ERA-GUI-100.pdf - Europa
ERA-GUI-100.pdf - Europa
ERA-GUI-100.pdf - Europa
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Guide for the application of the Art 14 (a) of the Safety Directive and Commission Regulation (EU) No 445/2011<br />
on a system of certification of entities in charge of maintenance for freight wagons – VERSION 1.0<br />
procedures outlined by a RU in its SMS, including those for the exchange of information<br />
(See recital (6) of ECM Regulation).<br />
The RU shall implement any other additional control measures that it considers necessary to keep<br />
the identified risks related to the supply of maintenance under control. Those risks could be<br />
highlighted through a structured approach to risks assessment and a systematic analysis of<br />
findings related to the routine monitoring put in place by the RU as part of its SMS arrangements.<br />
In practice, it will be up to the RU to consider its contractual arrangements to keep the risks<br />
associated to the supply of maintenance under control. The RU remains fully accountable for the<br />
control of risks inherent to the maintenance activities even if this control is subcontracted to a third<br />
party.<br />
9.4 Is there a harmonised framework for the pre departure inspection?<br />
The ECM Regulation doesn’t regulate the pre-departure inspections. They are not part of the<br />
maintenance activities of the ECM but they are set up by the Railway Undertaking, as part of their<br />
SMS, to verify the vehicle is fit for the journey and the operation: the ECM Certification does not<br />
liberate the Railway Undertaking from its responsibilities to manage the risks in operations and<br />
maintenance.<br />
The pre-departure inspections are regulated in particular by the TSI Traffic Operation and<br />
Management and must be managed by Railway Undertakings within their SMS. There are some<br />
harmonising tools already in place. The GCU (General Contract of Use) is a harmonised contract<br />
between Railway Undertakings and keepers regarding the provision of wagons.<br />
The harmonisation of the pre-departure inspections should be developed by the stakeholders<br />
themselves.<br />
It is important for the ECM to know the content of those inspections and their possible differences<br />
when establishing and updating the maintenance file. For that purpose, cooperation between RUs<br />
and ECMs is crucial.<br />
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