ERA INTEROPERABILITY UNIT
COMPLEMENTARY STUDY “INTERCHANGEABLE SPARE PARTS”
INTEROPERABILITY UNIT
COMPLEMENTARY STUDY
“INTERCHANGEABLE SPARE PARTS”
Reference:
ERA/REP/10-2011/INT
Version:
3
Date:
26 September 2011
Name
Document type:
Final Report
Edited by
Checked by
Approved by
Hubert LAVOGIEZ
Denis BIASIN
J-C. PICHANT
Interoperability Unit
Head of RST Sector
Interoperability Unit
Head of Unit
[signed]
[signed]
Airy MAGNIEN
Position
Interoperability Unit
Project Officer – Rolling stock
Economic Evaluation Unit
Date &
[signed]
Signature
The following document has been produced by the European Railway Agency
as a Final Report of the complementary study on the issue of the
interchangeable spare parts, aimed at ascertain whether the TSIs related to
the rolling stock subsystem should include specific provisions about these
spare parts.
This issue was raised in section 2.2 d) of the Annex of the “Commission
Decision of 29.4.2010 concerning a mandate to the European Railway
Agency to develop and review Technical Specifications for Interoperability
with a view to extending their scope to the whole rail system in the European
Union” (Commission Decision C(2010)2576 final).
This document is intended to inform the European Commission on the
analysis carried out. Where appropriate, on the basis of the results of this
complementary study along with the results of the other three complementary
studies listed in section 2.2 of the Commission Decision C(2010)2576 final,
the mandate will be up-dated by the Commission in accordance with the
procedure set out in Article 29(3) of Directive 2008/57/EC.
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AMENDMENT RECORD
Version
Date
Section number
Modification/description
Author
0.0
04 March 2011
All
Creation of first draft issue for internal
review
H Lavogiez
A Magnien
JM Dechamps
0.1
07 April 2011
All
6 and 8
Modifications
Additions
Internal draft used as a basis for ESG
meeting on 14/04/2011
H Lavogiez
A Magnien
0.2
20 April 2011
All
8
9
Modifications
Case studies (information from RBs)
Draft conclusions
Draft preliminary report issued for
comments of RBs
H Lavogiez
A Magnien
1.0
20 May 2011
All
Editorial modifications and clarifications
Preliminary report issued to
Commission
H Lavogiez
A Magnien
2.0
21 July 2011
All
Editorial modifications and clarifications
Annex 5 added
Final report for ERA internal consultation
H Lavogiez
A Magnien
JM Dechamps
3.0
26 Sept 2011
2.2, 3.2, 5.6.3
Editorial modifications
Final report issued to Commission
H Lavogiez
CONTENTS
EXECUTIVE SUMMARY ............................................................................................................... 5
1. INTRODUCTION – MANDATE TO THE AGENCY.................................................................... 6
2. REFERENCE DOCUMENTS – DEFINITIONS .......................................................................... 7
2.1. Reference documents ................................................................................................................... 7
2.2. Abbreviations and definitions ...................................................................................................... 9
3. SCOPE AND LEGAL FRAMEWORK ...................................................................................... 11
3.1. Scope and Objectives of the study ............................................................................................ 11
3.2. Legal framework ......................................................................................................................... 11
3.3. New approach and rail market regulation ................................................................................. 12
4. WORKING METHOD AND REPORTING ................................................................................ 13
4.1. Working method .......................................................................................................................... 13
4.2. Reporting ..................................................................................................................................... 14
5. GENERAL ANALYSIS............................................................................................................. 15
5.1. Expectations from the sector ..................................................................................................... 15
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5.1.1 Outcome from meeting with Representative Bodies (held on 01/03/2011) ............................................................. 15
5.1.2 Questionnaire .......................................................................................................................................................... 16
5.1.2.1
Purpose ......................................................................................................................................................... 16
5.1.2.2
Synthesis of answers received ...................................................................................................................... 16
5.1.3 outcomes ................................................................................................................................................................. 16
5.2. Definition of “interchangeable spare part” ............................................................................... 17
5.2.1. Definition of a spare part for the purpose of the study ............................................................................................. 17
5.2.2. Common definition of interchangeability .................................................................................................................. 17
5.2.3. Definition of ISP for the purpose of the study .......................................................................................................... 18
5.3. Categorisation of spare parts for the purpose of the study .................................................... 18
5.4. Comparison with interoperability constituents ........................................................................ 19
5.4.1. Current status for ICs ............................................................................................................................................... 19
5.4.2. Contribution of the concept of IC to harmonisation.................................................................................................. 20
5.4.3. Comparison between IC and ISP ............................................................................................................................ 21
5.4.4. Summary ................................................................................................................................................................. 21
5.5. Conformity assessment.............................................................................................................. 22
5.5.1. TSI framework for conformity assessment .............................................................................................................. 22
5.5.2. Proposal from a representative body for ISP ........................................................................................................... 22
5.5.3. Summary ................................................................................................................................................................. 23
5.6. Use of spare parts: maintenance, renewal ................................................................................ 23
5.6.1. Maintenance and renewal ........................................................................................................................................ 23
5.6.2. Technical file provided with the EC declaration of verification ................................................................................. 23
5.6.3. Responsibility of stakeholders; Safety directive ....................................................................................................... 24
5.6.4. Summary ................................................................................................................................................................. 25
5.7. Concept of ISP in normative documents and in research projects ......................................... 25
5.7.1. EN standards ........................................................................................................................................................... 25
5.7.2 UIC leaflets .............................................................................................................................................................. 26
5.7.3. MODTRAIN project .................................................................................................................................................. 26
5.7.4 Other normative documents .................................................................................................................................... 27
6. ISP CONCEPTS ALREADY EXPERIMENTED ....................................................................... 28
6.1. Historical background in the Railway sector ............................................................................ 28
6.1.1 Top down approach ................................................................................................................................................. 28
6.1.2 Bottom up approach ................................................................................................................................................ 30
6.2. Concept of ISP in other sectors ................................................................................................. 32
6.2.1. Example of EU Directives ........................................................................................................................................ 32
6.2.2 Automotive sector .................................................................................................................................................... 32
6.2.3 Aviation sector ......................................................................................................................................................... 32
6.3. Summary...................................................................................................................................... 33
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7. ECONOMIC ASPECTS ........................................................................................................... 34
7.1. General ........................................................................................................................................ 34
7.2. Cost drivers ................................................................................................................................. 34
7.2.1. Vendor lock-in .......................................................................................................................................................... 34
7.2.2. Technical and commercial obsolescence ................................................................................................................ 35
7.2.3. cost of diversity / economies of scale ...................................................................................................................... 35
7.2.4. Maintenance costs ................................................................................................................................................... 36
7.2.5 About standardisation Costs .................................................................................................................................... 36
7.2.6 Outlook .................................................................................................................................................................... 37
8. CASE STUDIES ...................................................................................................................... 38
8.1. Purpose and Selection of case studies ..................................................................................... 38
8.2. Cab display unit .......................................................................................................................... 38
8.3. Contact strips .............................................................................................................................. 40
8.4. Door control ................................................................................................................................ 41
8.5. Wheel ........................................................................................................................................... 42
8.6. Summary...................................................................................................................................... 44
9. CONCLUSIONS ...................................................................................................................... 45
9.1. Proposal on how ISP should be managed ................................................................................ 45
9.2. Pertinence of provisions about ISP in RST TSIs ...................................................................... 45
10.
ANNEXES ......................................................................................................................... 47
LIST OF RESPONDENTS ........................................................................................................... 51
SUMMARY OF ANSWERS ......................................................................................................... 51
1.
Technical aspect (questions A1 to A6) ...................................................................................... 51
2.
Conformity assessment (questions B1 to B4) .......................................................................... 52
3.
Current practice (questions C1 to C2) ....................................................................................... 52
4.
Other comments (question D) .................................................................................................... 53
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EXECUTIVE SUMMARY
Mandate to the
Agency
Annex, Section 2.2. of the [1] Commission Decision
C(2010)2576 final concerning a mandate to the European
Railway Agency to develop and review Technical
Specifications for Interoperability with a view to extending
their scope to the whole rail system in the European Union
states that: “The Agency shall carry out the following
complementary study:
d) Complementary study on the issue of the
interchangeable spare parts, aimed at ascertain whether
the TSIs related to the rolling stock subsystem should
include specific provisions about these spare parts.”
The final report concerning the abovementioned
complementary study shall be delivered as set out in
section 3.2 of the mandate (12 months after its notification).
Where appropriate, on the basis of the results of this study,
the mandate will be updated by the Commission in
accordance with the procedure set out in Article 29(3) of
Directive 2008/57/EC.”
Summary
The need, identified by some stakeholders of the railway
sector, for EN standards covering the concept of
interchangeable spare parts (ISP) is not put in question;
concerned stakeholders have already taken initiatives, and
may address any request to standardisation bodies.
Economic aspects linked to spare parts are recognised, but
can only be assessed on a case by case basis with
consideration of various business issues, in which ERA has
no leading role.
The specification of the ISP being seen as an optional
requirement, the TSI does not appear to be the right
support; standards applied on a voluntary basis are
appropriate.
The definition of additional regulatory technical
specifications covering interchangeability, without any link
to essential requirements from the interoperability directive,
would be difficult to achieve in a transparent and nondiscriminatory way.
The concept of ISP can already be implemented within the
current legal framework (maintenance documentation,
definition of the „area of use‟ for interoperability
constituents‟) without any specific provision in RST TSIs.
Therefore, RST TSIs should not include any additional
specific provision regarding interchangeability of spare
parts above those that may already be indirectly covered in
the current framework.
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1.
INTRODUCTION – MANDATE TO THE AGENCY
This report has been prepared by the Interoperability Unit of the European
Railway Agency, together with the Economic Evaluation Unit for the impact
assessment.
Article 1 of the [1] Commission Decision C(2010)2576 final concerning a
mandate to the European Railway Agency to develop and review Technical
Specifications for Interoperability with a view to extending their scope to the
whole rail system in the European Union, hereafter referred to as Mandate
2010, states that:
“The mandate for extending the scope of technical specifications for
interoperability ("TSI") to be issued in accordance with Article 8(2) of
Directive 2008/57/EC is hereby adopted by the Commission.”
Annex, Section 2.2. of the [1] Mandate 2010 states that:
“The Agency shall carry out the following complementary studies:
d) Complementary study on the issue of the interchangeable spare parts,
aimed at ascertain whether the TSIs related to the rolling stock subsystem
should include specific provisions about these spare parts.”
[...]
The final reports concerning the abovementioned complementary studies
shall be delivered as set out in section 3.2 below. Where appropriate, on
the basis of the results of these studies, the present mandate will be
updated by the Commission in accordance with the procedure set out in
Article 29(3) of Directive 2008/57/EC.”
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2.
REFERENCE DOCUMENTS – DEFINITIONS
2.1.
REFERENCE DOCUMENTS
Ref. Document Reference
Official Journal
Version/ Modifications
[1]
Commission Decision C(2010)2576
NA
final of 29.4.2010 concerning a
mandate to the European Railway
Agency to develop and review
Technical Specifications for
Interoperability with a view to extending
their scope to the whole rail system in
the European Union
Dated 29.04.2010
[2]
Directive 2008/57/EC of the European L 191, page 1
Parliament and of the Council of 17
18.7.2008
June 2008 on the interoperability of the
rail system within the Community
As amended by
Commission Directive
2009/131/EC of 16 October
2009 (OJ L 273, 17.10.2009,
p. 12)
Commission Directive
2011/18/EU of 1 March 2011
(OJ L 57, 2.3.2011, 21)
[3]
Directive 2004/49/EC on Safety on the
Community‟s railways,
L164, page 44
30.04.2004
As amended by
Directive 2008/57/EC of the
European Parliament and of
the Council of 17 June 2008
(OJ L 191 18.7.2008, p.1)
Directive 2008/110/EC of the
European Parliament and of
the Council of 16 December
2008 (OJ L 345, 23.12.2008,
p. 62)
Commission Directive
2009/149/EC of 27
November 2009 (OJ L 313,
28.11.2009, p.65)
[4]
Regulation (EC) No 881/2004 of the
European Parliament and of the
Council of 29 April 2004 establishing a
European Railway Agency (Agency
Regulation).
ERA/REP/10-2011/INT
L 164, page 1, 30
April 2004
Corrected by Corrigendum
(OJ L 220, 21.6.2004, p.47)
As amended by Regulation
(EC) No 1335/2008 of the
European Parliament and of
the Council of 16 December
2008 (OJ L 354, 31.12.2008,
p.51)
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Ref. Document Reference
Official Journal
Version/ Modifications
[5]
Commission decision N° 2011/291/EU
of 26 April 2011 concerning a TSI
relating to “Locomotives and
Passenger rolling stock” of the transEuropean conventional rail system.
L 139, page 1
26.5.2011
NA
[6]
Commission decision N° 2006/861/EC
of 28 July 2006 concerning a TSI
relating to “Freight wagons” of the
trans-European conventional rail
system.
L 344, page 1
8.12.2006
As amended by
Commission decision
N°2009/107/EC of 23
January 2009 (OJ L 45,
23.2.2009, p.1)
[7]
Work Programme of the Agency for
implementing the Commission
Decision C(2010)2576 concerning a
Mandate to the European Railway
Agency to Develop and Review
Technical Specifications for
Interoperability with a View to
Extending Their Scope to the Whole
Rail System in the European Union
NA
July 2010
Update in June 2011
(intermediate report; midterm review)
[8]
Commission regulation (EU) N°
445/2011 of 10 May 2011 on a system
of certification of entities in charge of
maintenance for freight wagons
L 122, page 22
11.05.2011
NA
[9]
Document from the Commission
referenced DV77 EN06 dated
13.11.2008 titled “Interoperabilty
constituents”
NA
DV77 EN06
(status „I‟ informative)
[10]
Economic benefits of standardisation:
Summary of results. Published by DIN
(German Institute for Standardization),
Beuth Verlag, 2000 (ISBN 3-41014860-4
NA
NA
[11]
Directive 97/23/EC of the European
Parliament and of the Council of 29
May 1997 on the approximation of the
laws of the Member States concerning
pressure equipment
OJ L 181, 9.7.1997,
p. 1
As amended by Regulation
(EC) No 1882/2003 of the
European Parliament and of
the Council of 29 September
2003 (OJ L 284, 31.10.2003,
p. 1)
Corrected by Corrigendum
(OJ L 265, 27.9.1997, p. 110
(97/23/EC)) and
Corrigendum (OJ L 93,
7.4.2011, p. 38 (97/23/EC))
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Ref. Document Reference
Official Journal
Version/ Modifications
[12]
OJ L 157, 9.6.2006,
p. 24
As amended by
Regulation (EC) No
596/2009 of the European
Parliament and of the
Council of 18 June 2009 (OJ
L 188, 18.7.2009, p. 14)
Directive 2006/42/EC of the European
Parliament and of the Council of 17
May 2006 on machinery, and
amending Directive 95/16/EC
Directive 2009/127/EC of the
European Parliament and of
the Council of 21 October
2009 (OJ L 310,
25.11.2009, p. 29)
Corrected by Corrigendum
(OJ L 76, 16.3.2007, p. 35
(2006/42/EC))
[13]
2.2.
Decision N°2006/14/R of the executive
director of the European Aviation
Safety Agency of 20 december 2006
(acceptable means of compliance and
guidance material)
NA
ABBREVIATIONS AND DEFINITIONS
Table 3: Abbreviations and Definitions
ABBREVIATION /
FULL TEXT / DEFINITION
TERM
APS
Authorisation for placing in service
CCS
Control-Command and Signalling
CEN
European Committee for Standardization
CENELEC
European Committee for Electrotechnical Standardisation
ECM
Entity in charge of maintenance
ERA
The European Railway Agency
ERTMS
European Rail Traffic Management System
ETCS
European Train Control System
IC
Interoperability Constituent
IEC
International Electro-technical Commission
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Table 3: Abbreviations and Definitions
ABBREVIATION /
FULL TEXT / DEFINITION
TERM
ISP
Interchangeable Spare Part
IU
Interoperability Unit of the European Railway Agency
IA
Impact Assessment
LOC & PAS
Locomotives and Passenger Rolling Stock
Mandate 2010
[1] Commission Decision C(2010)2576 final concerning a mandate to
the European Railway Agency to develop and review Technical
Specifications for Interoperability with a view to extending their scope to
the whole rail system in the European Union
NA
Not Applicable
NB-Rail
Co-ordination group of Notified Bodies for Railway products and
systems
NoBo
Notified Body
NSA
National Safety Authority
OEM
Original Equipment Manufacturer
RB
Representative bodies from the railway sector referred to in Article 3
paragraph 2 of [4] Regulation (EC) 881/2004, as modified by
Regulation (EC) 1335/2008
RFS
Request for a standard issued by ERA to Standardisation bodies
RST
Rolling Stock
RST TSIs
For the purpose of the report, this term in plural refers to the following
TSIs: Freight Wagons TSI, HS RST TSI and CR LOC&PAS TSI
RU
Railway Undertaking
Stakeholders
For the purpose of the report, stakeholders are all the bodies impacted
by the study
TCMS
Train control and monitoring system
TSI
Technical Specification for Interoperability
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3.
SCOPE AND LEGAL FRAMEWORK
3.1.
SCOPE AND OBJECTIVES OF THE STUDY
The study provides an analysis to the European Commission aimed at
evaluating if specific provisions related to interchangeable spare parts (ISP)
should be included in rolling stock TSIs.
This analysis is based on a structured approach covering legal, technical and
economic aspects.
The CCS subsystem and ETCS components are not required to be covered in
this study (the Mandate mentions explicitly “TSIs related to the rolling stock
subsystem”). They were mentioned by some RBs, but ERA‟s view it that they
cannot be dealt with in the same way as other spare parts due to the
particularity of the CCS TSI (more prescriptive than other TSIs); additionally,
specialized experts groups are in charge of specifying and managing
modifications, and all technical issues relating to CCS should be dealt with by
these groups.
3.2.
LEGAL FRAMEWORK
The interoperability directive [2] includes the following articles, which have
to be taken into account in the scope of the present study on ISP:
Article 1 „Purpose and scope‟:
2. The pursuit of this objective must lead to the definition of an optimal level
of technical harmonisation and make it possible to:
(b) contribute to the progressive creation of the internal market in
equipment and services for the construction, renewal, upgrading and
operation of the rail system within the Community;
Article 2 „Definitions‟:
(b) „interoperability‟ means the ability of a rail system to allow the safe and
uninterrupted movement of trains which accomplish the required levels of
performance for these lines. This ability depends on all the regulatory,
technical and operational conditions which must be met in order to satisfy the
essential requirements;
(i) „technical specification for interoperability‟ (TSI) means a specification
adopted in accordance with this Directive by which each subsystem or part
subsystem is covered in order to meet the essential requirements and ensure
the interoperability of the rail system;
(f) „interoperability constituents‟ means any elementary component, group
of components, subassembly or complete assembly of equipment
incorporated or intended to be incorporated into a subsystem, upon which the
interoperability of the rail system depends directly or indirectly. The
concept of a „constituent‟ covers both tangible objects and intangible objects
such as software;
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Annex III „Essential requirements”:
No requirements have been identified as relevant for the scope of the study
on ISP.
ERA view is that only the Article 1(2) may be referred to as a legal framework
for the inclusion in TSIs of provisions about ISP; this is further analysed and
argued in the following sections of this report.
As described in section 5.6.3 of this report, the safety directive [3], defines
the responsibilities between the actors of the railway sector, including those
related to maintenance activities, which have to be taken into account in the
scope of the present study on ISP.
3.3.
NEW APPROACH AND RAIL MARKET REGULATION
The aim of the new approach (1985) to EU regulation was to limit, as far as
possible, EU legal requirements to functional requirements, leaving it to
Industry to set harmonised standards as sufficient means of compliance with
these requirements. Additionally, the new approach introduced the
harmonisation of essential requirements.
In the case of rail market regulation, the interoperability directives were based
on the principles of the new approach, but an intermediate layer was
recognized necessary, namely TSIs. This was due to the extent of technical
compatibility issues inherent to the railway system. TSI drafting aims at
functional specifications, as far as possible, in order to avoid market
distortions and freeze of innovation. TSIs are not meant to become full
industrial specifications. The optimum level of technical harmonisation
brought about by TSIs should contribute to the progressive creation of the
internal market.
TSIs may enforce detailed specifications, under the condition (governed by
the subsidiarity and proportionality principles) that these means are necessary
to achieve the aims of the policy (expressed by the interoperability directive),
and that the means must be proportionate to the sought effects.
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4.
WORKING METHOD AND REPORTING
4.1.
WORKING METHOD
The analysis was carried out by the rolling stock sector of the interoperability
unit of ERA in collaboration with other sectors and units of ERA, particularly
the economic evaluation unit and the safety unit. The main stages are the
following:
1. Qualitative analysis
A preliminary analysis was performed within ERA in order to identify the
information available and the different aspects to be covered. In particular:
- legal framework
- former correspondence (letters from the sector) and activities (workshops)
on the subject of interoperability constituents and spare parts have been
taken into account.
A preparatory working meeting was organised on 01/03/2011 with RBs in
order to better understand their expectations.
A questionnaire was sent to NSAs, RBs and NB-Rail in order to collect the
views and expectations of the different actors of the railway sector.
This qualitative analysis presents the different aspects to be considered when
addressing the subject of interchangeable spare parts in the legal framework
in force in the railway sector.
2. Former experiences, experiences in other sectors and global economic
aspect
The subject of interchangeable spare parts was then analysed globally, on the
basis of various experiences, with the objective of identifying the “why” and
“how”.
3. Identification of case studies, for technical and economic analysis.
Considering the different nature and complexity of spare parts, a global
analysis presents limitations; as mitigation, case studies were selected with
RBs, and were analysed by ERA with support of RBs.
4. Drafting of the conclusions:
- Technical feasibility of including specific provisions about interchangeable
spare parts in rolling stock TSIs.
- Legal framework for such provisions.
- Economic aspects.
- Impact on the work programme of the mandate 2010 [7].
The findings and conclusions of ERA are presented in this report.
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4.2.
REPORTING
The preliminary report (version 1.0) summarises the findings of the study and
proposes a conclusion. It was submitted to the Commission as a
preliminary report in May 2011.
The preliminary report was also presented to the organisations consulted by
the questionnaire: NSAs, RBs and NB-Rail (NoBos), for their feedback.
The comments provided to ERA are presented in the annex 5 of the report
and the relevant sections of the preliminary report have been updated
accordingly.
The up-dated version of the report is provided to the Commission as
final report (current version 3.0).
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5.
GENERAL ANALYSIS
This section of the report presents the context of this study on
“interchangeable spare parts”. It covers:
- Expectations from the sector,
- Definition and categorisation of a “interchangeable spare part”,
- Comparison between specification for interoperability constituents and
specifications for ISP.
- Conformity assessment,
- Use of spare parts and responsibilities, and possible benefits of an EC
certificate.
- Relevant normative documents and research projects.
5.1.
EXPECTATIONS FROM THE SECTOR
5.1.1
OUTCOME FROM MEETING WITH REPRESENTATIVE BODIES
(HELD ON 01/03/2011)
CER considers the ISP concept as part of the objectives of the interoperability
directive, because it contributes to the creation of an internal market and to a
reduction of life cycle cost for rolling stock. The regulatory approach and ERA
role are seen as levers to develop standardisation in this field.
Some initiatives were taken in the past, through calls for tender, through
development based on a unique specification required to different
manufacturers, through the drafting of standards; results have not been those
expected, due to a lack of common objectives between the different
stakeholders (mainly between RUs and manufacturers).
The ISP concept is a step forward to implement clear interfaces for
components, with the effect to open the market of these components to more
suppliers in Europe.
CER proposes to apply the following principle in the definition of ISPs:
- The definition of ISPs needs to allow the use of the “Russian doll” principle
(e.g. ISP “wheel” in an ISP “bogie”).
- ICs have to be checked against 5 essential requirements (safety, reliability
and availability, health, environmental protection, technical compatibility).
- ISPs need to be checked against the 5 essential requirements and a “6 th
requirement” called “interchangeability”, the latter is optional and may have
3 levels (see also sections 5.2.3 and 5.3).
CER considers the concept of ISP as an extension of the concept of IC, to be
applied on a voluntary basis (option in the TSI).
The detailed specifications of ISPs should be available in EN standards to be
developed upon request from ERA to standardisation bodies.
CER has provided a list of components to which the concept of ISP may
apply; this list can be found in annex 3 of this report.
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UITP does not support any additional mandatory requirement and considers
the ISP concept as a pure market/business issue.
UIP thinks the ISP concept is necessary for freight wagons because they are
operated and have to be maintained in different locations.
UNIFE thinks the ISP concept should remain in the voluntary domain, by
means of EN standards. They don‟t see any general reason, nor any general
legal ground, for inclusion or reference of such standards in TSI‟s or
involvement of ERA in the standardisation decision process (see also section
5.3).
UNIFE points out that:
- An economic positive impact of standardisation cannot by itself be a
justification for the intervention of public authorities in the competitive
domain.
- The respective responsibilities, including the liability of the product supplier,
have to be considered in the study.
5.1.2
QUESTIONNAIRE
5.1.2.1
PURPOSE
ERA has prepared a questionnaire in order to collect information related to
legal aspects that have to be analysed in this study on ISP.
The aim is to receive the opinion of the interested parties regarding the
possible evolution of the legal framework (TSIs) that regulates the conformity
assessment: „EC‟ declaration of conformity (constituents) and/or „EC‟
declaration of verification (rolling stock).
The questionnaire was distributed to all representative bodies, the national
safety authorities of the EU and EEA Member States and NB-Rail, in order to
get a feedback from the interested parties who might be impacted in their
activity by a potential regulation of some spare parts related to rolling stock.
This questionnaire is not the unique source of information for ERA to perform
the study; in particular, the concerned representative bodies have already
expressed their expectations to the Commission or to ERA, and have
provided technical and economic data (see sections 4.1 and 5.1.1 of this
report).
The questionnaire can be found in annex 1 of this report.
5.1.2.2
SYNTHESIS OF ANSWERS RECEIVED
The answers received to the questionnaire are summarised in annex 2 of this
report.
5.1.3
OUTCOMES
Among the 12 NSAs who answered, 5 of them answered that the concept of
ISP should not be dealt with in TSIs.
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Among the 7 NSAs who are in favour of this concept in TSIs, 5 of them
answered also that the specification for the verification of the ISP should be
available through the technical file; among those, 1 suggested to have a list of
approved spare parts in the technical file, and 1 mentioned the responsibility
of the ECM in the choice of spare parts.
All reported the following expected benefits: “opening of the market” and
“increase of quality”.
These answers show that for spare parts, the distinction between TSI
requirements and maintenance recommendations given in the technical file
should be clarified; ERA will provide the necessary explanations in the
different working groups (TSI drafting, ECM recommendation, definition of a
RST type…).
If we were to specify the ISP characteristics in the TSI, these should be
sufficient, and additional information (specification, list of approved spare
parts) should not be necessary in the technical file.
CER answered that the TSI should include a list of components considered as
ISP, and the corresponding specification for conformity assessment. For
complex ISP, TSIs should describe the functionalities and list the different
interfaces to be taken into account (mechanical / electrical …) and then refer
to standards for the detailed specification. The information given in the
technical file should be limited to the use (or not) of the ISP concept
(considered as optional) for components identified as ISP in the TSI.
CER answered also that the concept of ISP may also apply to other
components (not listed) in the TSI, based on EN standard or UIC leaflets.
UNIFE is not in favour of any additional regulatory provision regarding ISP (no
clear legal basis).
5.2.
DEFINITION OF “INTERCHANGEABLE SPARE PART”
5.2.1.
DEFINITION OF A SPARE PART FOR THE PURPOSE OF THE STUDY
Spare parts are materials, components or sub-assemblies that are used for
replacement following:
- Consumption (oil, sand…)
- Criteria for limit of use reached (including wear)
- Failure
- Accident
They are usually identical to the original components, but may be different
provided that the functionalities and the interfaces are ensured.
New spare part may need to be developed in case the original spare part
cannot be found anymore on the market.
5.2.2.
COMMON DEFINITION OF INTERCHANGEABILITY
The following common definitions have been found:
IEC:
“Situation where two or more items are so similar in functional and physical
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characteristics that they are considered equivalent in performance and
durability. Each is capable of replacing the other(s) without causing a need
for alteration or adjustment to fulfil the same requirement.”
Wikipedia:
“Interchangeable parts are parts that are, for practical purposes, identical.
They are made to specifications that ensure that they are so nearly
identical that they will fit into any device of the same type. One such part
can freely replace another, without any custom fitting (such as filing). This
interchangeability allows easy assembly of new devices, and easier repair of
existing devices, while minimizing both the time and skill required of the
person doing the assembly or repair.”
These definitions may apply to the spare parts in the railway sector.
5.2.3.
DEFINITION OF ISP FOR THE PURPOSE OF THE STUDY
The common definitions given above are restrictive, in comparison with the
work done up to now by the sector (see section 5.7).
CER and UNIFE have proposed to consider a definition of a “interchangeable
spare part”, with different levels of interchangeability, allowing a flexible
application to different spare parts:
- Level 3: “plug & play” – full physical and functional interchangeability
- Level 2: adaptable – partial interchangeability
- Level 1: only functional interchangeability
CER has pointed out that the levels correspond to steps in the approach,
each step representing an increase in interchangeability; considering only
level 3 would be too ambitious, and premature in a number of cases
(considering the time that would be needed to develop relevant standards).
Additionally, considering that a TSI is not a comprehensive technical
specification of a product, ERA notes that it may not be always possible to
cover a full interchangeability (for which all aspects have to be considered).
It has been agreed to consider in this study the definition and levels proposed
by CER and UNIFE.
5.3.
CATEGORISATION OF SPARE PARTS FOR THE PURPOSE OF THE
STUDY
UNIFE has proposed the following segmentation that has been used in the
standardisation work with UIC and CER:
- Parts for which possible interchangeability is only a matter of simple
mechanical interfaces, with no significant impact on vehicle system
design or on safety (e.g. cab door handles, grab bars, steps etc. ), or
materials subject to simple specification such as sand, lubricants…
- Subsystem with complex interfaces, and with therefore a significant
impact on system design (e.g. toilet modules, doors)
- Part or sub-systems having a significant impact on functional safety
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-
Parts of which the behaviour can hardly be described and having a
significant impact on safety (e.g. brake pads or disks)
This segmentation gives the degree of complexity of the specification of the
spare part as stand-alone component.
UNIFE view is that for the 2 highest level of complexity, interchangeability
level 3 cannot be achieved on the simple basis of compliance with a standard
(see their comment on respective responsibilities in section 5.1.1, and section
5.6). Additionally, for the second highest level (subsystems with high impact
on system design), UNIFE thinks the ISP concept would preclude innovation
and badly jeopardise competitiveness.
The proposal made by CER is to classify the spare parts according to the
following categories:
- Consumables at operating level (sand, grease, …)
- Consumables at maintenance level (brake pads, …)
- Line replaceable units (hardware with mechanical, electrical, pneumatic,
data and other interfaces)
- Software modules (like in the IC definition)
The technical feasibility to define ISP specifications is reflected by the
segmentation proposed by UNIFE.
The benefits expected from the concept of ISP depend on the category of
spare part, as defined above, but also on the expected frequency of
replacement during the lifetime of the rolling stock.
For the purpose of the study, the categories above are considered, together
with a degree of complexity (illustrated in the section 8 “case studies”).
5.4.
COMPARISON WITH INTEROPERABILITY CONSTITUENTS
5.4.1.
CURRENT STATUS FOR ICS
Interoperability constituents are defined in article 2(f) of the interoperability
directive (quoted in section 3.2 of this report).
Interchangeability was clearly identified as an objective for IC in a working
document issued in 2005 by AEIF (“Association européenne pour
l‟interopérabilité ferroviaire” in charge of drafting TSIs before the creation of
ERA).
The subject was discussed with the Commission from 2006 to 2008, and a
document [9] was issued in November 2008 (DV77 EN06; status „I‟
informative), stating:
“An IC is not per definition interchangeable since not all product parameters
are defined. ICs may be interchangeable in the defined circumstances, but
interchangeability is not necessary condition (requirements). The
interchangeability may depend on the area of use. The interchangeability of
an IC as a spare part may be described in the maintenance file of the
subsystem.”
“Any additional requirements which are not related to the interoperability
should remain in voluntary EN standards.”
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The last statement is consistent with the “new approach”, which aims at
opening the market, in avoiding any superfluous regulatory provision (see
section 3.3 of the present report).
On another hand, this study analyses the need for additional regulatory
provisions related to ISP, in order to contribute to the creation of a market of
spare parts.
We have here two opposite views.
Additionally, the issue of the voluntary use of the concept of IC was discussed
at the same time. The conclusion of this discussion was reported in the TSIs
recently drafted: IC not covered by the relevant EC declaration of conformity
or suitability for use (non-certified ICs) can only be incorporated in a
subsystem during a transition period of 6 years; in that case, the
corresponding TSI requirements have to be checked at the level of the
subsystem.
Indeed, TSI requirements are mandatory by nature, and their application is
not left to the choice of the applicant; this applies also to requirements set up
for constituents.
For freight wagons, the former regime (RIV, UIC code applied on a voluntary
basis) has contributed to create a market of components which is still
effective, so that advantages of the IC concept defined in the TSI [6] are not
clearly identified.
It is likely that the IC concept could present more advantages to the sector for
locomotives and passenger rolling stock, for which there is a wider variety of
designs (UIC code has not provided the same level of technical harmonisation
than for freight wagons). Since the CR LOC&PAS TSI [5] is applicable from 1
June 2011, there is no feedback available on its effect on the market.
In general, ERA view is that the concept of IC might not have been up to now
sufficiently used in order to influence the market.
5.4.2.
CONTRIBUTION OF THE CONCEPT OF IC TO HARMONISATION
As soon as a component has technical characteristics that have to be verified
against TSI requirements independently of the RST subsystem, this
component may be considered as covered by the concept of IC.
If declared as IC in the TSI, the component will be certified independently of
any application (rolling stock project).
When a new rolling stock is designed, it seems credible that components
already certified will be chosen in priority, in order to simplify the conformity
assessment. This should lead indirectly to a harmonisation of characteristics
that are not specified in the TSI (like mechanical interfaces if they are not
relevant to «interoperability»), and should contribute to the development of a
market of components.
In the CR LOC&PAS TSI, the IC characteristics that are in interface with the
rolling stock are described (area of use); these characteristics define at least a
functional interchangeability (level 1 as defined by the sector); they have to be
covered by the EC „declaration of conformity or suitability for use‟ covering the
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component (see section 5 of the CR LOC&PAS TSI). Therefore there is
already a framework defined for an ECM to use a component different than
the original one or not listed in the maintenance documentation (technical
file); this is covered by the ECM regulation [8], annex III section II.2.c &d (to
be of mandatory application for freight wagons).
5.4.3.
COMPARISON BETWEEN IC AND ISP
It is already allowed to integrate e.g. mechanical interface specifications into
IC specifications. Such specifications would promote interchangeability of ICs.
This question was raised several times, e.g. during the drafting of the first
release of the CR LOC&PAS TSI. No such interfaces could be agreed upon;
roof mounting of pantographs is a typical example.
The reasons for not finding an agreement were that in the legal context of
TSIs, mechanical interfaces would represent an over specification that would
prevent project designers to develop and implement the best solution for their
project, additionally there was no clear criteria to select the particular
mechanical interface to be specified.
Mechanical interfaces specified in the context of standards or other normative
documents (see section 5.7 of this report) are of voluntary application, and
therefore do not present this burden.
When a standard is drafted for the conformity assessment of TSI
requirements applicable to an IC, this standard can also include additional
specifications in order to ensure interchangeability (level 1, 2 or 3); these
additional specifications would be of voluntary use, and would not all be
covered by the EC certificate (but are part of the component specification).
The view of CER is to consider the concept of ISP as an extension of the
concept of IC, applicable as an option, with 3 levels of interchangeability, and
to have a conformity assessment procedure as for ICs, under the
responsibility of the component manufacturer, covering all characteristics,
including those for interchangeability purpose that are not related to the area
of use of the component defined in the TSI.
The technical specification should clearly describe the level of
interchangeability reached, in order to have clear information in the EC
certificate.
5.4.4.
SUMMARY
When comparing the IC and ISP concepts, the following issues are identified:
- From a legal point of view, unlike the specification for ICs, the specification
of the ISP being seen as an optional requirement, the choice to apply that
requirement would be left to the applicant; therefore the TSI might not be
the right support. An information would be necessary in the technical file
for the corresponding spare part: “ISP concept applied, with selected level
of interchangeability”.
In the current framework, the specification to be applied to the spare part
(including interchangeability if relevant) can be mentioned in the technical
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file (maintenance documentation), provided that the relevant specification
(EN standard) is available.
- From a technical point of view, the decision criteria to define a particular
technical solution as “interchangeable”, with a particular status recognised
in the TSI, may be not transparent.
- From a technical point of view, the level of interchangeability reached (if
different than 3 for interfaces with high level of complexity) may present
some uncertainties.
- From an economic point of view, the efficiency of an optional requirement
for interchangeability, additionally with different levels, cannot be predicted
globally (see also section 8 of this report).
5.5.
CONFORMITY ASSESSMENT
5.5.1.
TSI FRAMEWORK FOR CONFORMITY ASSESSMENT
A TSI shall allow independent conformity assessment against a clear
technical basis by a notified body. The compliance to harmonised EN
standards may give presumption of conformity.
When necessary in order to have a clear basis for verification of conformity to
TSI requirements, ERA may issue requests for standards to standardisation
bodies.
The application of the TSI results in:
- „EC‟ declaration of conformity or suitability for use for interoperability
constituents, drawn up by the manufacturer.
-
„EC‟ declaration of verification for rolling stock, with associated technical
file, drawn up by the applicant.
These declarations are both based on a certificate delivered by a notified
body (excepted when module CA “Internal production control” is applied).
In case TSI requirements are defined for ISPs, the conformity assessment
process should be similar to the process for ICs; it is expected that the same
modules as for ICs could be used.
5.5.2.
PROPOSAL FROM A REPRESENTATIVE BODY FOR ISP
Among the Representative Bodies, CER made a proposal regarding the
conformity assessment procedure that may apply to ISP.
CER suggested a conformity assessment procedure similar to those used for
ICs, pointing out that a notified body should not systematically be involved; for
example, the application of the module CA for ICs “internal production control”
is under the responsibility of the manufacturer.
CER also suggested defining the role of the notified body according to the
type of quality management system applied by the manufacturer, and to the
type of ISP:
- no role if the quality management system in place allows that
- choice of a module depending on level of interchangeability
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- choice of a module depending on criticality/complexity
- choice of using a notified body depending on cross-border traffic
5.5.3.
SUMMARY
ERA has not identified any particular issue regarding conformity assessment.
A procedure similar to those already in place for ICs may apply, provided that
a clear technical specification defines the level of interchangeability to be
reached, and its limitations (see section 5.4.4); this is a condition for a NoBo
to be in a position to deliver a certificate.
5.6.
USE OF SPARE PARTS: MAINTENANCE, RENEWAL
5.6.1.
MAINTENANCE AND RENEWAL
A distinction should be made between spare parts for routine maintenance,
for which the maintenance documentation apply, and spare parts for
refurbishment, that may be subject of additional legal provision.
Renewal is defined in article 2(n) of the interoperability directive as “any major
substitution work, which does not change the overall performance”.
The substitution of a component by another one not identical (ISP) may fall
under this definition. Processes to be applied are described in the article 20 of
the interoperability directive.
Obsolescence of components may require the development of new spare
parts, and may lead to triggering a renewal of the rolling stock (in the sense of
the interoperability directive) in case the component may have an impact of
the conformity assessment of the rolling stock against the TSI.
The on-going work on the definition of a type for a vehicle (in the framework of
the type register ERATV working party) will clarify the process to be followed
for modifications to a type; this aspect is therefore not covered in the present
report.
5.6.2.
TECHNICAL FILE PROVIDED WITH THE EC DECLARATION OF
VERIFICATION
The clause 4.2.12.3.2 of the CR LOC&PAS TSI (taken as example, other
TSIs have a similar requirement) requires as part of the maintenance
description file:
“Parts list: The parts list shall contain the technical descriptions of the spare
parts (replaceable units) and their references, in order to allow identification
and procurement of the correct spare parts. The list shall include all parts
specified for changing on condition, or which may require replacement
following electrical or mechanical malfunction, or which will foreseeable
require replacement after accidental damage (e.g. windscreen).”
It is possible in the technical file to reference several ISP, or to include the
specification for interchangeability of a spare part; this is consistent with the
extract of the document DV77 for ICs given above in section 5.4.1.
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The technical file is lodged with the applicant, and is part of the declaration of
verification necessary to get an authorisation for placing in service (APS). It is
not publicly available, in order to protect the intellectual property rights; the
applicant is responsible for the information contained in this technical file.
Modifications after the APS are managed as described below in section 5.6.3;
there is no imposition to have the original technical file updated.
5.6.3.
RESPONSIBILITY OF STAKEHOLDERS; SAFETY DIRECTIVE
The safety directive [3] includes the following articles, which have to be
taken into account in the scope of the present study on ISP:
Article 4(3):
“…Without prejudice to civil liability in accordance with the legal requirements of the
Member States, each infrastructure manager and railway undertaking shall be made
responsible for its part of the system and its safe operation, including supply of
material and contracting of services, vis-à-vis users, customers, the workers
concerned and third parties.”
Article 4(4):
“This shall be without prejudice to the responsibility of each manufacturer,
maintenance supplier, keeper, service provider and procurement entity to ensure that
rolling stock, installations, accessories and equipment and services supplied by them
comply with the requirements and the conditions for use specified, so that they can
be safely put into operation by the railway undertaking and/or infrastructure
manager.”
Article 9(2):
“It (the SMS) shall ensure the control of all risks associated with the activity of the
infrastructure manager or railway undertaking, including the supply of maintenance
and material.”
Article 14a(3):
“Without prejudice to the responsibility of the railway undertakings and infrastructure
managers for the safe operation of a train as provided for in Article 4, the entity shall
ensure that the vehicles for which it is in charge of maintenance are in a safe state of
running by means of a system of maintenance. To this end, the entity in charge of
maintenance shall ensure that vehicles are maintained in accordance with:
(a) the maintenance file of each vehicle;
(b) the requirements in force including maintenance rules and TSI provisions.”
This article introduces the responsibilities and the rules for ECM, which have
been further developed in the regulation on system of certification of ECM [8],
making the certification mandatory to any ECM of freight wagons; the
specified rules may be used as good practices by any maintenance
organisation, dealing with any type of vehicles.
Point 2 b) - d) in section II of Annex III of the regulation on system of
certification of ECM [8]:
“In case of changes brought to the maintenance with deviation from the
maintenance documentation (part of the technical file), this regulation for
certification of ECM specifies tasks the ECM is responsible for:
 Verifying in all circumstances the consistency of the maintenance file
with the authorisation of placing-in-service (including any national
safety authority requirements), the declarations of conformity to TSIs,
the declarations of verification, and the technical file;
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

Identifying the need for risk assessment regarding the potential impact
of the substitution in question on the safety of the railway system;
Managing the configuration of all technical changes affecting the
system integrity of the vehicle.”
The concept of ISP, if implemented in RST TSIs, will not impact the
respective responsibilities of the different stakeholders, including the liability of
the product supplier, the responsibility of the applicant, the responsibility of
the rolling stock manufacturer, the responsibility of the end user (RU and
ECM).
5.6.4.
SUMMARY
The following issues relating to the use of spare parts are identified:
- When replacing a component by another component considered as ISP, it
shall be ensured that no new risk is introduced at rolling stock level.
The risk assessment to be performed by the initial applicant, by the user or
by the ECM requires a case by case analysis; the conformity to an EN
standard defining parameters for interchangeability may facilitate this
analysis.
- In case of partial interchangeability (level 1 or 2), the added value of the
conformity to such standard (verified under the responsibility of
manufacturer of the component) needs to be clarified.
- In many cases, a replacement may lead to the revision of maintenance
instructions (e.g. considering the result of “in service behaviour” tests), to
be done under the responsibility of the ECM. This is normal practice, and
interchangeability specifications (depending on their “depth”) may only
contribute to reduce such tests and maintenance rules revisions.
5.7.
CONCEPT OF ISP IN NORMATIVE DOCUMENTS AND IN RESEARCH
PROJECTS
5.7.1.
EN STANDARDS
Interfaces are covered in current EN standards, but in general,
interchangeability of components is not seen as a normative requirement, and
is not fully covered.
The following EN standards are listed as examples:
- EN 15020: “rescue coupler” (dimensions of coupler type 10 given as
informative)
- EN 15220-1: “brake indicator” (dimensions given as informative)
- EN 14535-2: “brake discs” (dimensions given as informative)
The standard EN 13979-1: “wheels” gives a checklist of aspects to be
considered in order to ensure interchangeability of wheels (see the case study
“wheel” in section 8.5); the approach is similar to those for IC in TSIs
(definition of area of use; see section 5.4.2).
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5.7.2
UIC LEAFLETS
UIC leaflets are widely used by the sector on a voluntary basis or in the
framework of agreements (former RIV, RIC). In UIC leaflets, interchangeability
is described as a mandatory requirement for particular components, but with
possible exemptions or limitations.
A global framework is described in the UIC leaflet 500: “Standardisation of
transport stock and components – Principles, procedures, results”.
This leaflet describes 6 standardisation degrees, including:
- Degree 1: qualitative and dimensional standardisation.
This degree covers the content and structure of a technical specification,
to allow comparisons between different components.
- Degree 2: compatibility.
This degree covers the compatibility between vehicles and track; it
corresponds to TSI requirements ensuring technical compatibility between
the vehicle and the network.
- Degree 4: unification.
This degree covers the most important characteristics (constitution,
functioning and use by customers, conditions for vehicle operation and
use).
- Degree 6: Standardisation.
This degree covers identical rolling stock or equipment based on a full set
of standard drawings.
For freight wagons, the UIC leaflet 570: “Wagons – Interchangeable spare
parts” list provisions governing interchangeability of spare parts, including as
examples:
- UIC 517: wagons – suspension gear - standardisation.
- UIC 526-1: wagons – buffers.
- UIC 542: Brake parts – interchangeability – brake blocks.
The approach developed by UIC shows the complexity of the concept of ISP,
even when applied in a framework allowing for more flexibility than regulatory
provisions (see also section 6.1.2 of this report).
5.7.3.
MODTRAIN PROJECT
The MODTRAIN project dealt with the functional, electrical and mechanical
interfaces and validation procedures as reference for interchangeable
modules, with more focus on functional subsystems than on maintenance and
spare parts.
It was a positive learning experience between RUs and manufacturers.
A functional breakdown structure was developed (standard EN 15380), which
is the basis for Eutreq (EU technical requirements database).
The outcome has contributed to the development of EN standards, some of
them covering interchangeability aspects.
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The MODTRAIN project is followed by an initiative from UNIFE and UIC to
develop technical recommendations (TecRec), considered as “pre-standards”
to be taken over by CEN/CENELEC.
Interchangeability (with levels as defined in section 5.3 of the present report)
is considered in the TecRec; however, there is not yet any return of
experience regarding this initiative.
5.7.4
OTHER NORMATIVE DOCUMENTS
Other normative documents are in use outside of EU, for example in the USA
(AAR specifications / FRA regulations): it appears that the freight sector in the
USA has a high level of standardisation, while other railway activities present
a level of standardisation comparable to that observed in EU.
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6.
ISP CONCEPTS ALREADY EXPERIMENTED
In the present section, we provide an overview of the ISP concept as has
been developed in the railway sector, or other transport modes.
6.1.
HISTORICAL BACKGROUND IN THE RAILWAY SECTOR
Note: section 6.1 is certainly no full, systematic investigation. Elements compiled here were
gathered from personal knowledge of the authors, web searches and telephonic interviews
with CER stakeholders.
We observe two approaches to interchangeable spare parts: bottom up, and
top down. Bottom up is by defining components with a huge range of
applications (example: UIC couplers). Top down would be by mass purchase
of rolling stock of a given type or from a given “platform”, or through common
specifications. Both are illustrated below.
Both success stories and failures are of interest, in particular the latter. This is
because “market failures” are one possible reason for political intervention,
either at Member State or at EU level, when appropriate.
6.1.1
TOP DOWN APPROACH
HST-E (high speed train for Europe):
HST-E is a project initiated by DB and SNCF, later joined by Trenitalia;
timeframe was approx. 2002-2005. Purpose was to establish common
specifications for high speed trains serving the European passenger market.
Rather than specifying “from scratch”, current specifications were compared.
The participants could agree on about 90% of the common specifications. The
remaining 10% could not be agreed upon, partly because different market
needs could not find a common solution, partly because present needs could
already be served by types available on the market (undermining the possible
economies of scale).
The successful part of the works could influence UIC 612-0 (Driver machine
interfaces) and derived leaflets UIC 612-x, all concerning drivers‟ cab
arrangement and displays. All other work on common specifications was (if at
all) used RU-internally, and are partly transposable to conventional (not: high
speed) multiple units.
The resources involved could be estimated at 5 to 6 full time equivalents per
RU. Supply industry was not directly involved, except at a very general
discussion level, or during the development of UIC 612.
EUROFIMA
From the EUROFIMA website [7/4/2011]:
EUROFIMA European Company for the Financing of Railroad Rolling Stock is a
supranational organization located in Basel, Switzerland. It was established in
1956 based on an international treaty signed by 25 European sovereign States so
far. EUROFIMA fulfils a non-profit maximizing mission to support the development
of rail transportation in Europe. It supports its shareholder railways as well as
other railway bodies in renewing and modernizing their equipment.
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This organization is still active, having by the way DB AG, SNCF and
FS S.p.A. holding 58.7 % of shares. Its recent activities are of the financing
nature. A past initiative is however worth mentioning in this context. From
http://de.wikipedia.org/wiki/Eurofima-Wagen we may quote:
… zu gleicher Zeit *197x+ reifte bei mehreren europäischen Bahnverwaltungen die
Idee, eine gemeinsame und standardisierte Wagenserie zu beschaffen. Beauftragt
wurde die UIC, welche die „Arbeitsgruppe Zukunft des Internationalen
Reisezugverkehrs“ eingerichtet hatte. Neben einem günstigeren Beschaffungspreis
durch eine gemeinsame Großbestellung als auch kostengünstigere Unterhaltung
durch standardisierte Bauteile wurde sich ein bedeutender Rationalisierungseffekt
erhofft.
[EN translation by the author:]
At the same time [197x], several European railway administrations came to the idea
of purchasing a common and standardized coach series. UIC was put in charge and
set up a “Working group about the future of international rail passenger transport”.
In addition to a more advantageous purchase cost through a common massive order,
and more economic maintenance by the means of standardized parts, they hoped for
a significant rationalization.
Following the realization of ten prototype coaches, a tender for 500 coaches
(for six end customers: DB, SNCF, SNCB, ÖBB, FS, SBB) was launched in
1976. The coaches were sold to EUROFIMA and leased back to the railway
companies, providing fiscal benefits to the end customers.
In order to secure the participation of industrial companies from the different
Member States, manufacturing was spread over different companies:
 Bogie: FIAT Ferroviaria
 Bodyshells: an Austrian manufacturer for 1st class, Fiat Ferroviaria
(Savigliano) for 2nd class
 Inner arrangement: from Germany (probably LHB)
 Static converters: from Jeumont Schneider (France)
 etc.
Variants were delivered according to class (1st / 2nd) and maximum speed
(160 / 200), with adaptation of braking and suspension systems (addition of a
magnetic brake, removal of brake shoes and addition of anti-yaw dampers).
Details about the tendering process could not be found. In particular, it is not
clear whether the industrial breakdown was decided in advance, and how.
The unit price anyway exceeded expectations by 25%, maybe a consequence
of the imposed industrial setup1. Additional orders for the same type were not
placed, so scale effects could not occur2. In parallel, massive orders were
placed by individual railway companies (e.g. SNCF Corail coaches, resulting
in nearly 4000 deliveries from 1975 to 1989).
1 We may find solace in the fact that Airbus and even Boeing are facing similar constraints.
The actual economic impact of such constraints remains to be evaluated.
2 Some follow-up orders for derived types were placed, based on national specifications.
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The other goal (lower maintenance costs) could also not be reached, given
the low numbers delivered.
Conclusion on top down approaches and their “failure”
Historically, national railway companies (most of them heavily involved in
basic and sometimes even detailed design) stroke a balance in favour of
national industrial interests, and further developed their “own” products.
Such interests may have partly receded by now, but competition on rail may
now be another disincentive to developing and using common specifications.
Significantly, a most recent case (Intercity Express, UK) is a state-run project,
in an otherwise quite liberalized economy.
Outlook
It is expected that top-down “standardisation” of rolling stock will rather occur
through “platform” concept. Easing the “platform” concept by rationalizing the
corresponding costs for placing in service of customized variants may be the
most sensible facilitating contribution of EU legislation to this concept. The
available instruments are type approval and partial certificates of conformity.
However, the “platform concept” is specific to each manufacturer, and may be
seen as a protective measure in the competition between manufacturers.
6.1.2
BOTTOM UP APPROACH
UIC components
ERA exchanged views with UIC about the role played by UIC leaflets in the
past, and the intentions of UIC in the future. To date, the result is the following
UIC statement:
Within the context of its primary mission of facilitating the conditions for the
sustainable development of rail as a transport mode, the UIC has developed common
measures, specifications and recommendations aimed at facilitating rail operations
and underpinning the foundation on which railways around the world are
constructed, operated and maintained.
These voluntary standards, known today as “leaflets”, are professional documents
that are the result of cooperation between experts of the member railway networks
of the UIC, more often than not in collaboration with other experts in the industry,
standardisation bodies, etc. Their content makes them of global value and they are a
reference for the entire railway community. They aim at unifying or standardising the
construction measures as well as the railway operating procedures with a view to
facilitating rail operations. They also allow UIC members and third parties purchasing
the standards to rationalise their operations and to lower their costs.
The documents are applied, according to their content, by railway undertakings,
infrastructure managers, industry, public works undertakings, etc. The measures they
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contain are often integrated into national norms, European norms as well as
invitations to tender for railway equipment.
They are furthermore a source of supporting technical applications facilitating
operations between networks. The UIC Leaflets coexist with the national and
international laws. In this context, it should be noted that they often act as a
reference and technical basis for drafting the norms and regulations decreed by
authorised bodies in Europe (ERA, CEN, CENELEC etc.) and around the world.
Many common components with varying interchangeability levels derive from UIC
leaflets: couplers, buffers and buffer heads (UIC 526-1, 527-1), brake pipe, data
transmission cable (UIC 568), etc., up to “standard bogies” such as the Y25 (with
many derived types) that equips a considerable part of the wagon fleets in Europe,
which is defined in UIC 510-1. (see also clause 5.7.2 of this report).
The pursued aims are variable: coupling ability, mechanical interchangeability
(example: buffers, where mechanical interchangeability provisions are made both for
buffers and for the headstock), etc. Leaflets may also include performance levels,
verification criteria in view of homologation, marking, etc.
The UIC and its members, conscious of the heritage value of the entire suite of
underpinning voluntary standards, are in the process of developing a programme that
will undertake a review of the some 700 documents that are currently contained
within the standards catalogue (UIC Code).
CER commented that UIC successes in the past were more in relation with
spare parts for wagons (couplers, buffers, wheels, etc.), rather than with
powered rolling stock, owing to prevailing national industrial interests
supported by incumbent companies. This situation may have changed
favourably.
Initiatives of individual railway undertakings
Initiatives were taken in the past by individual railway undertakings to tender
out a component on the basis of a common specification, in order to ensure a
double sourcing (examples: electro-valve for braking system; brake pads…).
These initiatives seem to have suffered from:
- the difficulty to provide a significant market share to each manufacturer,
- lack of in-house resources (on customer side) required for a shared
development and procurement, and
- the restructuration of the railway industry in order to face a more
competitive market not limited to the EU.
Outlook
As with the top down approach, the current problem seems to lie with the
fragmentation of customers and orders, together with the changed missions
of customer organisations.
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6.2.
CONCEPT OF ISP IN OTHER SECTORS
6.2.1.
EXAMPLE OF EU DIRECTIVES
ERA has analysed relevant extracts of the “Pressure equipment” directive N°
97/23/EC [11] and “Machinery” directive N° 2006/42/EC [12]; ISP are not dealt
with; interchangeability is addressed in the Machinery directive, but with a
different meaning (definition of interfaces for customized tools).
6.2.2
AUTOMOTIVE SECTOR
In the automotive sector, components used as spare parts for maintenance
can be classified in 2 groups:
- Components produced by “component suppliers”, that are not specific to a
particular type of vehicle; for these components, there is a wide market.
- Components produced by the vehicle manufacturer, that are specific to a
particular type of vehicle; up to now the vehicle manufacturer is the owner
of intellectual property rights for these components.
Considering the market of maintenance of automotive vehicles, this market is
driven by following issues:
- Maintenance works usually realised by a workshop recognised by the
vehicle manufacturer.
- References of spare parts available through the vehicle manufacturer.
Additionally, the automotive market being international, spare parts have been
produced worldwide, and have shown in some cases a degraded quality,
resulting in new safety risks for users.
6.2.3
AVIATION SECTOR
In the legislation in force in the aviation sector (i.e. document [13] section
titled AMC M.A.501), parts and appliances are sorted into two categories:
those that are type-related, and those having no direct link with a specific type
(example: radio or ATM devices) that are defined as “standard parts” with
certain conditions of use:
“To designate a part as a standard part the Type Certificate (TC) holder3 may issue a
standard parts manual accepted by the competent authority of original TC holder or
may make reference in the parts catalogue to a national or international specification
(such as a standard diode, capacitor, etc.) not being an aviation only specification for
the particular part.”
Full extract is given in Annex 4, and includes examples.
It appears that “standard parts” are identified in the technical documentation
issued by the type certificate holder (by a particular specification, or by
reference to standards).
3
In other words, the applicant
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Regarding intellectual property, departing from the original equipment
manufacturer induces a change approval. Patent, licensing and other
intellectual property issues remain purely in the contractual domain. In the
process of the change approval, the European Aviation Safety Agency only
checks that the submitted documentation is complete.
Transposed in the legal framework applicable to the railway sector, “standard
parts” would be defined in the technical file (see section 5.6.2 of this report),
under the responsibility of the applicant for an EC type certificate.
6.3.
SUMMARY
The various experiences in the railway sector and other sectors show that in
general, the standardisation of spare parts is driven by business.
Regulations ensure the transparency of mandatory requirements, and provide
a clear framework regarding the respective responsibilities of the different
stakeholders.
However, the number of manufacturers and the profile of customers are
specific to each sector (automotive, railway, aviation); these aspects have to
be taken into account in any comparison, and may justify specific regulations.
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7.
ECONOMIC ASPECTS
7.1.
GENERAL
Market opening and regulation are subject of several directives, including but
not limited to interoperability directive (2). The optimum level of technical
harmonisation to be achieved by TSIs is intended to (Error! Reference
source not found., Art. 1, 2 b – see also section 3 of this report):
“contribute to the progressive creation of the internal market in equipment and
services for the construction, renewal, upgrading and operation of the rail
system within the Community”
The concept of “interchangeable spare parts” has an effect on the market of
components. Spare parts economics are therefore addressed in the present
study on ISP, no matter if TSIs would be affected; the present section
explores the “why” and “how”.
Consistent with section 3.3 of this report, market failures are per se no
sufficient condition for EU regulatory intervention. The causes of market
failures need to be understood first.
7.2.
COST DRIVERS
7.2.1.
VENDOR LOCK-IN
Vendor lock-in is often invoked from the spare part customer side as a key
problem. There is evidence that alternate sourcing of particular spare parts
has resulted in about halving the unit prices. Such evidence first of all reveals
that “breaking out” is certainly possible without invoking EU law such as a TSI,
and without infringing existing laws and regulations.
However, the claimed benefits should not be taken at face value. Underlying
problems may be the following:
- the upfront cost of re-engineering may be high, significantly reducing
the benefits.
- the competence for re-engineering may be difficult to find, finance and
manage.
- there is a maintenance risk: the re-engineered products may turn out to
be less reliable than the original ones. The variety of operating and
maintenance conditions must therefore be taken into account.
- intellectual property issues may arise. Manufacturers have intensively
developed their patenting activities, especially in the nineties.
Indeed, manufacturers define their selling prices (original components and
spare parts) with consideration of these different aspects, and with hypothesis
on their future market. Overall, moving a spare part to some level of
interchangeability bears all characteristics of an investment and a project, with
initial costs, constraints, risks, and an expected return. Whether such projects
are worth undertaking, requires a preliminary analysis of the above.
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7.2.2.
TECHNICAL AND COMMERCIAL OBSOLESCENCE
Railway vehicles are still relatively long-lived in comparison with the new
technologies they host (control systems, IT backbones, HVAC, etc.).
Providers of these new technologies (vehicle suppliers and original equipment
manufacturers „OEMs‟) may themselves withdraw from particular markets or
disappear. When parts are supplied by OEMs, vehicle suppliers are as much
exposed to these uncertainties as their customers4. This results in increasing
manufacturing costs and risks, overall decreasing the competitiveness of the
railway system. One may therefore expect “market forces” to lead to some
“standardisation” of OEM parts (including some level of interchangeability),
but not of systems manufactured by the vehicle supplier himself.
Drawing a parallel with the aviation sector, we may also quote here from (10).
Under the “practical examples” section, this study mentions:
DASA-Airbus estimated the price ratio between customized and standardized
components as being 15:1, with half of the customized components being suitable
for standardization. By switching to standardized components the company could
reduce its purchases by 10% (source: DIN Aerospace Standards Committee”)
The scope of „components‟, in this case, is wider than „Interchangeable spare
parts‟. The situation in rolling stock manufacturing industry is probably similar.
7.2.3.
COST OF DIVERSITY / ECONOMIES OF SCALE
Independently from “monopolistic behaviours” or “obsolescence”, one may
observe that the railway market fragmentation is per se a cost driver. The
fragmentation results from numerous rolling stock types (tailored to particular
customers that also tend to become more numerous). Massive orders also
have become rare: the above mentioned 500-coaches order that was
relatively small in the seventies would be perceived as massive nowadays.
According to verbal testimonies, a particular railway undertaking estimated
(not for the purpose of the present study) that a reduction of wheelset diversity
in their fleet could bring about 30% internal cost savings (inventory
management, purchasing, etc.), and a further 8% due to scale effects5. Given
that wheelsets are the top spare parts expense in rolling stock life cycles 6, this
statement is particularly significant.
Excessive diversity also means, from the suppliers‟ point of view, involvement
of sales and engineering forces in activities that does not necessarily
contribute to quality or innovation – a wasteful use of valuable resources.
4
It is not seldom that customers would include contractual 10-year guaranties of availability of
supplies for key, short-lived components, in order to transfer some of the risk to the manufacturer.
5
all figures awaiting confirmation and supporting evidence.
6
This statement applies to repairable spare parts. As far as consumables are concerned, brake
pads (especially for high performance disk brakes) may come on top, depending on applications.
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7.2.4.
MAINTENANCE COSTS
Interchangeability of parts in the process of overhauls can be a way to
overcome the obsolescence of parts.
Benefits can also be expected from interchangeable spare parts as line
replaceable units (reduction of time to repair).
In both cases, benefits of interchangeability are dependent on the
maintenance methods and tools (sometimes strongly - axle and wheel design
take maintenance tooling constraints into account, for instance). Any
development of spare parts specifications should therefore be preceded and
supported by the analysis and harmonisation of corresponding maintenance
requirements.
As evoked above (EUROFIMA coaches), maintenance benefits expected from
common specifications and procurement do not always materialize.
Interchangeability of spare parts is secondary to overall fleet sizes and spare
part inventory reduction.
7.2.5
ABOUT STANDARDISATION COSTS
Defining interchangeability requirements at European scale is certainly a
challenging task. Past ERA work on relatively trivial subjects (brake hoses,
pantograph contact strips) showed the difficulty to come to a consensus on
materials for instance, in relation with climatic conditions or wear & tear.
Developing interchangeability requirements (above level 1) could therefore be
assimilated to the development of an “average” to “difficult” standard.
Typically, the development of a standard would take 3 to 5 years. The overall
costs of developing such a standard are difficult to estimate; quoting from [10]
, section 4:
“The interviews with experts *…+ revealed that the cost of developing company
standards and industry-wide standards are not easily quantified.”
…and indeed no figures are provided in that section of the report [10]. Derived
for this report [10], as an order of magnitude, we could however retain 10 M€,
or 2M€ to 3M€ per year over 5 to 3 years, for each standard; this represents a
significant amount compared to the ERA budget.
This amount might be fully justified with regards to expected benefits.
The works in this field may rely on mandates to standardisation bodies, as
suggested by CER (see section 5.1 of this report).
In any case, this work would require an intense participation of the railway
industry.
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7.2.6
OUTLOOK
ERA has been provided a list of candidate “interchangeable spare parts” of
very different nature (list attached in annex 3). This list is not necessary to
make the economic case for interchangeability – the sole case of wheelsets
seems clear enough. No matter how the concept of interchangeable spare
parts may be accommodated into the TSIs, this list raises the question of
prioritisation.
ERA would like to point out that an open, shared, systematic approach (cost
breakdown structure for rolling stock) is necessary, in order to identify:
- What components currently have what interchangeability level (e.g. using
the levels definitions proposed by CER)
- What the corresponding life cycle costs are (design stage, maintenance,
overhauls, disposal)
- What interchangeability level could reasonably be targeted
o Taking into account patents, intellectual property rights, etc.
o Taking into account operating and maintenance conditions
o Taking into account harmonized maintenance requirements, where
relevant
- The corresponding, expected benefits as a function of
o Current / potential suppliers (market opening perspective)
o Fixed costs for transaction, development, certification (antagonistic)
- The likely effort to reach the desired interchangeability level
o Involving preliminary studies and most certainly CEN / CENELEC
work.
The missions of ERA as defined in the Agency regulation [4] do not foresee a
leading role in this approach, which is in the field of competence of railway
manufacturers and operators.
However, some stakeholders acknowledged that a “transparent” selection
process for candidate ISPs to be covered by EN standards could be an added
value from ERA.
Whether any intervention in any form of EU legislation (e.g. codified in TSIs)
would respect the proportionality principle (see section 3.3 of the present
report), needs at first an evaluation of the expected benefits. Benefits can only
be estimated case by case.
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8.
CASE STUDIES
8.1.
PURPOSE AND SELECTION OF CASE STUDIES
As illustrated in the sections 5.2 and 5.3 of the present report, and in its annex
3, spare parts are used for components of different nature and complexity.
In order to investigate more deeply on the relevance and technical feasibility
to include the concept of ISP in the rolling stock TSIs, ERA has considered as
necessary in this study to analyse how this concept could be established on a
few examples of spare parts, and set priorities according to the expected
harmonisation.
To that end, ERA has asked to representative bodies to provide such
examples. CER proposed the following examples:
-
cab display interface with TCMS (excl. ETCS display)
contact strip
door control (train level, consist level, local control)
These examples were refined by a dialog between ERA and CER; ERA
suggested to take the wheel as additional example applicable to freight
wagons (this example was identified as one of interest in the presentation
given by CER in the preparatory meeting held on 01/03/2011, and is listed in
annex 3).
8.2.
CAB DISPLAY UNIT
Clarification
The current CR LOC&PAS TSI specifies a functional requirement in the
clause 4.2.9.3.3 regarding the proper use and reaction from the driver.
This general requirement applies to the display unit or screen as component
(characteristics independent of any application that ensure proper use,
visibility…), and to the application (design of pictograms and views, refreshing
time,…).
The RFS N° 22 (integration of screens) covers the aspect of installation to
ensure a proper visibility, and the RFS N° 23 (design of displays / views)
covers the application (software development); they were both issued by ERA
(after having been drafted with the sector in the WP CR LOC&PAS).
ERA understands that the definition of a “display unit or screen” as ISP should
be independent of any application; it should cover the hardware (including
physical and communication interface to the TCMS, and mechanical interface
with the driver‟s desk) and its operating system (if any; including
communication protocol). The software developed for a particular application
is not in the scope of the ISP. The 2 on-going RFS mentioned above do not
contribute to the concept of ISP.
The ISP would be defined as a line replaceable unit, and the objective should
be to reach interchangeability level 3 (plug & play), or level 2 with minor
mechanical adaptations.
The software specific to a particular application (train), which is not in the
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scope, may have to be re-developed for each hardware environment.
The benefit of such interchangeability would depend on the reliability of the
hardware (compared to the lifetime of the TCMS system and of the train), on
the risk of obsolescence, and on the feasibility and cost to re-develop the
software for a particular application.
If adaptations are needed from TCMS side, no benefits are expected.
The “railway specific” characteristics are not predominant. In case
components available on the market and used in other sectors are available,
they should be preferred.
Description
The definition of a “display unit or screen” as ISP covers the hardware,
including physical and communication interface to the TCMS, mechanical
interface with the driver‟s desk) and its operating system (if any). The software
developed for a particular application is not in the scope of the ISP.
The clause 4.2.9.3.3 of the CR LOC&PAS TSI applies to this component:
”the information or commands to be used by the driver to control and command the
train, and given by means of display units or screens, shall be designed to allow
proper use and reaction from the driver”.
The ISP is defined as a line replaceable unit, and the objective should be to
reach interchangeability level 3 (plug & play), or level 2 with minor
mechanical adaptations.
The ISP has no significant impact on vehicle system design or on safety
(software developed for a particular application is out of scope).
Information provided
CER provided information on cab display units (CDU) of the DB rolling stock
fleet.
Among 20 000 CDUs, 30 different types are identified, from 8 different
suppliers; 2 of these suppliers provide each more than 6 different types of
CDUs.
Analysis
The reasons for having these different types of CDUs are not given; the
following reasons may be guessed:
- Lifetime of a CDU type, shorter than the lifetime of a rolling stock.
- Use of CDU types available on the market, and not railway specific, for
economic reasons.
- Use of the latest technology, for technical reasons, and to limit the risk of
obsolescence.
Anyway, the figures show that “interchangeability” might be improved
internally between 1 customer (DB) and 1 supplier, by a reduction of the
number of types or by ensuring their compatibility, without need for additional
regulation.
The process followed to design a TCMS and driver‟s cab application, and
particularly to specify and select a CDU as component, which is in the field of
activity of train manufacturers, seems to be the more efficient framework to
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analyse and reach a certain level of interchangeability; this process is
influenced by the specification of end users (RUs, as customers).
In this context, a provision in the RST TSI covering interchangeability of CDU
does not appear to ERA as being a key element.
8.3.
CONTACT STRIPS
Clarification
In the HS RST TSI and in the CR LOC&PAS TSI, contact strips are defined
as interoperability constituent, part of the pantograph which is also defined as
interoperability constituent.
The following standards are identified in the TSI:
- EN 50405:2006 “testing methods for carbon contact strips”.
The RFS N°24 issued by ERA (after having been drafted with the sector in
the WP CR LOC&PAS) requires that this standard covers also other
material; the standard should be applicable to any contact strip.
- EN 50206-:2010 “pantographs: characteristics and tests”.
Additionally, the 2 open points “contact strip material” and “automatic dropping
device” have an impact on the design of contact strips.
Therefore, certain technical characteristics of the contact strips are already
specified and harmonised by the TSI, and the closure of open points may
complement the specification.
The case study should evaluate the benefits expected from the
standardisation of the geometry and the mechanical interfaces (including
pneumatic one for ADD) of contact strips; the impact on the design of
pantograph heads should also be evaluated.
Description
The clause 5.3.8.1 of the CR LOC&PAS TSI defines characteristics relevant
for the area of use of contact strips:
“Contacts strips shall be designed and assessed for an area of use defined by:
 Their geometry, as defined in clause 4.2.8.2.9.4.1.
(note: this clause specifies the 2 pantograph head geometries).
 The material of the contact strips, as defined in clause 4.2.8.2.9.4.2.
 The type of voltage system(s), as defined in clause 4.2.8.2.1.
 The current capacity, as defined in clause 4.2.8.2.4.
 The maximum current at standstill for DC systems, as defined in clause
4.2.8.2.5.
The requirements specified above in this clause shall be assessed at IC level.
In addition, for contact strips made of carbon or of impregnated carbon, a conformity
assessment as specified in clause 6.1.2.2.7 shall be carried out.”
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The ISP is defined as consumable at maintenance level; the level of
interchangeability already reached by the TSI and EN standards corresponds
to level 2 (adaptable); therefore, the objective would be to reach
interchangeability level 3 (plug & play).
To that end, the geometry and mechanical interface of contact strips with the
pantograph should be covered by a standard.
The ISP has no significant impact on vehicle system design or on safety.
Information provided
CER provided information on contact strips of the UK rolling stock fleet, and of
SNCF rolling stock fleet.
UK:
- Total number of pantographs that equip the fleet: 1271.
- Number of different types of pantographs. 5 (25 kV) + 1 (1500 V DC).
- Number of different types of contact strips: 1 or 2 per type of pantograph.
SNCF:
- Total number of pantographs that equip the fleet: 8200.
- Number of different types of pantographs. 37.
- Number of different types of contact strips: 13.
The different types correspond to different IC “area of use”.
Analysis
The reasons for having these different types of contact strips seems directly
linked to the different types of pantographs (bow length, voltage, current
capacity, HS or CR).
In UK, new types with a different mechanical interface were developed in
order to improve reliability and wear life.
In this context, a provision covering interchangeability of contact strips in the
RST TSI does not appear to ERA as being a key element.
8.4.
DOOR CONTROL
Clarification
Further to the proposal from CER, ERA pointed out that the example “door
control” would be too complex to be properly covered in the framework of the
complementary study. A spare part is supposed to be a replaceable
component, and should be defined as such; there are many different design
architectures for door control systems; if the purpose is to harmonize the
design, this may be done by imposing technical rules in the TSI; the concept
of ISP is only applicable when the technical solution to cover a function is
sufficiently harmonised.
After some exchanges by e-mail, CER indicates that their proposal is to cover
the DCU (electronic board for the control of individual doors).
The current TSIs specify functional requirements (e.g. CR LOC&PAS TSI
clause 4.2.5.6); the standard EN 14742:2005 covers passenger doors, and
refers to general standards for electronic components.
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This case has similarities with the case 1) above, but also differences.
ERA understands that the definition of a DCU as ISP should cover the
hardware (including physical/communication interface to the TCMS, and
mechanical interface with the vehicle) and its operating system (if any).
It has to be clarified if it could cover also interfaces with door actuators and
sensors, and be independent of the door itself; sensors and actuators in
interface to the DCU may be different (electric motor, electro valve…).
The software developed for a particular application (door system and train
management) could be handled separately as an “ISP”, but not globally
together with the hardware part.
The ISP would be defined as a line replaceable unit, and the objective of
interchangeability level is still to be defined.
The benefit of such interchangeability would depend on the reliability of the
DCU (compared to the reliability and lifetime of the door system), on the risk
of obsolescence (including door actuators and sensors), and on the feasibility
and cost to re-develop the software for a particular application.
In order to study economic aspects, a clear reference case (today situation)
needs to be available.
Description
The definition of a DCU as ISP covers the hardware, including
physical/communication interface to the TCMS, mechanical interface with the
vehicle) and its operating system (if any), and interfaces with door actuators
and sensors.
Depending on the architecture of the door system, sensors and actuators in
interface to the DCU may be different (electric motor, electro valve…); this
may lead to the definition of characteristics defining the area of use of the ISP
(electric or pneumatic control, type of sensor for obstacle detection…).
The ISP is defined as a line replaceable unit, and the objective of
interchangeability level is still to be defined
It has complex interfaces, and therefore may have significant impact on the
door system design.
Information available
Each door supplier seems to have its own design for DCU.
Analysis
The DCU fits to the architecture and the design of the door system; the TSI
specifies functional requirements, and the various possible technical solutions
should not be imposed; they may be addressed in standards.
In this context, a provision covering interchangeability of DCU in the RST TSI
does not appear to ERA as being technically feasible.
8.5.
WHEEL
Clarification
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The 3 case studies above do not apply to freight wagons; this additional case
study is considered because applicable also to freight wagons (significant
fleet, and RIV experience).
The study should identify why the existing technical framework (see
description below) is not fully applied, and therefore does not bring the
expected benefits.
Description
The clause 5.3.2 of the CR LOC&PAS TSI defines characteristics relevant for
the area of use of wheels (similar clause in other TSIs):
“A wheel shall be designed and assessed for an area of use defined by:
 Geometrical characteristics: nominal tread diameter.
 Mechanical characteristics: maximum vertical static force, maximum speed
and service life.
 Thermo mechanical characteristics: maximum braking energy.
A wheel shall comply with the requirements on geometrical, mechanical and thermo
mechanical characteristics defined in clause 4.2.3.5.2.2; these requirements shall be
assessed at IC level.”
Interchangeability is covered in the standard EN 13979-1:2003+A1:2009 (E)
“Monobloc wheels - Technical approval procedure - Part 1: Forged and rolled
wheels”, clause 3.1 “Parameters for geometrical interchangeability”:
“3.1 Parameters for geometrical interchangeability
The application shall be defined by geometrical interchangeability parameters divided
into three categories according to whether they are linked to functional, assembly or
maintenance requirements.
3.1.1 Functional requirements
- the nominal tread diameter that influences the buffer height and the loading gauge;
- the maximum rim width linked to the points and crossing and the track brakes;
- the tread profile outside the conical part of the tread;
- the position of the rim internal surface relative to the corresponding surface of the
hub;
- the conicity of the hub bore;
- the space required for disc brakes mounted on the wheel;
- the space needed on the bogie frame, braking equipment and suspension equipment.
3.1.2 Assembly requirements
- the bore diameter;
- the hub length to ensure overhanging of the hub on the wheelseat.
3.1.3 Maintenance requirements
- the wear limit diameter or the last reprofiling diameter;
- the wear groove shape;
- the geometry of the area for wheel clamping on reprofiling machines;
- the position and shape of the hole and groove for displacement under oil pressure;
- the general rim shape to allow ultrasonic measurement of residual stresses in wheels
braked by shoes.”
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The ISP is defined as consumable at maintenance level; the level of
interchangeability already reached by the TSI and EN standards corresponds
to level 2 (adaptable); therefore, the objective would be to reach
interchangeability level 3 (plug & play), by application of the clause 3.1 of
EN 13979-1 (with developments if required).
Information provided
CER provided information on the different types of wheels of the DB rolling
stock fleet. There are more than 30 different wheel types; nearly every train
type uses a specific type of wheel (CER statement not specific to freight
trains, for which the degree of harmonisation is higher).
Additionally, a CER member also reported that interchangeability of spare
parts in the field of freight wagons is managed with UIC leaflets without any
major difficulty.
Analysis
The IC “wheel” specification already included in RST TSIs, and the available
EN standards, provide already a framework in order to cover
interchangeability of wheels.
The checklist provided in the EN standard issued in 2003 identifies all
parameters to be considered for interchangeability level 3, and illustrates why
there are different types of wheels; it is unclear why this standard has not yet
contributed to the expectations of CER; in this context, the benefit of further
steps to be taken on board by standardisation bodies is questioned.
8.6.
SUMMARY
For interoperability constituents, for which a conformity assessment against
the TSI is required and justified by essential requirement(s) of the
interoperability directive, actual legal provisions should contribute to the
development of a market of components; there is not yet a sufficient return of
experience to evaluate this effect.
As pointed out during the drafting process of the CR LOC&PAS TSI, it is
primordial to define in the TSI the “area of use” of the interoperability
constituent, and the EC certificate shall cover the parameters defining this
“area of use”, that are in interface with the rolling stock subsystem. EN
standards should provide the means to assess these parameters.
In case of components that may be not specific to rolling stock (cab display
unit), the benefit (in terms of open market) from an EC certificate in the TSI
framework is questioned.
In case of components to which no TSI requirement apply, and that are
included in complex systems (door control unit), the tentative to hamonise
interfaces would certainly lead to the definition of a complex “area of use” that
would make the conformity assessment very difficult, independently from the
door system itself.
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9.
CONCLUSIONS
9.1.
PROPOSAL ON HOW ISP SHOULD BE MANAGED
The concept of interchangeable spare parts can already be used in the
current framework.
ERA would suggest:
- Actually using the technical file as reference for maintenance activities,
including identification and/or specification (when technically feasible) of
spare parts.
- Implementing in full the concept of interoperability constituent, as planned
by the interoperability directives since 1996 and specified in RST TSIs,
and evaluating its effect on the market of components.
- Implementing the rules described in the regulation on system of certification
of ECM [8], so that their responsibility when they select a spare part, and
the responsibility of the applicant having issued the technical file, are
clearly identified.
The existence of EN standards covering interchangeability levels of spare
parts as defined in the present report would facilitate the development of this
concept; concerned stakeholders of the railway sector have already taken
initiatives, and may address any request to standardisation bodies on this
matter. ERA would welcome such initiatives to have these standards drafted.
9.2.
PERTINENCE OF PROVISIONS ABOUT ISP IN RST TSIS
From a legal point of view, the specification of the ISP being seen as an
optional requirement with no link to the essential requirements of the
interoperability directive, the TSI is not seen to be the right support; standards
applied on a voluntary basis seem to be the relevant support.
Provisions about ISPs in RST TSIs would lead to an EC certificate covering
their interchangeability; such certificate may lead to uncertainties regarding
the respective responsibilities of the stakeholders (manufacturer, applicant,
RU, ECM), in particular for “partial” interchangeability (levels 1 and 2).
For “full physical and functional” interchangeability (level 3), the technical
feasibility to draft EN standards defining the relevant specifications and
technical characteristics that would make possible the assessment of
conformity (resulting in an EC certificate) is not demonstrated; this should be
done before taking any decision regarding additional provisions in RST TSIs.
From a technical point of view, the definition of additional regulatory technical
specification covering interchangeability, without any link to essential
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requirements from the interoperability directive, would be difficult to achieve in
a transparent and non-discriminatory way.
From an economic point of view, the global effect on the market of an
“optional” provision in RST TSIs describing 3 possible levels of
interchangeability, and referring to EN standards to be drafted, cannot be
evaluated; economic aspects can only be assessed on a case by case basis.
Considering these different aspects, ERA concludes that RST TSIs should not
include any additional specific provision regarding interchangeability of spare
parts above those that may already be indirectly covered in the current
framework.
This conclusion has no impact on the current ERA work programme [7].
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10.
ANNEXES
Annex 1
Questionnaire to NSAs, RBs, NB-Rail (NoBos)
Annex 2
Summary of answers to the questionnaire
Annex 3
Proposals from the sector for ISP (list from CER)
Annex 4
Aviation sector – Extract from AMC M.A.501 (c) Installation
Annex 5
Comments received to the preliminary report (to be included in
the final report in case comments are received from the
stakeholders)
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Annex 1: Questionnaire on the issue of Interchangeable Spare Parts (ISP)
1.
General information
1.1. Introduction
The European Railway Agency (ERA) has to carry out several complementary studies in
relation to the Mandate from the European Commission (Commission Decision
C(2010)2576 final for extending the scope of the technical specifications for interoperability
(TSIs) in accordance with Article 8(2) of Directive 2008/57/EC), in particular the study
defined in Point 2.2(d) of the Annex of the Mandate:
“d) Complementary study on the issue of the interchangeable spare parts, aimed at
ascertain whether the TSIs related to the rolling stock subsystem should include specific provisions
about these spare parts.”
The purpose of the study is shortly described in the ISP reference document provided with
this questionnaire; in particular, the concept is described, and definitions are given.
The planned delivery date of the study is 4 May 2011 (Point 3.2 of the Annex of the
Mandate).
ERA has prepared this questionnaire in order to collect information related to legal aspects
that have to be analysed in this study on „interchangeable spare parts‟.
The aim is to receive the opinion of the stakeholders regarding the possible evolution of the
legal framework (TSIs) that regulates the conformity assessment: „EC‟ declaration of
conformity (constituents) and/or „EC‟ declaration of verification (rolling stock).
The questionnaire is distributed to all representative bodies, the national safety authorities
of the EU and EEA Member States and NB-Rail, in order to get a feedback from the
stakeholders who might be impacted in their activity by a potential regulation of some spare
parts related to rolling stock: national safety authorities, railway operators, entities in charge
of maintenance, suppliers of RST and of spare parts, notified bodies etc.
This questionnaire is not the unique source of information for ERA to perform the study; in
particular, the concerned representative bodies have already expressed their expectations
to the Commission or to the Agency, and have provided technical and economic data; ERA
has already met these organisations to define how this data will be used for the purpose of
the study.
ERA will appreciate very much your answers by 31 March 2011and thanks you in
advance for your responsiveness.
1.2. Information about respondent
1.3. Data protection statement
Any personal data processed for the purpose of questionnaires shall be processed
pursuant to Regulation (EC) No 45/2001 on the protection of individuals with regard to the
processing of personal data by the Community institutions and bodies and on the free
movement of such data.
It shall be processed solely for the purposes of communicating with the respondents to
clarify responses, if necessary. The data subject shall have the right to access his personal
data and the right to rectify any such data that is inaccurate or incomplete. Should the data
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subject have any queries concerning the processing of his personal data, he shall address
them to the entity acting as data controller, i.e. the Head of the Interoperability Unit of the
European Railway Agency. The data subject shall have right of recourse at any time to the
European Data Protection Supervisor.
2.
Questionnaire
A. Technical aspects relating to „interchangeable spare parts‟
Question A.1: do-you think the components to which the concept of „interchangeable spare
parts‟ may apply should be listed in the rolling stock TSIs?
Question A.2: do-you think the concept of „interchangeable spare parts‟ should apply
exclusively to components listed as such in the rolling stock TSIs?
Question A.3: do-you think the specification for the verification of the „interchangeability‟ of
spare parts should be available through the TSIs?
Question A.4: do-you think the specification for the verification of the „interchangeability‟ of
spare parts should be available through the technical file of the concerned rolling stock
(kept by the Applicant, with a right of use for the user of the rolling stock)?
Question A.5: do-you think the specification for the verification of the „interchangeability‟ of
spare parts should be available through EN standards?
Question A.6: after its placing in service, a rolling stock is often subject to a number of
modifications (during its lifetime); how in your mind is-it possible to ensure that the
specification for the verification of an „interchangeable spare part‟ remains relevant from a
legal point of view?
B. Conformity assessment procedure for „interchangeable spare parts‟
Question B.1: what benefits do-you expect from a regulated conformity assessment
procedure of „interchangeable spare parts‟? (quality of the maintenance, rolling stock
maintained in safe operating conditions, efficiency of the railway system, opening of the
market...)
Question B.2: which entities should be involved in the conformity assessment of
„interchangeable spare parts‟: Applicant, Manufacturer, ECM, Notified Body, NSA...?
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Question B.3: in case the NSA should be involved, how do-you define its role?
Question B.4: do-you think an „EC‟ declaration of conformity (by similarity to ICs) should be
required for „interchangeable spare parts‟, independently of any rolling stock project?
C. Current practice
Question C.1: what is your current experience related to the development of
interchangeable spare parts in your scope of activity?
Question C.2: have-you met difficulties? If yes, do-you have a proposal for improvement?
D. Other comments
Do you have any additional comments related to the above issues?
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Annex 2: Summary of answers to the questionnaire.
List of respondents
Answers were received from the following organisations:
 NSAs:
Answers were received from NSAs from 12 Member States: Austria, Bulgaria,
Denmark, Estonia, Finland, France, Latvia, Lithuania, Luxembourg, Romania,
Slovenia, and Spain.
 Representative Bodies:
Answers were received from CER and UNIFE.
 NB-Rail and NoBos:
No answer was received
It has to be noted that the opinions expressed by the organisations consulted by the
questionnaire represent one input that has to be balanced by the conclusions of the
general qualitative analysis carried out by ERA (see report).
Summary of answers
1.
TECHNICAL ASPECT (QUESTIONS A1 TO A6)
This series of questions aims at evaluating, from the organisations‟ point of view in which
kind of technical document the specification of the “interchangeable spare parts” should be
found.
NSAs
5 NSAs answered that the TSI should not include any list of ISP.
Among them, 1 NSA answered that the TSI should include a definition of ISP (including
traceability requirements).
7 NSAs answered that the TSI should include a list of ISP.
Among them, 4 NSAs answered that the concept of ISP should apply exclusively to the
components listed in the TSI, and one more (total 5) answered also that the specification
for the verification of the ISP should be available through the technical file; 3 NSAs
answered also that it should be available through EN standards.
Representative Bodies
CER answered that the TSI should include a list of ISP, and that the concept of ISP may
also apply to other components (not listed), based on EN standard or UIC leaflets. The
information given in the technical file should be limited to the use (or not) of the ISP
(concept considered ass optional).
CER view is that for ISP where interfaces specifications can be easily described, this
should be directly given in the TSIs. For more complex ISP, TSIs should describe the
functionalities and list the different interfaces to be taken into account (mechanical /
electrical …) and then refer to standards for the detailed specification.
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UNIFE is not in favour of any additional regulatory provision regarding ISP (no clear legal
basis).
NB-Rail (NoBos)
No answer received.
2.
CONFORMITY ASSESSMENT (QUESTIONS B1 TO B4)
This series of questions aims at evaluating, from the organisations‟ point of view what are
the benefits expected from a regulated conformity assessment procedure of
“interchangeable spare parts”.
NSAs
The 5 NSAs who answered negatively to question A have not identified any benefit
(consistent answer).
The 7 NSAs who answered positively to question A have mentioned “opening of the
market” and “increase of quality” as benefits (consistent answer).
Representative Bodies
CER answered that they expect the opening of the market leading to better quality and
lower price; the conformity assessment procedure should be similar to those applied for
ICs.
UNIFE answered that they see no benefits; safe operating conditions could be jeopardised
(if reliability of certain ISPs not satisfactory); new entrants on the ISP market may be
discouraged (small volumes offered by the railway market).
NB-Rail (NoBos)
No answer received.
3.
CURRENT PRACTICE (QUESTIONS C1 TO C2)
This series of questions aims at getting background information on the concept of
“interchangeable spare parts.
NSAs
The 5 NSAs who answered negatively to question A1 have not met any difficulty (they don‟t
deal with ISP). 1 NSA mentioned that the sector should deal with the issue of ISP (former
RIC; annex to CUU).
Among the 7 NSAs who answered positively to question A1, 4 NSAs answered that they
have no experience; 2 other NSAs answered that the subject is not well defined / regulated;
1 other NSAs reported positive experience for freight wagons.
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Representative Bodies
CER answered that several RUs are working on de-specialisation of spare parts to reduce
costs; it works at company level, and bigger effect is expected at EU level.
UNIFE answered that they are involved with UIC in a process of voluntary standardisation,
judged as satisfactory; only one difficulty was reported (lack of involvement of operator‟s
experts, including those from maintenance services).
NB-Rail (NoBos)
No answer received.
4.
OTHER COMMENTS (QUESTION D)
This question gives the possibility to the respondent to complement his answer.
NSAs
1 NSA considered that the concept of ISP is very similar to the concept of IC, therefore
they don‟t see the need for the creation of an additional category of components.
2 NSA mentioned possible additional difficulties with the concept of ISP in case of
exchange of RST with 3rd country, particularly for freight wagons (regulation from the 3rd
country to be applied, or UIC code).
Representative Bodies
No additional comment reported.
NB-Rail (NoBos)
No answer received.
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Annex 3: CER current proposal for ISP “candidates”
The list below identifies components for which a specification for interchangeabiltity is
envisaged, classified according to priority level.
• Axles
• Brake discs
• Contact strip for pantographs
• Wheels
• Wheelset bearings
• Battery and battery charger
• Brake pad and brake pad holder
• Odometry
• Wheelset
• Secondary damper
• Labelling inside the train for passengers
• Air compressor
• Slack adjuster
• Wheelset bearing condition monitoring
• Displays
• Door actuator for external door
• Air-drying installation and air treatment
• Brake block, Brake block shoe and Brake block shoe key
• Brake indicator
• Driver's desk control elements
• Sanding equipment and sand
• Head and tail lights
• Horn
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Annex 4 – Extract legislation Aviation sector [13]
AMC M.A.501 (c) Installation
1. Standard parts are:
(a) parts manufactured in complete compliance with an established industry, Agency,
competent authority or other Government specification which includes design,
manufacturing, test and acceptance criteria, and uniform identification requirements.
The specification should include all information necessary to produce and verify
conformity of the part. It should be published so that any party may manufacture the
part. Examples of specifications are National Aerospace Standards (NAS), Army-Navy
Aeronautical Standard (AN), Society of Automotive Engineers (SAE), SAE Sematec,
Joint Electron Device Engineering Council, Joint Electron Tube Engineering Council,
and American National Standards Institute (ANSI), EN Specifications etc…
(b)…Examples of equipment which can be considered standard parts are electrical
variometers, bank/slip indicators ball type, total energy probes, capacity bottles (for
variometers), final glide calculators, navigation computers, data logger / barograph /
turnpoint camera, bug-wipers and anti-collision systems.
Equipment which must be approved in accordance to the airworthiness code shall
comply with the applicable ETSO or equivalent and is not considered a standard part
(e.g. oxygen equipment).
2. To designate a part as a standard part the TC holder may issue a standard parts
manual accepted by the competent authority of original TC holder or may make
reference in the parts catalogue to a national/international specification (such as a
standard diode/capacitor etc) not being an aviation only specification for the particular
part.
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Annex 5 – Comment received on preliminary report:
Comments from Member States:
After the presentation given to Member States in the interoperability committee on
09/06/2011, Member States have not expressed any disagreement to the conclusion
expressed by ERA in the preliminary report.
Comments from Representative bodies:
- CER has expressed the following position (extract of the position paper dated 17/06/2011
received from CER):
“CER finds it important to recognize that
• the current level of technical harmonization, developed on the basis of ERA recommendations
and adapted by the commission assisted by the committee established by Article 21 of Directive
96/48/EC, does not provide the necessary contribution “to the progressive creation of the
internal market in equipment and services for the construction, renewal, upgrading and
operation of the rail system within the Community” as requested by Article 1.2(b) of Directive
2008/57
• the market players themselves fail to develop a functioning market, which weakens the
competitiveness of the European railway transport mode versus other modes of transport
• a stronger role of the ERA is needed to overcome this situation.
CER seriously doubts the concept of interchangeable spare parts being applicable in the current
framework.
Instead, CER asks ERA to manage ISPs in the following way: ERA shall carry out a
“transparent” selection process for candidate ISPs:
1. impact assessment to understand the benefits for the whole railway sector and the scope of
the standardisation needed
2. issue a request for standard to the ESOs and define priorities
3. monitor the progress of the standardisation organisations in developing the standard
4. if the standardisation organisations do not deliver on time, ERA has to task themselves or a
consultant and propose the result to the appropriate ERA working party and include the results
(after study by this working party) in the TSI as an optional annex.”
- UIP, UITP and UNIFE have expressed their agreement with the conclusion made by ERA.
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