Cross-Acceptance: UNIFE expectations
Alice Polo
Safety and Certification Manager
What is UNIFE ?
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.
 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 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
Common reference for
non-TSI conform
vehicles in Europe
2. The reference
document
Collection of all National
Technical Rules
3. The report on
authorisation process
Overview of today situation
and foster harmonisation
of certification procedures
DV29!
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
Simplification and
transparency of
authorisation processes
URGENT
NEEDS
A quick move towards a true
European wide vehicle
authorisation, on the basis of
the recast Interoperability
Directive 2008/57/EC
Current situation
Today’s authorisation for putting in service a vehicle in Europe
is the final outcome of 3 apparently multiplicative processes:
1.
2.
Assessment of conformity with all relevant TSI’s
Assessment of conformity with the whole set of NNTR
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
Certification/Authorisation process
too 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 Authorisation
in 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
2. Elimination of all
unnecessary NNTR
Notwithstanding the
identification by NSA of possible
new specific cases
3. Automatic extension to the
whole “interoperable network”
of authorisations delivered on
the basis of TSI compliance
All vehicles placed in service in
Europe are never designed only
for TEN operations but also for
off TEN
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
1. Mechanism for authorization of
variation of type
2. Recognition of ISA assessment
between Member States
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
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!