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 on a system of certification of entities in charge of maintenance for freight wagons – VERSION 1.0 procedures outlined by a RU in its SMS, including those for the exchange of information (See recital (6) of ECM Regulation). The RU shall implement any other additional control measures that it considers necessary to keep the identified risks related to the supply of maintenance under control. Those risks could be highlighted through a structured approach to risks assessment and a systematic analysis of findings related to the routine monitoring put in place by the RU as part of its SMS arrangements. In practice, it will be up to the RU to consider its contractual arrangements to keep the risks associated to the supply of maintenance under control. The RU remains fully accountable for the control of risks inherent to the maintenance activities even if this control is subcontracted to a third party. 9.4 Is there a harmonised framework for the pre departure inspection? The ECM Regulation doesn’t regulate the pre-departure inspections. They are not part of the maintenance activities of the ECM but they are set up by the Railway Undertaking, as part of their SMS, to verify the vehicle is fit for the journey and the operation: the ECM Certification does not liberate the Railway Undertaking from its responsibilities to manage the risks in operations and maintenance. The pre-departure inspections are regulated in particular by the TSI Traffic Operation and Management and must be managed by Railway Undertakings within their SMS. There are some harmonising tools already in place. The GCU (General Contract of Use) is a harmonised contract between Railway Undertakings and keepers regarding the provision of wagons. The harmonisation of the pre-departure inspections should be developed by the stakeholders themselves. It is important for the ECM to know the content of those inspections and their possible differences when establishing and updating the maintenance file. For that purpose, cooperation between RUs and ECMs is crucial. Page | 60
Guide for the application of the Art 14 (a) of the Safety Directive and Commission Regulation (EU) No 445/2011 on a system of certification of entities in charge of maintenance for freight wagons – VERSION 1.0 9.5 You are an ECM, what are your responsibilities? • restore the vehicle in its conditions of use (design operating state) MAINTENANCE ECM DESIGN OP<strong>ERA</strong>TING STATE USE USE DEGRADATION OF PERFORMANCE • described in the technical file • the vehicle is operated • vehicle no more in a design operating state RU KEEPER Allocation of responsibilities ECM ‣ ECM must set up and keep updated the maintenance file (maintenance development part II.4 b annex III) ‣ ECM must ensure that the implementation of the first maintenance file is done correctly (maintenance development part II.4 b annex III) ‣ ECM must coordinate all those activities and supervise its subcontractors Exchange of information - Article 5(2) of Commission Regulation 445/2011 The ECM has to address return to operation issues to RUs and keepers. Certification - Commission Regulation 445/2011 For freight wagons: ‣The ECM must be certified against the Commission Regulation 445/2011. ‣The ECM must inform its partners, RUs, IMS and keepers, about all changes (amendment, renewal, suspension, revocation) Page | 61
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ERA-GUI-100.pdf - Europa

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