The autumn session of the Joint Meeting of the RID Committee of Experts and WP15, the Working Party on the Transport of Dangerous Goods of the UN Economic Commission for Europe (ECE), was held in Geneva this past 19 to 27 September. The session was chaired for the last time by Claude Pfauvadel (France) with Silvia García Wolfrum (Spain) as vice-chair; she will assume the chair for next year’s sessions as Claude Pfauvadel is soon to retire.
The autumn session was attended by representatives of 22 full member states, as well as a representative from Zimbabwe in a consultative capacity. Also attending were the EU, the European Agency for Railways (ERA) and 14 international non-governmental organisations.
This was the first time since the Covid pandemic that the meeting had been held in-person only and, following difficulties experienced by the UN Sub-committee at its summer session, it was evident that the UN Office had taken steps for streamlining the issuance of identification badges, which will in future be managed by a digital process.
The session was not without its difficulties, however; a number of official documents that had been submitted in French had not been able to translated in time.
The aim of the Joint Meeting is that, by involving experts and regulators from the different modal bodies, harmonisation can be maintained between the three European rulebooks: RID for rail, ADN for inland waterways and ADR for road, though this latter is being applied more widely than just in Europe these days. The Joint Meeting is the primary point of discussion for those amendments deriving from changes in the UN Model Regulations but it also hears proposals from member states and non-governmental organisations with consultative status.
The Joint Meeting is currently well on the way to finalising the amendments that will enter into force in 2025, which reflect the 23rd revised edition of the UN Model Regulations, adopted in December 2022, as well as other changes.
TANKS MATTERS
As is the usual procedure, most of those papers relating to tanks were passed on to the Working Group on Tanks, which met for three days at the start of the session under the chairmanship of Arne Bale (UK). Separately, the Joint Meeting held a discussion on the basis of a paper from the Netherlands, which suggested that the requirements for the carriage of foodstuffs, articles of consumption and animal feeds in tanks that have previously carried dangerous goods are not well defined, with particular reference to 4.3.2.1.6 and special provision TU15 of RID and ADR.
The Joint Meeting Joint Meeting confirmed that such simultaneous or alternated carriage of foodstuffs and animal feeds in tanks, containers and receptacles used for dangerous goods is forbidden in the EU according to Regulation 852/2004. However, RID/ADR/ADN do not forbid the practice in principle, subject to certain restrictions, and it was felt it would be helpful to harmonise these provisions in RID/ADR/ADN. The Netherlands will continue to work on the topic and return with a new proposal.
The Working Group on Tanks began by revisiting its amendment to RID/ADR regarding sight glasses agreed at the previous session but left in square brackets. This will result in 6.8.2.2.11 being revised to read:
Level-gauges shall neither be part of, nor fitted to shells, if they incorporate transparent material which can, at any time, come into direct contact with the substance carried in the shell.
The Working Group on Tanks looked at the relevant parts of the discussions of the Ad Hoc Working Group on the Harmonisation of RID/ADR/ADN with the UN Recommendations on the Transport of Dangerous Goods, which had met in April 2023. A number of the resulting proposals related to the assignment of tank codes in Table A of Chapter 3.2 (the Dangerous Goods List), and it was agreed that:
- For UN 1391 and 3482, the proposed replacement of ‘L10BN(+)’ in column (12) should be ignored and that tank code retained
- For UN 1835, PG II, the proposed replacement of ‘L4BN’ in column (12) should be ignored and that tank code retained
- For UN 3423, the current tank code in column (12), ‘SGAN/L4BN’, is to be replaced by ‘S10AH/L10CH’; new special tank provisions are inserted in column (13): ‘TU14 TU15 TE19 TE21’ for ADR and ‘TU14 TU15 TU38 TE21 TE22’ for RID
- For UN 3553, the new entry for disilane, the proposed tank code ‘PxBN(M)’ was accepted; the special tank provisions are ‘TA4 TT0’ for ADR and ‘TU38 TE22 TA4 TM6’ for RID
- For UN 3560, the new entry for tetramethylammonium hydroxide aqueous solution (TMAH), the proposed tank code ‘L10CH’ was accepted; the special tank provisions are ‘TU 14 TU15 TE19 TE21’ for ADR and ‘TU14 TU15 TU38 TE21 TE22’ for RID.
Two new transitional measures relating to these changes were adopted:
1.6.1.55 Substances assigned to UN No. 1835 or 3560, may be carried until 31 December 2026 in accordance with the classification provisions and transport conditions of RID/ADR/ADN applicable to UN 1835 TETRAMETHYLAMMONIUM HYDROXIDE SOLUTION up to 31 December 2024.
1.6.1.56 Substances assigned to UN No. 3423, may be carried until 31 December 2026 in accordance with the classification provisions and transport conditions of RID/ADR/ADN applicable up to 31 December 2024.
The Working Group on Tanks did not support the inclusion of other proposed transitional provisions relating specifically to the new tank codes.
The Working Group on Tanks also addressed the assignment of two different tank codes for Class 8 corrosives (for ADR, those with classification code CT1); this involved the insertion of additional footnotes in the explanatory table in 4.3.4.1.2, to indicate specific tank codes to be used with hydrofluoric acid and hydrogen difluoride solutions.
The International Union of Railways (UIC) returned an issue left open in 2022, relating to the holding time for empty tank wagons and tank containers that have contained refrigerated liquefied gases. After work in collaboration with the European Industrial Gases Association (EIGA), UIC was now in a position to make a formal proposal, which received general support. It was agreed that the consignor is responsible for offering the empty uncleaned tank wagons and tank containers in a condition that the pressure relief devices are not activated during carriage.
It was agreed to amend 4.3.3.5 by adding a new sentence at the end:
The requirements of 4.3.3.5 need not be complied with for empty, uncleaned tanks/tank-containers.
In addition, in 4.3.3.6, “and for refrigerated liquefied gases:” is added after sub-paragraph (d) and a new sub-paragraph (h) is added at the end:
When empty, uncleaned, unless the pressure has been reduced to a level that ensures that the pressure relief devices will not activate during carriage4
The Netherlands had identified what it felt was an error. The last paragraph of 1.8.6.2.1 had been introduced to exempt competent authorities from having accreditation while the requirement of 1.8.6.3 applies. However, the last sentence of 1.8.6.3.1 requires the inspection body to “additionally be accredited according to the standard EN ISO/IEC 17020:2012…”, which means that those competent authorities performing inspections must still be accredited.
Discussion revealed that this is not the only conflict between 1.8.6.2.1 and 1.8.6.3.1; however, a proposed solution offered by the Working Group on Tanks did not find favour with the Joint Meeting and further clarification is needed.
The Netherlands also queried the applicability of EN 12252 in the table in 6.8.2.6.1 of ADR, where reference is made to 6.8.3.2 on items of equipment. However, 6.8.3.2 seems to suggest that 6.8.2.2 is not applicable, which is not the case. Clarification is therefore needed. There was support for the case presented but the proposal to add a note might, it was felt, set an unfortunate precedent and lead to a plethora of explanatory text.
The Working Group on Tanks suggested adding a new note after the heading of 6.8.3 to make it clear that the special requirements of that section supplement of modify the requirements of section 6.8.2; plenary did not support this, pointing out that such text already exists in 6.8.1.3. The Joint Meeting did, though agree to insert ‘6.8.2.2’ before ‘6.8.2.3’ in column 3 of the table in 6.8.2.6.1 against EN 12252:2005 + A1:2008 and EN 12252:2014.
Another brief paper from the Netherlands addressed the obligations of in-house inspection services, which are more limited than those of the competent authorities and accredited inspection bodies but are not, it felt, well defined. Its paper proposed a new 1.8.6.4 in RID/ADR to deal with the omission.
While the Working Group on Tanks could see the logic behind the proposal, it felt the solution offered was over-elaborate. A simpler solution, which was adopted by plenary, was to add ‘authorization and’ before ‘surveillance’ in 1.8.6.1 and in the title of 1.8.7.7.
In passing, it was also noticed that 1.8.8.6 contains an outdated reference to 1.8.7.7.1(d); this has been changed and will in the 2025 editions read ‘1.8.7.7.1(b)(ii)’.
Belgium reported that, during inspections of tank wagons carrying gases of Class 2, the maximum allowed working pressure (MAWP) is often not present on the corrosion-resistant plate or the tank shell. On investigation, it seems that industry has found various reasons for not doing so, not least since the MAWP for compressed gases varies according to the partial pressure of the product and the operating temperature. Belgium felt there is clearly some confusion in the different provisions in Chapters 6.7 and 6.8 and offered some proposals to clarify the requirements.
The Working Group agreed that Chapter 6.8 is consistent and that tanks for compressed, liquefied or dissolved gases did not require marking of a maximum working pressure on the tank plate. It addressed this by adding the words ‘(for Class 2 see 6.8.3.5)’ at the end of the last sentence of 6.8.2.5.1.
It was also noticed that while Chapters 4.3 and 6.8 use the term ‘maximum working pressure’, in 4.3.3.4 it appears twice as ‘maximum allowable working pressure’. As a result, the word ‘allowable’ is deleted on both occasions.
Belgium was also concerned that an error had crept into the 2023 editions of ADR and RID, with an inconsistency in the application of type examinations and initial inspections between the two documents. This is of particular concern to tank containers, which move intermodally. Specifically, in 6.8.1.5.1 of ADR, a note requires that tank containers are inspected by an inspection body approved or recognised by the country of registration; this is missing in RID.
Most experts were in favour of deleting this note in ADR, though no consensus could be reached since there were a number who were in favour of adding it to RID. The Working Group referred the matter to plenary, which noted that the provision in ADR is only applicable to tank containers that are permanently used in road transport; it invited WP15 to consider the matter at its session in November 2023.
France had identified a problem resulting from the terminology used in relation to the information required to appear on a plate (often referred to as the ‘manufacturer’s plate) attached to the tank, as required by 6.8.2.5.1 of RID/ADR. It is common practice, particularly in rail transport, to display this additional information on side panels. In the French versions of RID/ADR (and the German and Russian versions, it was said), two different terms are used – ‘plaque’ and ‘panneau’. The English versions use ‘plate’ in both cases and this, France said, has led to different interpretations.
France offered a simple solution, which was rapidly adopted. In the English text in 6.8.2.5.2 and 6.8.3.5.6, ‘(on the tank itself or on plates)’ is amended to read ‘(on the tank itself or on panels)’. This was agreed by plenary.
Another paper from France sought amendment of 4.3.4.2.1, which requires the surface temperature of tanks carrying substances at elevated temperature to be no higher than 70°C, to prevent burns when the tank is touched. However, openings and closures cannot always be insulated to comply with this provision and, in any case, are located where they cannot easily be touched. France offered an amendment, which was adopted so that rather referring simply to the ‘outer surface of the tank’, 4.3.4.2.1 should read:
Where hot substances are loaded, the temperature of the outer surface of the shell, excluding openings and their closures, or of the thermal insulation shall not exceed 70°C during carriage.
An informal document from France picked up on the change to the title of 6.8.2.6.2, which means that reference to EN 12972:2018 is no longer appropriate in 6.8.2.6.1. This is now deleted. Also, in 6.8.2.6.2, reference to 6.8.2.3 is added in column 3 in the row for EN 12972:2018.
Germany spotted that, when the new entry for UN 3550 Cobalt dihydroxide powder was added in the 2023 editions of RID and ADR, it was assigned tank codes S10AH and L10CH, in accordance with the rationalised approach. This indicates that the substance may be offered for carriage in a liquid (i.e. molten) state. However, research shows that cobalt dihydroxide has no melting point – in fact it decomposes at around 160°C prior to melting – so it is not possible to offer the substance for carriage in the molten state.
The Working Group on Tanks agreed, deleting the tank code L10CH from column (12) of Table A of Chapter 3.2 against UN 3550. In addition, special tank provisions TU14 and TE21 (ADR) and TU14, TU38, TE21 and TE22 (RID) were also deleted from column (13). The Joint Meeting asked the European Chemical Industry Council (Cefic) to check if any transitional measure were needed.
OUT FOR DISCUSSION
While the topics listed above all involved proposals for specific amendments for the 2025 editions of the regulations, the Working Group on Tanks also held some more general discussions.
EIGA and the European Cylinder Makers’ Association (ECMA) said that, having referenced EN ISO 23826:2021 in RID and ADR (especially in 6.8.3.6), the use of ball valves for battery vehicles/wagons and multiple-element gas containers (MEGCs) is now permitted. However, this standard is not explicitly referenced in EN 13807:2017 and, for clarity, it would be desirable to add a note to the table in 6.8.3.6 to highlight the permission to use ball valves. France had a similar issue, with the additional thought that 1.1.5 applies in this case. The European Committee for Standardisation (CEN) reported that EN 13807 is due for revision, likely after RID/ADR 2015 enter into force.
The Joint Meeting confirmed that ball valves meeting the provisions of EN ISO 23826 may be fitted on battery wagons/vehicles or MEGCs.
At its spring session, the Working Group on Tanks had discussed the difficulties presented by the dual approval of tanks (portable tanks and tank containers) under Chapters 6.7 and 6.8 and most experts expressed a preference for forbidding dual approval, albeit there are advantages for users. France now made a proposal to eliminate the possibility of dual approval, with a limited transitional provision extending existing dual approvals to the next periodic or intermediate inspection before 1 July 2027.
The proposal was strongly rebutted by the International Tank Container Organisation (ITCO), which pointed out that UN portable tanks with RID/ADR 6.8 approval have been successfully operated by industry for many years without incident; indeed, this was standard practice even before the introduction of UN portable tanks, when ‘IMO tanks’ were dual approved. ITCO also said that the need for removing or restricting dual approval has not been properly justified, with no detailed evidence of need being provided. The cost to industry of any change could be immense.
EIGA was not against the idea in principle but did point out that some countries, ports or terminals would not accept 6.7 portable tanks unless they are also approved as 6.8 tank containers. The Working Group was surprised at this, as it was the intention that 6.7 portable tanks should be able to be carried by all modes of transport and filled or emptied in any RID/ADR/ADN contracting party/state.
Overall, there was support within the Working Group to remove dual approval but it was felt that there should be a better understanding of the consequences before and such change is made. ITCO offered to organise an intersessional meeting.
Germany came with a query about a unique design of aircraft refuelling vehicle, designed to be operated also outside the airfield, comprising a box-shaped tank with a reduced shell thickness, with three compartments of a maximum 15,000 litres capacity. Each compartment is filled or emptied via a single bottom valve in the middle compartment, with stop-valves between the three compartments open; during off-site transport, these stop-valves are hermetically closed. This design was brought to it for approval in accordance with Chapter 6.8 of ADR.
Germany was of the opinion that operation with openable partitions is not described in ADR nor in the relevant standards, such as EN 14564:2019. In addition, according to 1.4.3.3(f), the filler shall ensure that all closures are closed after filling and there is no leakage; this is impossible in the case described. Moreover, while the vehicle is moving by road, it is a three-compartment tank but during filling and emptying it is effectively a single-compartment tank. How does this fit with ADR?
The Working Group on Tanks decided that, since only one type of fuel can be carried, leakage between the compartments does not pose a safety issue. However, as the use of openable partitions is not defined in the regulations or in standards, the design could not be considered acceptable as an ADR tank.
Germany also queried the use of water chambers on vacuum-operated waste tanks as, during work on EN 14025, issues regarding legal compliance have arisen. Such waste tanks have been optionally fitted with water chambers for many years in Germany – and in other countries – so as to have water available in the case of an accident for cleaning and rinsing. So far, no incidents related to the operation of the water chamber, which is not pressurised, have been reported. Germany illustrated three options for the external and internal arrangement of the water chamber. The Working Group on Tanks agreed that all three arrangements comply with ADR.
The Netherlands provided some information on the intersessional discussions on the holding time of tanks, with particular emphasis on those used for the transport of refrigerated liquefied gases. While, in an ideal world, the calculation of the holding time is preferable, in real-life situations this proves very difficult to perform due to the number of variables. A number of potential ways forward were suggested. The Working Group on Tanks welcomed the documents, valuing their contribution to the debate, but it is clear that more work is needed.
France recalled that the 2023 editions of RID/ADR include an amendment that reflects discussions relating to the use of tanks whose inspection period has expired, which led to a new provision in 4.3.2.3.7. The question has now arisen: what type of inspection should be carried out if the due date for an intermediate inspection has passed? France’s opinion is that this should be an intermediate inspection, unless the date for the next periodic inspection is approaching, but it is aware that other countries are systematically requiring a periodic inspection.
The Working Group on Tanks confirmed that, following earlier discussions, it had been agreed that an intermediate inspection is sufficient in these cases. The International Union of Wagon Keepers (UIP) offered to present a formal proposal for clarification at the next session.
Poland referred to 6.8.2.5.1 of RID/ADR, which requires that the date and type of the most recent inspection is marked on the tank plate, with the date showing the month and year in the format ‘mm/yyyy’. However, it said, in practice this is not fully observed and the year is often shown with two digits, e.g. 03/23 rather than 03/2023. Poland suggested wording should be introduced to avoid any variation.
The Working Group on Tanks was of the opinion that 6.8.2.5.1 does not specify the format for the date (the English version of ADR certainly does not) and that, in any case, ‘03/23’ and ‘03/2023’ are equally understandable. Furthermore, in many cases there is limited space available on the tank plate and the shorter version is easier to position. It was decided not to regulate on the matter and leave the option of two or four digits for the year.
Another informal document from Poland sought advice on how to implement the requirement in EN 12972, point 5.8.3 on the leakproofness test pressure, which states that “Internal leakproofness of shut-off devices shall be tested at the leakproofness test pressure as well as at a pressure of not more than 0.2 bar”. This seems to contradict the provision in 6.8.2.4.3 of RID/ADR that the pressure of the leakproofness test, whether for liquids or gases, shall not be lower than 0.2 bar.
The Working Group explained that the whole of 5.8.3 has to be considered and the provision highlighted by Poland refers to an additional test if shut-off devices are tested separately from the tank. It was suggested that the wording of 5.8.3 could be improved but no amendment to RID/ADR is required.
France sought the Working Group’s opinion on another apparent contradiction, this involving the maximum working pressure of tanks with the L4BH code. According to 6.8.2.1.14(d), tanks for the carriage of substances with a boiling point of not more than 35°C shall be designed for a calculation pressure not less than 4 bar; as per 6.8.2.2.8, this means the safety valve shall be set at not less than 3 bar, which would also be the maximum working pressure. In light of this, is it possible to approve L4BH tanks with a maximum working pressure of less than 3 bar?
The Working Group confirmed that tank vehicles are permitted to have tank code L4BH and a working pressure of less than 3 bar, though in such cases some competent authorities – though not all – impose a restrictive list of substances permitted to be carried. More discussion is needed on this point, though there was insufficient time to deal with it at the autumn meeting.
SETTING STANDARDS
CEN provided its usual update on its work to develop new or revised standards of relevance to RID/ADR/ADN. The Working Group on Standards has been advised that work is to start on an amendment to EN ISO 17871:2020 Gas cylinders – Quick-release cylinder valves – Specification and type testing.
The Working Group on Standards has also reviewed several standards that are open for public enquiry, assessing them all as suitable for inclusion in RID/ADR. These are:
EN ISO 18119:2018/prA2 Gas cylinders – Seamless steel and seamless aluminium alloy gas cylinders and tubes – Periodic inspection and testing
EN ISO 10297 Gas cylinders – Cylinder valves – Specification and type testing
prEN 17339 Transportable gas cylinders – Fully wrapped carbon composite cylinders and tubes for hydrogen
There are several other new and revised standards that have been submitted for formal vote or that have already been published. Again these have already been assessed as suitable for inclusion in RID/ADR:
EN ISO 11623:2023 Gas cylinders – Composite cylinders and tubes – Periodic inspection and testing
FprEN 14129 LPG equipment and accessories – Pressure relief valves for LPG pressure vessels
EN 14432:2023 Tanks for the transport of dangerous goods – Tank equipment for the transport of liquid chemicals and liquefied gases – Product discharge and air inlet valves
EN 14334:2023 LPG equipment and accessories – Inspection and testing of LPG road tankers
EN 14433:2023 Tanks for the transport of dangerous goods – Tank equipment for the transport of liquid chemicals and liquefied gases – Foot valves
FprEN 14025 Tanks for the transport of dangerous goods – Metallic pressure tanks – Design and construction
FprEN ISO 21011 Cryogenic vessels – Valves for cryogenic service.
The Joint Meeting adopted references to the new EN ISO 20111 in 6.2.4.1 and 6.8.2.6.1, and to the updated EN ISO 11623:2023 in 6.2.4.2 and EN 14334:2023 in 6.8.2.6.2.
CEN also supplied an updated list of the latest versions of standards to be cited in RID. CEN volunteered to submit an official document with an updated list of standards to be referenced in RID/ADR, for consideration and adoption at the next session in March 2024.
The second part of this two-part report on the autumn 2023 session of the Joint Meeting, which will appear in next month’s HCB, will cover more work on the harmonisation of RID/ADR/ADN with the UN Model Regulations, miscellaneous proposals for amendment, reports from other working groups and other business.
