Reminder to implement the European intermediate solution to demonstrate responsibility for the maintenance of freight wagons

The European railway sector has already committed to enforce the Entity in Charge of Maintenance (ECM) policy, laid down by the EU Railway Safety Directive, from 1 January 20111. This means all freight wagons must have an ECM assigned to them.
Freight wagon keepers2 confirm by way of a Keeper’s Self-Declaration that they have assigned an ECM to all freight wagons or are carrying out the ECM work themselves. The Keeper’s Self-declaration must be sent to the European Railway Agency (ERA) for publication on the Internet.
You will find further information on the ECM policy and the European intermediate solution to demonstrate responsibility for the maintenance freight wagons in the documents listed in the annex to this letter.
Since 1st January 2011, when transporting freight wagons, railway undertakings have been establishing in principle whether,
- a Keeper’s Self-declaration is available for these on the ERA website;
- these freight wagons (according to the statement in the Keeper’s Self-declaration) have had an ECM assigned to them for which an ECM certificate or an ECM self-declaration has been published on the European Rail Agency (ERA) homepage.

So far, on the ERA homepage, keepers’ self-declarations have not been available for all keepers and ECM certificates or ECM self-declarations have not been available for all ECMs in Europe.
Please check whether you, as a keeper, have already submitted a Keeper’s Self-Declaration. If not, please check whether the relevant conditions have been met, submit the Keeper’s Self-declaration and send it to the ERA for publication.
Please check regularly whether an ECM self-declaration or an ECM certificate is published on the ERA website for all ECMs assigned to your wagons. Should this not be the case, ask the relevant ECMs to present and publish their self-declarations or certificates.
If you – as a keeper of freight wagons – do not have the above information by the end of March 2011, then the railway undertakings will have to assume there is no maintenance management available for your freight wagons that meets the requirements of the European intermediate solution or the MoU ECM. In this case, the railway undertakings reserve the right to exclude your wagons from being transported from April 2011 onwards.
The Implementation Guide for Structured Exchange of Information (see annex) foresees the receipt of incoming information, so please send a receipt to: kuntz@vdv.de.
In order to facilitate the exchange of information, we would finally like to remind you that according to Appendix 8 of GCU all signatories are obliged to submit to the GCU Bureau all contact data and the registration numbers of all wagons of which they are the keeper and that can be used by other signatories. According to random checks in the GCU wagon database not all signatories have fulfilled this duty yet.
For further information about this matter, please contact one of the following representatives:
- Mr Markus Vaerst, for commercial/technical questions: markus.vaerst@aae.ch
- Mr Götz Walther, for questions related to Germany: walther@vdv.de
- Ms Monika Heiming, for overall EU questions: monika.heiming@erfa.be

Annex
Information on the European intermediate solution for freight wagon maintenance

 Keeper's self declaration (KSD) implementation guide:
http://www.gcubureau.org/resource/file/pdf/JSG_KSD_Implementation_guide_v1_1_EN.pdf

 Implementation guide for the ECM self declarations - European intermediate solution - Joint Sector Group http://www.era.europa.eu/DocumentRegister/Documents/
Sector%27s%20guide%20for%20ECM%20self%20declarations.pdf

 Implementation guide for the Structured Information Exchange http://www.gcubureau.org/resource/file/pdf/Implementation_guide_SIE.pdf

 ERA-Homepage / Maintenance: http://www.era.europa.eu/Core-Activities/Safety/Pages/maintenance.aspx

 ECM MoU Certificates: http://www.era.europa.eu/
Core-Activities/Safety/Pages/ECM-MoU-Certificates.aspx

 ECM Self Declarations: http://www.era.europa.eu/
Core-Activities/Safety/Pages/ECM-Self-Declarations.aspx

 Keepers Self Declarations: http://www.era.europa.eu/Core-Activities/
Safety/Pages/Keepers-Self-Declarations.aspx?page=1

 GCU website: http://www.gcubureau.org/page/43/Home

15.04.2011:::

UIP Congres

Invitation
The next UIP congress will take place on 30th September 2011 in Bern.
Since the last UIP congress in 2007, the rail environment has evolved considerably. Relationships between players in the sector have been changing as they close ranks to face the challenges. Although rail freight transport is increasing, the rail freight market has not yet recovered from the economic crisis and the double-digit decline in all related business.

Environmental issues are in the spotlight more than ever. Freight transport needs rethinking, not only in terms of the modal split, but also in terms of safety, effective total costs and quality of life. For rail transport this implies reviewing priorities so as to increase capacity, promote efforts to maintain or create sidings and apply an effective, pragmatic approach to noise abatement. All this calls for a package of measures that are harmonized across Europe.

Of course, safety remains the principal issue. Rail is and will remain the safest means of transport, but after the terrible accident of 2009 in Italy the immediate reaction in several European countries was to request additional non-harmonized safety measures. This lack of uniformity was jeopardizing international rail transport. In close cooperation with the sector, the EU Commission and the ERA laid the basis for a framework. The work done by the Task Force and the Joint Sector Group, resulting in implementation of the European Visual Inspection of Wheelsets during maintenance (EVIC), showed that the sector is able and willing to take whatever action is needed to agree on harmonized rules for the benefit of rail freight.

This idea of an active sector, working to define essential self-regulation rather than waiting for authorities to impose rules, needs strengthening in the future so as to increase competitiveness and quality of service. We look forward to welcoming you in Bern, where you can participate in presentations by insiders representing different players in the rail freight sector, and we hope you will contribute to achieving our common goals.

15.04.2011:::

UIP Position on noise

Mr Maurizio Castelletti
Head of the Railways
Safety and Interoperability Unit
European Commission - DG Move
Rue De Mot 28
B - 1040 Bruxelles

7th April 2010

Re : UIP Position on noise

Dear Mr Castelletti,
In preparation of the workshop on "NDTAC and other rail noise developments" on 27th April 2010 and with reference to the final report "Analysis of pre-conditions for the implementation and harmonisation of noise-differentiated track access charges" Oct. 2009 by KCW , Steer Davies Gleave and TU Berlin for EC DG TREN, as well as with reference to the CER / EIM letter to Mr Castelletti in December 2009 regarding the same topic, UIP has formed the following positions:
It is well known that rail noise affects the neighbours of rail traffic and therefore it must be the common goal of all players in the sector to reduce noise emissions in order to insure the environmental friendly character of rail transport and to maintain the high and favourable levels of acceptance of the rail in society.
However, no additional cost burden must be given to the rail transport mode.
We agree with CER and EIM that the most effective way of reducing rail noise is to do it at its source, that is retrofit new break components, namely break blocks. We also agree with CER and EIM that the so called LL block is the better retrofit solution compared to the K block. Therefore any support to perform its EU wide certification until 2012 should be given.
We also agree that the implementation and effective functioning of a NDTAC will take a lot of effort and cost and it will be doubtful whether the incentive payments will reach the private keepers and thus make the retrofit attractive to them.

12.04.2010:::

Meeting of the Secretary General of UIP Mr. Holger Segerer with the Bulgarian Association of the keepers of private wagons – BPW

The meeting took place in Sofia on 19.02.2010.
Mr. Hristo Lazarov, President of BPW made a welcoming speech and presented the Bulgarian Association.
Mr. Holger Segerer, Mr. Jean-Luc Dosquet and Mr. Charles-Antoine Riviere made presentation of UIP under different aspects of its activity underlining its important role for the railway sector:
- liberalization and harmonization of the sector, which was commended by the EU with the Directives on high speed transport, conventional transport and safety;
- to implement the directives 16 TSIs / Technical specifications of Interoperability/ were set up, some of them are currently revised. As further help to implementation, around 80 European standards were and still are to be completed or created. Although standards are usually recommendations, they become comparable to laws as soon as they are referred  to in a TSI, i.e. a law.
- all actors of the sector are invited to support all these activities.

The representatives of UIP and BPW exchanged ideas on current topics /problems encountered, negotiations with the EU concerning maintenance, development of the GCU, etc./ and envisaged the possibility to integrate associations or keepers from neighboring countries of Balkan peninsula.

23.02.2010:::

Meeting with P. Rapacz (DG TREN - responsible for Noise policy) November 12, 2009

Participants UIP : W.Gehrmann, H. Segerer

Topic: Retrofitting on the basis of noise-differentiated track access charges (NDTAC).
Legal basis:
Legal basis for the introduction of an obligatory system of NDTAC will be the recast of the Directive 2001/14/EC. The adoption by the Commission is expected for March 2010. Discussion within the EU institutions and transposition into national law will take another 4 years.
In the recast only one article is foreseen dealing with environmental charges.
The conditions of the NDTAC will be treated in an annex to the Directive. This annex will not be very specified. Important: no reference to of a bonus/malus system will be included. The annex might be modified further according to the EU comitology approach, i.e. no need for including European Parliament and Council for further changes.
Text of annex will not be distributed (officially) to the stakeholders before adoption.
Coming into force of the NDTAC and probable contents
DG TREN assumes that the NDTAC will become operational with the implementation of TAF TSI which might be not before 2017.
DG TREN agrees with the conclusions of the expert study (“Analysis of preconditions for the implementation and harmonization of NDTAC”) favouring a bonus system for silent wagons without implementation of maluses in regard to noisy wagons. The bonus level should be calculated on the basis of costs of retrofitting plus additional operational and administrative costs which occur on the side of the RU and the Wagon Keeper.
The funding of the “bonus” will not be regulated in detail. (Directive only fixes objectives). This means that funding will be up to the Member States which might include the industry.
Interim solution
As the NDTAC will only be operational in some years DG TREN will propose an interim solution but only strictly on a voluntary basis : self declaration + bonus system according to the Swiss model..
A meeting with stakeholders is foreseen in February/March 2010 where more details will be discussed.
LL-projects
Homologation of LL shoes cannot be expected before 2013.
Currently two projects are under way:
- “Decibell” presented by Faiveley, supported by the EU in the framework of the EU “LIFE” Programme. Decibell concentrates only on 1 LL product.
- “Europe-Train” presented by UIC checking several LL products in the framework of a train running 100.000 km p.a. and testing conditions in the different countries (Northern and South Europe included). UIC started a study in June 2009 (duration 3 years, costs 600.000 Euro) on problems with the new brake blocks of “equivalent conicity”.The Europe-Train shall help to achieve the objectives of the study. The practical test by “Europe-Train is foreseen for 2010 and will take 1 ½ years. Participation with wagons at the train would be possible for UIP. UIC has asked for 3 ½ mio Euro funding from the EU.

W.Gehrmann
UIP

30.11.2009:::

General Assembly of UIP

During the last general assembly in Bruges, it has been announced that the next meeting will take place in September in Budapest (Hungary). In order to limit travel, it has been decided to group several meetings and to hold the meetings of the infra and superstructure committees together with the general assembly over a period of 3 days on 16th , 17th and 18th September, followed by an excursion on Saturday 19th for those interested.
The Hungarian association MVME, who is hosting us, prepared the program, as well as the registration form for the various activities and hotel rooms.
In order to ensure a smooth running of the event, the organizer needs to receive the registration by 15 August at the latest. The agendas of the various meetings will be sent in due time.

30.07.2009:::

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.

03.06.2009:::