Assurance provided by a second pair eyes (RASBO) of the correct Safe integration by the proposer of a new or modified Rolling Stock

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Quality & Safety for Systems & Software Railway Engineering Assurance provided by a second pair eyes (RASBO) of the correct Safe integration by the proposer of a new or modified Rolling Stock Ir. Marc Bronchart AsBo & independent Safety Assessor

Presentation structure Part I Safe integration Part II Regulatory framework Part III Independent assessment 28 June 2017 Safe integration of a new or modified Rolling Stock 2

PART I SAFE INTEGRATION 28 June 2017 Safe integration of a new or modified Rolling Stock 3

Safe integration Railway vehicles Railway vehicles ( rolling stocks ) consist of following subsystems: Rolling stock itself, including (not exhaustive list) Braking devices Traction cut-off Coupling devices Doors Energy Signalling Particular fittings 28 June 2017 Safe integration of a new or modified Rolling Stock 4

Safe integration Interfaces to consider All these subsystems are interfacing and interacting between them and with: passengers train drivers maintenance staff infrastructures 28 June 2017 Safe integration of a new or modified Rolling Stock 5

PART II REGULATORY FRAMEWORK 28 June 2017 Safe integration of a new or modified Rolling Stock 6

Regulatory framework TSIs per Subsystem National Rules Safety Directive CSM REA NoBo DeBo National Safety Auth. Assessment Body 28 June 2017 Safe integration of a new or modified Rolling Stock 7

Regulatory framework CSM REA as support for the APoM 1 Requirement capture (Applicant) (a) (b) (c) (d) TSIs EU law (Derogations in Art. 7 of ID 2016/797) NNR in force at time of request of Authorisation National Law Other requirements (e.g. Environmental laws, Contractual requirements, etc.) Regulation 402/2013 (CSM RA) EU law (when making changes) Management of technical and safe design (Applicant) 2 Proposer s formal demonstration of conformity vs. TSIs Proposer s formal demonstration of conformity vs. NNR Proposer s formal demonstration of compliance with all other requirements Proposer s formal demonstration of compliance vs. CSM RA Independent Conformity Assessment (CABs) 2 NOBO EC verification of conformity vs. TSIs DEBO verification of conformity vs. NR No obligation for independent conformity assessment RASBO assessment of correct application and suitability of results 3 Vehicle authorisation for placing on the market (Authorising Entity) 28 June 2017 Safe integration of a new or modified Rolling Stock 8

Regulatory framework Placing On the Market placing on the market means the first making available on the Union's market of an interoperability constituent, subsystem or vehicle ready to function in its design operating state Article 2 (35) of Interoperability Directive 2016/797/EU 28 June 2017 Safe integration of a new or modified Rolling Stock 9

Regulatory framework STI LOC&PAS (locomotives & passengers) STI WAG (wagons) STI NOI (noise). Others transverse Tunnel PRM CCS) Or Functionnal OPE TAF AP). TSIs per Subsystem 28 June 2017 Safe integration of a new or modified Rolling Stock 10

Regulatory framework Roles and responsibilities for safe integrations STEP 1 STEP 2 STEP 3 Responsibilities of Applicant Design, construct, install, test & demonstrate Safe Integration of components and sub-systems within the vehicle Responsibilities of Railway Undertaking Check technical compatibility and demonstrate Safe Integration of Vehicle within the Route Responsibilities of RU & ECM Operation & Maintenance according to SMS/MS [and thus Technical File(s)] Technical File containing all Operational & Maintenance Requirements linked to the design Technical compatibility and safe integration within the vehicle Conformity with TSI(s) Check by NoBo (Use of CSM for RA) Conformity with NNR Check by DeBo RA according to CSM RA Check by CSM Assessment Body Technical compatibility and safe integration of vehicle within the Route Conformity with infrastructure register (RINF) Check by NoBo (Use of CSM for RA) Conformity with NNR Check by DeBo Update of SMS SMS update according to CSM for RA Check by CSM Assessment Body Operation according to RU SMS Supervision by NSA Return of experience Maintenance according to ECM System of Maintenance Surveillance by ECM Cert Body Supervision by NSA [Art 16(2)(f)] NSA Authorisation for placing on market ( * ) RU decision of placing in service ( * ) There is no NSA Authorisation for placing in service 28 June 2017 Safe integration of a new or modified Rolling Stock 11

Regulatory framework Duplication of independent assessment work between different Conformity Assessment Bodies involved in a project shall be avoided Compliance with TSIs Compliance with CSM Risk Assessment: WHAT is the interaction of (R)AsBo with other Conformity Assessment Bodies (CABs) 28 June 2017 Safe integration of a new or modified Rolling Stock 12

Safety Impact of ETCS Integration TSI requirements are not sufficient for ensuring the safety of the modified system 27 June 2017 Safe integration of the ETCS into the infrastructure 13

Regulatory framework CSM RA DeBo Depending on national rules Track detector Track Rail Point machine Railway system ISA STI CCS (ISA) On board ETCS Signalling Non ETCS Equipment s Trackside ETCS Tunnel equipments. Fire detection 27 June 2017 Safe integration of the ETCS into the infrastructure 14

Regulatory framework Duplication of independent assessment work between different Conformity Assessment Bodies involved in a project shall be avoided Compliance with TSIs Compliance with CSM Risk Assessment: WHAT is the interaction of (R)AsBo with other Conformity Assessment Bodies (CABs) 27 June 2017 Safe integration of the ETCS into the infrastructure 15

Regulatory framework CSM REA Railway system Track Rail Vehicle Energy Catenary ISA Rolling stock Converters Track detector Point machine Braking devices Non ETCS Equipments On board ETCS Signalling DeBo Depending on national rules Trackside ETCS STI CCS (ISA) 28 June 2017 Safe integration of a new or modified Rolling Stock 16

Independent Assessment Conditions for AsBo s (continued) Annex II: criteria for accreditation or recognition following ISO17020:2012 Competence In risk management In the parts of the railway system (different areas of competence, technical as well as functional subsystems) In the correct application of safety and quality management systems or in auditing management systems Independence (types A, B, C) 27 June 2017 Safe integration of the ETCS into the infrastructure 17

Independent Assessment Conditions for AsBo s (continued) An AsBo has to take into account organisation put in place to ensure coordinated approach to achieving system safety Methodology put in place Technical aspects for assessing relevance and completeness 27 June 2017 Safe integration of the ETCS into the infrastructure 18

Independent Assessment Methodology Use of combined types of activities: Audit, visit, interview Document review Test witnessing Specific analyses (or request) Focus on vertical and horizontal project life-cycle cross-section Assessor IS NOT performing design, verification or test activities 27 June 2017 19 Safe integration of the ETCS into

Independent Assessment Methodology Assessor must accept alternative ways, different from what he would have expected/done 27 June 2017 Safe integration of the ETCS into the infrastructure 20

Independent Assessment Result Safety Assessment report Identification of the AsBo Independent Assessment plan Definition of the scope & limitations Results of the independent assessment Carried out activities Non-compliances Recommendations Conclusions 27 June 2017 Safe integration of the ETCS into the infrastructure 21

Regulatory framework New or modified vehicle New or modified vehicle? Currently not clear (enough) if independent assessment is required from safety perspective (more information available about interoperability) Does it mean new or modified type of vehicle? 28 June 2017 Safe integration of a new or modified Rolling Stock 22

Regulatory framework New or modified vehicle New or modified vehicle? Is it linked with potential impact of railway undertaking certificate? But certificate means is able to (Railway Safety Directive, Article 10 1) What about actual safety level? Is the Safety Management System really applied? 28 June 2017 Safe integration of a new or modified Rolling Stock 23

Regulatory framework New or modified vehicle By 16 June 2018, the Commission shall adopt, by means of implementing acts, practical arrangements specifying: (a) how the requirements for the single safety certificate laid down in this Article shall be fulfilled by the applicant and listing the documents required; (b) the details of the certification process, such as procedural stages and timeframes for each stage of the process; [ ] Railway Safety Directive 2016/798/EU Article 10, 10 28 June 2017 Safe integration of a new or modified Rolling Stock 24

Regulatory framework New or modified vehicle Assessment can vary from no assessment (no significant change) to full assessment In case of assessment same kind of assessment activities 1 + approach is often used Assessment not only on the, but also potential influence on the 1 Possibility of a slide in the principles by abusing CSM REA regulation 28 June 2017 Safe integration of a new or modified Rolling Stock 25

PART III INDEPENDENT ASSESSMENT 28 June 2017 Safe integration of a new or modified Rolling Stock 26

Safe integration Multiple aspects Dynamic safety Control-command & signalling Static safety Fire safety Mechanical resistance It requires several competencies for assessment 28 June 2017 Safe integration of a new or modified Rolling Stock 27

Independent assessment Vehicle particular topics Global approach is required Technical compatibility is not sufficient Safety objectives may depend on common targets (e.g.: ERTMS/ETCS on-board) may be not commonly defined at Union level 28 June 2017 Safe integration of a new or modified Rolling Stock 28

Independent assessment Current difficulties Safety objectives not commonly defined at Union level Pure national rules Independent Assessment car rely on it (DeBo?) Possible influence on international requirements has only to be assessed. 28 June 2017 Safe integration of a new or modified Rolling Stock 29

Independent assessment Key items Safety objectives not commonly defined at Union level How to make a judgement? risk acceptance criteria defined in the Safety Management System of the Railway Undertaking could not match with safety requirements of all Member States The CSM REA gives some quantitative objectives (10-7 /h or 10-9 /h) when detailing the criterion explicit risk estimation without giving the scope of them 28 June 2017 Safe integration of a new or modified Rolling Stock 30

Independent assessment Key items More and more software Formal approval and management of imported constraints from solution providers (subcontractors) Infrastructure managers Formal issue of exported constraints towards relevant actors Ultimately to the Railway Undertakings and Entities in Chare of Maintenance 28 June 2017 Safe integration of a new or modified Rolling Stock 31

Independent assessment Key items EMC One can hope that norms are sufficient for reaching appropriate safety level 28 June 2017 Safe integration of a new or modified Rolling Stock 32

Q&A 28 June 2017 Safe integration of a new or modified Rolling Stock 33