Cross-Acceptance: UNIFE expectations

Alice Polo

Safety and Certification Manager

What is UNIFE ?

Full members: 70 of the largest and medium-sized companies in the rail supply sector

Associated members: 18 National Associations, representing almost 1,000 suppliers of railway equipment

UNIFE represents the European rail supply industry

Based in Brussels since 1992, 22 permanent employees

A trusted partner of the European institutions in all matters related to rail and transport

UNIFE members have an 80% market share in Europe and supply more than 50% of the worldwide production of rail equipment and services.

UNIFE Members

70 Full Members 15 National Associations

Introduction

Overview of UNIFE presentation:

1. Current situation

2. Major problems

3. European manufacturers needs

4. Expectations

X-A activities

UNIFE welcomes very much the activities realised so far by ERA in the framework of Cross-Acceptance, in particular:

1. The New annex VII of Interoperability Directive

2. The reference document

3. The report on authorisation process

Common reference for non-TSI conform vehicles in Europe

Collection of all National Technical Rules

Overview of today situationand foster harmonisation of certification procedures

DV29!

Good Starting point

BUT

Authorisation Process

Strong need for a quick fix of the difficulties still applicable to the authorisation process (cost and time)

Authorisation process is seen by UNIFE as the most urgent problem to be solved for the interoperability and the competitiveness of the European rail system

The railway sector simply cannot afford being subject to differing national interpretations of European rules nor months-long delays before being able to introduce appeals

UNIFE needs

URGENTNEEDS

Simplification and transparency of authorisation processes

A quick move towards a true European wide vehicle authorisation, on the basis of the recast Interoperability Directive 2008/57/EC

3. Comprehensive risk analysis of the change brought by the introduction of the new vehicle, notwithstanding the

compliance of it with all relevant TSI’s and Notified National Technical Rules

2. Assessment of conformity with the whole set of NNTR

Current situation

Today’s authorisation for putting in service a vehicle in Europe is the final outcome of 3 apparently multiplicative processes:

1. Assessment of conformity with all relevant TSI’s

Certification/Authorisation processtoo much time and cost consuming (1 to 5 Million Euros)

Authorisation and CSM

Next steps toward the solution is the transposition of ID according to DV29, but the application of CSM shall be further clarified!

ERA X-A should:

1. Investigate in detail the way in which CSM on risk assessment are understood and applied by the main European National Safety Authorities for the authorisation of new vehicles

2. Map the hazards covered by the conformity to all published TSI or NNTR, which by definition should not be subject to any additional risk assessment

First Type Authorisation

1. Extension of the geographical scope

of the TSIs

2. Authorisation for TEN also validd off TEN

Further Authorisationin other EU countries

Platform authorisation

UNIFE requests

1. Immediate extension of scope of the rolling stock TSI’s

The related works can only lead to the identification of a few additional specific cases or operation cases justifying partial possible relaxations of the requirements

Notwithstanding the identification by NSA of possible new specific cases

All vehicles placed in service in Europe are never designed only for TEN operations but also for off TEN

3. Automatic extension to the whole “interoperable network” of authorisations delivered on the basis of TSI compliance

2. Elimination of all unnecessary NNTR

TSI and NNTRs

Reference list is the tool for the comparison of NNTR and TSI requirements

Thanks ERA for the very good achievement in collecting all the NNTRs! This is the starting point for:

1. Systematic use of TSI requirements in place of the National Notified Technical Rules, each time they cover the same parameter or hazard

2. Elimination of all unnecessarily National Technical Rules: reduce the number of National Rules to duly identified national specific cases

Insufficiencies of the notion of type authorisation

Type Authorisation(in ID)

Only concerns authorisations for fleets of strictly identical vehicles, having to cross borders on a European international corridor

Need for a real European authorisation for rolling stock, including ERTMS onboard equipment

A European-wide type authorisation should be delivered at the outcome of the first authorisation of a vehicle type by one NSA

Platform authorisation

To solve the problem of furhter authorisations in EU country:

Platform Authorisation

This would drastically simplify the authorisation of a vehicle in a 2nd member state, when another vehicle based on the same technical “platform” has already been authorised in a 1st member state

ERATV should support the traceability between different versions, i.e. platform evolutions

1. Mechanism for authorization of variation of type

2. Recognition of ISA assessment between Member States

Conclusions

UNIFE has high expectations from X-A unit in supporting and work for the achievements of the following points:

1. Clarify the correlation between TSI and CSM

2. Systematic use of TSI requirements in place of the NNTR, each time they cover the same parameter or hazard

3. Elimination of all unnecessarily NNTRs and reduction to duly identified national specific cases

4. Immediate extension of already delivered TEN authorisation

5. Recommendation for Platform Authorisation

Thank you for your attention!