ERA roadmap - XAcc Conference

Report
The Future – the “Roadmap”
SIMPLIFICATION
The Road Map
Interoperability
Open points
Updates
Hi Speed
TSI in
Place
Conv Loc & pass
Off TENS
TSI
Conformity
New Vehicles
Existing Vehicles
Networks
Mutual recognition
Inf Register / Net Statement
Bi & Multilat
XA agrts
The list of
Parameters
The Reference
Document
Mutual Regn
Of Veh Types
2
1996
2001
2004
2010
2014
Recheck
Only against
rules
Relating to
compatibility
with the Networks
~2040
~2080
Simplification – One Process
25 x National Homologation Processes
+
25 x Different Interpretations of the Directive
DV 29 Process
3
Simplification -“Cleaning Up” the rules
Now
Short
term
Requirements
Law by Parliament
National Regulations
Formal Agreements between MS
MOUs
Requirements Issued by Ministries
“Guidelines” issued by Ministries
Requirements Issued by NSAs
“Guidelines” issued by NSAs
Requirements issued by IMs
“Access Conditions” Issued by IMs
Judgement of Independent Safety Assessors
Judgements of NSA Inspectors
Judgement of RU or IM
Project risk assessment
Checks
•NoBo
•Designated body
•National Safety Authority
•Independent Safety Assessor
•“Competent person” specified by NSA
Authorisation
•NSA
•IM
N° 4
Foreseen by
the directive
Long
term
TSI
= All requirements
TSI
National Rules(inc interface to
the network)
•NoBo
One entity
•Designated Body may fill all
•CSM Assessor
Roles
NSAs
NoBo
NSA -1!
Deadline – 12 months from publishing the Ref Doc Decision
Simplification - Transparency
From expert Judgement
(single point of decision)
3rd party verification of conformity
to transparent, repeatable rules
Rule setter
(Ministry on NSA advice)
Judgement of
“wise”
expert in NSA/IM
•Requirements
•Checking method
•Authorisation
(Safety Case)
(“approved” by ISA
based on “judgement”)
Transparency
3rd party
Checking Body
(NoBo or DeBo)
Authorising
Authority (NSA)
5
Simplification – Prevention of “Surprise”
new rules
• Creation of New Rules
• TSI Loc & Pass in place – no need for new national rules – scope
extension is on the way
• Draft national rules must be notified and scrutinised under
Directive 98/34 – up to 12month “standstill”
• Dealing with findings of accidents- “Emergency Rules”
• Safety Directive is clear – Immediate risk must be controlled by
the SMS of the RU – i.e. company procedures
• Errors and omissions in TSIS dealt with by reporting to RISC +
Agency Technical Opinion (one new rule for all)
•
Rules must be permanent (not different for each project)
• Result - No more “surprise” new rules
6
Simplification - Equivalence
• 25 Fire Extinguishers in the cab => 1
• Geographical Interest Groups reviewing
equivalence for All MS
(except Poland, UK, Baltic states)
• For Off -TENs MSs may decide to accept TSIs as
equivalent to national rules
• A logical simplification
• Extra column in Ref Doc to be added
7
Simplification – Visibility of National Rules
• One point of data entry and extraction
• The Agency Website (incl access to NOTIFIT)
• Rules catalogued according to the list of
parameters
• Rules cross referenced with TSIs
• Clarity of what must be notified to be contained
in Application guide to NOTIFIT/Ref Doc
Database
8
Simplification – Type Authorisation
Vehicle authorised in MS A = Type Approved in MS A
Vehicle authorised in MS B
(check of B and C rules relating only to compatibility
with the Network)
= Type authorised in MS B
9
Simplification
• Separation of authorisation from use + type
• Only one authorisation per MS per design
• Authorisation for a network according to
national rules for compatibility/integration with
network.
• Route non-conformities dealt with by Network
Statement /RINF + SMS
10
Anything Missing?
Anything Missing (1)?
• Next Step – check for missing regulatory
simplifications
• Practical definition of Type
• Common understanding of “major” /
“significant” /”substantial”
• How to deal with “platforms”
• Anything else?
12
Anything missing (2)?
• Technical compatibility/Safe Integration vehnetwork
• Consistency (one set?) of parameters need to
used in TSI, Ref Doc, Infrastructure Register
(+ERATV,+Inf TSI)
• Review of risks covered by national rules,
compare with risks covered by TSI
• Anything else?
13
Anything Missing (3)
• Nature of Infrastructure
•
IMs must be maintaining infrastructure to some limits
otherwise vehicles could not be authorised,
compatibility with vehicles could not be maintained
and the IMs would loose their safety authorisations!
• Conclusion – Infrastructure knowledge exists
but is “hidden”
• Agree with EIM – rapid introduction of RINF for compatibility
parameters is necessary
14
Next Steps
• Publish this “road map”
• Opinion Formers (“Big Bosses”) need to know
what is already in the pipeline
• Which of today’s problems are solved by implementation of
the directives
• What is left as open points
• Dissemination of the framework
15
Finally – A Plea for “Big Bosses” and
Associations
• The tools to implement change exist – use them
• Stop writing letters of general complaint
• Start submitting specific complaints to the
Commission where MSs break the law (i.e. do
not comply with the directives / DV29)
• Why ask for more regulation when existing
regulation is not complied with?
16
Anything Else?
Comments and Questions
17

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