News - Railway transport

14.06.2009
Experiences with the authorization offreight wagons as per TSI

The chairman of the UIP Superstructure Committee, Rainer Kogelheide (GATX), reports.

The year 2008 can perhaps be viewed as the year of the first practical experiences for the freight wagon industry with TSI authorization procedures. An opportunity today to sum up these first experiences perhaps under the title ‘Yes, it’s working, BUT’.
The first issue would be TSI Rolling Stock and TSI Noise themselves. Devised very hastily under guidance of the AEIF we could realise early on that they contain lots of mistakes and unresolved (open) points.
Today we are urgently awaiting an ‘intermediate’ revision by summer 2009, and a complete overhaul is planned for the end of 2010. Yet this awareness of deficiencies has not stopped authorities – the ones with responsibility for approvals of placing in service – from referring to the quasi-legal character of the TSI and insistingon satisfaction, even on the part of the technical NoBos. This has meant that wagons have been standing – and perhaps are still standing – ready inthe factories, because discussions are underway about proof of lateral acceleration of 0.4 g, or perhaps a handbrake on a wagon equipped with composition K blocks does not offer the same braking power as one with grey iron blocks. Although other authorities in other EU Member States are adopting a rather pragmatic approach on the same topic, the real legally watertightsolution might not come until a radical revision 9 hopefully in 2010, which will see the 500 or more recognised mistakes rectified, the open points cleared up and also the doors opened to technically urgently needed alternative solutions.
It has also been recognised, albeit at the last minute, that the TSI for freight wagons is lagging clearly behind RIV, and the facility that an authorization for placing in service in one European country is equally valid for all other countries has delivered a certain quick remedy. But this, like TSI as a whole, is effective only on lines of TEN. Without the intermediate additional RIV test and marking, virtually no effective international deployment of such wagons entering service following the TSI would be possible. There is still no clarity as to the rights or duties of the ‘country placing in service’ with reference to their additional national regulatory requirements, above all with regard to maintenance. At present, individual countries impose their own specific requirements, e.g. on the use of particular workshops or testing of air braking systems, which significantly complicate the authorization procedure and then also the use of the wagons Europe-wide. Once you finally have your hands on the longed-for TSI authorization (with the addition ‘RIV’) after running the gauntlet between experts, Notified Bodies and authorities, then other things become clear:
Say a wagon has sustained damage to a wheel set somewhere in Europe – as a well-organised business, you have spares available, perhaps a spare part manufactured to be technically identical, or at least a similar interchangeable wheel set available – but now has it undergone a conformity assessment following the TSI, or has the TSI noise measurement been done? Unfortunately, usually the answer is No, and for wagon keepers who abide by the law, this unavoidably means substantial additional costs, e.g. by carrying duplicate stocks. And all this in spite of the fact that under the RIV rules, components would be freely interchangeable.
This really is a case for transitional provisions which would cover RIV interchangeability of components.

UIP Newsletter

back to top

04.06.2009
Some notes of the meeting of UIP under the heading “European Maintenance System” – Hamburg, 20.03.2009

Certification of the Maintenance Workshops (CMW)

After a ‘tour de table’ establishing the legal situation in Europe, it was decided to ask the UIP members what is the legal situation in each single MS

ISO and ERA CMW: it should be favourable if the same entity certifies against ISO and ERA CMW requirements. An analyzeze comparing ISO and ERA requirements is on-going. Results will be presented during the UIP technical committee.

National requirements: in such a ‘system’ certification, many requirements depend on the national legislation, for example the work conditions. A certification of one or more association (VPI), taking into account the national specificities, should be preferred in a short term.

ERA CMW and ECM: the ERA CMW is strongly linked to the ECM certification. During the ECM workshop, the mandatory application should be thought about. But presently, a voluntary application should be sufficient.

This issue will be put on the agenda of the technical committee before sending UIP position to the Agency

ECM certification

The tasks of the ECM are presented (see annex).

VPI explains an implementation of the MoU in Germany is legally possible because the German Authorities should sign this agreement. But in the practice it seems more difficult. The keeper is indeed defined in the German law and the border of the responsibilities/tasks for checking a wagon between a keeper and a RU/IM is not well defined.

Furthermore, VPI explains that the present document should be adapted for a daily application.

According to AFWP an implementation of the MoU in France is today possible and welcomed.

Even if no mandatory certification will exist before 2011, the MoU presents the interest to able keepers to be prepared because the structure of the certification will be the same (see tasks in presentation).

Presently only some MS signed the MoU. In May, during a NSA/ERA meeting, UIP should have the opportunity to asks NSAs who didn’t signed, which are the other possibilities for an ECM to be recognized.

Maintenance System throughout Europe

AFWP presented an overview of the Maintenance System in a short/middle term (see annex).
AFWP stressed on:

AFWP is on the opinion that the 4 points below could be common at the European level.

VPI explained it isn’t so easy to harmonize the use of European standards because of the existing of some national standards in some national law.

VPI tall their fears to manage a too big working groups responsible for bringing about some changes in the guidelines (laborious work). That’s why VPI proposes to non German speaking associations to put in national annexes the specificities

AFWP explained that the French association is more interested on setting up common maintenance requirements (remind that goal could be achieved in a middle term) than to have their particularities taken into account in the VPI guide. And AFWP understand and fully agrees that the maintenance guidelines is a guide and it’s up to the ECM/keeper to manage the maintenance plan and to take the responsibilities of the application.

Conclusion: VPI proposed that AFWP set up a comparative document between French requirements and VPI guidelines and to discuss between VPI/VAP and AFWP the differences.

back to top