. This would help prevent spray escaping from dome covers as a result of liquid surge, which does not appear to be a problem with conventional tank containers. Germany proposed that this should not apply to tanks fitted with surge plates. Others felt the 40,000-litre cut-off was arbitrary.
SWG felt it appropriate to adopt a new text in 6.8.2.2.4, relating to tank containers with a capacity of more than 40,000 litres and not divided by surge plates. This remains to be finalised, however. It was also felt that the matter may need to go to the UN Subcommittee of Experts if it were the intention that it apply also to portable tanks.
It was also proposed that the provisions of 4.3.2.2.4, which requires tank containers to be either more than 80 per cent or less than 20 per cent full to avoid dangerous surge movements, be dispensed with for rail transport; this proposal followed testing of extra-large tank containers. There is a problem with this proposal, insofar as tank containers are also designed to move by road. Further coordination is expected and the proposal may return at a forthcoming session.
It was agreed that the acceleration values used in 6.8.2.1.2 and 6.7.2.2.12 are not sufficient for extra-large tank containers. After discussion by the working
group, Germany and UIP will continue work with the aim of drawing up a proposal for the next session.
Similarly, UIC is progressing work on the design of a new mark for carrying wagons fitted with reinforced spigots, which are necessary for the carriage of extra-large tank containers. UIP, meanwhile, is looking at issues in the implementation of the requirements against the over-riding of buffers included in special provisions TE22 and TE25, coming up with a risk-based approach that would apply equally to tank containers and tank wagons. SWG supported the idea in principle, offering some pointers for improving the text.
RID/SMGS HARMONISATION Russia submitted a proposal to align the nominal shell thickness of tank wagons in 4.3.2.3.1 of RID with that in 6.8.2.1.18 of Annex 2 to the Agreement on International Goods Transport by Rail (SMGS). It was felt that the approach used in SMGS provides for unambiguous interpretation, would make it clearer for designers and would increase the service life of tank wagons.
SWG welcomed the proposal but it was felt that the provisions in RID already provide a performance-oriented approach that has shown to be effective in practice. It might be better if the other provisions in SMGS were to be addressed as part of the EN 14025 standard. Germany and UIP offered to take up the issue during the current revision of EN 14025.
Meanwhile, as the proposal was also of relevance to ADR, Russia was asked to submit a revised proposal to the Joint Meeting.
INFORMATION FROM ERA ERA informed the standing working group about the progress being made with the Common Safety Methods for Assessing the Safety Level and the Safety Performance of railway operators (CSM ASLP) at national
and EU level; this will need to interface with occurrence reporting under ADR. ERA’s draft recommendations were due to be issued for formal consultation on 17 December, with comments due in by 17 March.
ERA explained that the reporting model under CSM ASLP has been so designed as to fully align with that already employed under RID, involving an initial simple report to be followed, where necessary, by a detailed report within two months and a report on the occurrence scenario.
Operators and authorities – including competent authorities for the transport of dangerous goods – will be entitled to access relevant information. CSM ASLP also includes rules for the sharing of data, in accordance with the applicable legislation, and recommends the establishment of an Information Sharing System to control the way the data is shared. It will also set up a Group of Analysts, whose role will be to propose safety-related improvements to the EU rail system, on the basis of the information and data shared through the system.
ERA also reported on the work being done on derailment prevention and detection, as prompted by the European Commission’s request set out in the revised Technical Specifications of Interoperability (TSI). A working group is due to issue its final report and proposals by September 2021 following three meetings during 2020. It has already prepared draft requirements to be included in the freight wagon TSI, including three optional sets of requirements on derailment prevention, derailment detection, and derailment detection and actuation. These may have an impact on the development of digital automatic couplings.
It was also noted that the application guide for the freight wagon TSI should refer to 6.8.2.1.2 of RID, in terms of wagon strength. Germany felt that perhaps it would be better for this to be taken out of RID and made into a standalone guide, although ERA explained that this could only provide an interim solution. Belgium offered some additional text, although this will need to be made in a formal presentation, while UIP was of the view that the application guide should also mention the requirements of special provisions TE22 and TE25.
SOME ALIGNMENT IS NECESSARY BETWEEN RID
AND ANNEX 2 OF SMGS, WHICH APPLIES IN RUSSIA
AND OTHER FORMER EASTERN BLOC STATES The 13th session of the RID Committee of Experts’ standing working group is due to be held from 22 to 26 November 2021.
