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:

Common reference for

1. The New annex VII of
non-TSI conform
Interoperability Directive
vehicles in Europe

2. The reference Collection of all National

document Technical Rules

Overview of today situation

3. The report on and foster harmonisation
authorisation process of certification procedures

DV29!
 Authorisation Process

Authorisation process is seen by

Strong need for a quick fix of
the difficulties still applicable
to the authorisation process
(cost and time)
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. Assessment of conformity with all relevant TSI’s

2. 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
 1. Extension of the
First Type geographical scope
Authorisation of the TSIs

2. Authorisation for TEN

also validd off TEN

Further Authorisation Platform

in other EU countries authorisation

1. Immediate extension of
scope of the rolling stock TSI’s
2. Elimination of all
unnecessary NNTR
3. Automatic extension to the
whole “interoperable network”
of authorisations delivered on
the basis of TSI compliance
UNIFE requests
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
 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

Only concerns authorisations for fleets of strictly

Type Authorisation identical vehicles, having to cross borders on a
(in ID) 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:

1. Mechanism for authorization of

Platform variation of type
Authorisation 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!