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 Recheck Only against rules Relating to compatibility with the Networks The Reference Document Mutual Regn Of Veh Types 1996 2001 2004 2010 2014 ~2040 ~2080
Simplification – One Process 25 x National Homologation Processes + 25 x Different Interpretations of the Directive DV 29 Process
Simplification -“Cleaning Up” the rules Now Short term Long term Foreseen by the directive Requirements TSI National Rules • 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 = All requirements (inc interface to the network) TSI Checks • NoBo • Designated Body • CSM Assessor One entity may fill all Roles NoBo • NoBo • Designated body • National Safety Authority • Independent Safety Assessor • “Competent person” specified by NSA Authorisation NSA -1! NSAs • NSA • IM Deadline – 12 months from publishing the Ref Doc Decision
Simplification - Transparency 3rd party verification of conformity to transparent, repeatable rules From expert Judgement (single point of decision) Rule setter (Ministry on NSA advice) • Judgement of • “wise” • expert in NSA/IM • Requirements • Checking method • Authorisation Transparency 3rd party Checking Body (NoBo or DeBo) Authorising Authority (NSA) (Safety Case) (“approved” by ISA based on “judgement”)
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 • Rules notified and collated against the list of parameters • One Point of Entry for rules Database
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
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
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
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
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?
Anything missing (2)? • Technical compatibility/Safe Integration veh-network • 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?
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
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
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?
Anything Else? Comments and Questions