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VTT Expert Services Oy has since 2012 been the only Finnish notified body and independent safety assessment body (ISA) for the railways, as stipulated in the EU railway interoperability and safety directives. The area of competence of VTT, which is accredited by FINAS (the Finnish Accreditation Service), expanded to encompass all subsystems and assessments of safety management systems after FINAS completed its accreditation for rolling stock. Comatec Group acts as the expert on rolling stock for VTT Expert Services, under the leadership of Jorma Nordfors, Business Unit Manager, Special Vehicles and Rolling Stock.
From left: Jorma Nordfors, Business Unit Manager, Special Vehicles and Rolling Stock at Comatec, and Senior Expert Antti Karhu and Vice President Matti Lanu from VTT Expert Services Oy.
The free movement of goods and the people who belong to the community within its area is a basic concept for the European community. To achieve this freedom of movement, it is also necessary for rail services to be compatible throughout the EU area.
To this end it was necessary to create procedures to ensure the technical interoperability of the rolling stock and structural subsystems of the rail systems in the member states of the European Union.
The European Union is not a federation of states but is a union of independent member states. Joint policies are defined in directives, which regulate national legislation. The purpose of the directives is to give guidelines for interoperability.
“Since these are often features that are critical for safety and there cannot be a joint monitoring authority, a system of notified bodies has been introduced to ensure interoperability. Each member state informs the European Commission in the Nando system of the bodies they have that can carry out assessments of interoperability,” states Matti Lanu, Vice President at VTT Expert Services Oy.
“If one of these notified bodies states that a product, device or rolling stock complies with requirements, other bodies cannot contest this. This is based on the Cassis de Dijon principle.
“According to this principle, a product that has been legally produced in one EU member state must be allowed without hindrance on the market in other member states.
“A notified body acts as a third party in cases where there are no standards for demonstrating conformity with requirements or where a matter is so critical for safety that an external assessment is needed.”
CE marking and a declaration of conformity for subsystems and parts of a subsystem to the technical specifications for interoperability applying to track and rolling stock technology usually require examination by a notified body.
The bodies are anonymous. The body carrying out the assessment is recorded by a number, so the assessment report does not directly reveal who carried out the assessment or which country it took place in.
“In the case of VTT Expert Services, competence and independence were assessed by FINAS (Finnish Accreditation Service), and the Ministry of Employment and the Economy informed the commission, on the proposal from Trafi. The Finnish Transport Safety Agency (Trafi) is the government authority in this,” states Antti Karhu, Senior Expert at VTT Expert Services Oy.
The technical specifications for interoperability (TSI) ensure that within the EU area rail rolling stock, for example, conforms to national regulations in the different countries.
The directives define at a very general level the requirements such as for safety and interoperability. The requirements applying to technical details are given in more detail in the technical specifications for interoperability, or TSIs. So the TSIs are in a way like standards that have to be observed in the entire railway system in the EU area to ensure interoperability.
There are technical specifications for interoperability for all the structural subsystems in the railway system (infrastructure, energy, command, control, and signalling) and for rolling stock. VTT Expert Services now carries out assessments for all these subsystems.
Jorma Nordfors has created a flow chart for Trafi to illustrate the assessing and approval process for a rolling stock unit, and this describes a much broader process than what concerns the notifying body.
To be able to manufacture a rolling stock series, it is necessary to obtain type approval for the first unit in the series. For this purpose the purchasing unit, which may also be a supplier, places an order with a notified body for a TSI examination. A second order goes to ISA, which is responsible for an independent safety assessment. A Designated Body is responsible for checking national regulations. In Finland the Designated Body is Trafi. These parties produce the documents for the permit application. The notified body produces the EU examination certificate.
The purchasing unit uses the documents it has obtained to apply for type approval, authorisation for placing in service and registration to the national rail safety authority Trafi.
Type approval is needed for the first unit in a series. For the next units a type conformity declaration is all that is needed, and it is not necessary to apply for type approval again.
The authorisation for placing in service is for each rolling stock unit. They also have to be registered with Trafi. These requirements are based on national regulations and are not connected with the operations of a notified body.
The body responsible for independent safety assessment (ISA) is needed in railway projects in risk management for major changes and in assessments relating to the safety of railway systems.
ISA checks that the procedures for assessing safety and hazards are sufficient and comply with statutes and other safety standards. ISA can also carry out an independent external audit of the safety management systems of different parties in railway operations.
An assessment of interoperability cannot be carried out by a body that has itself participated in designing an object or that is in some way connected to the object being assessed, either financially or through its organisation. A notified body is an independent third party.
“If you have taken part in the design work, you cannot participate in the assessment. You cannot assess your own work. You might be tempted to cover up your own mistakes,” states Matti Lanu.
“You also have to be financially independent of the object being assessed. You also cannot be in a relationship of subordinate to superior, where the superior could influence the outcome. And you must not be in the position of assessing a company in which your relatives are owners.
“Our independence is constantly being checked by FINAS and Trafi.
“VTT Expert Services is the party with main responsibility in technical assessments of interoperability, since the work is done on the responsibility of our notified body. One of our tasks is to ensure independence before we even start the work,” explains Antti Karhu.
A technical assessment of interoperability requires specialist expertise.
“Of course we also have our own technical expertise, but often it is a case of very specialised knowhow, for example relating to rolling stock. Our partnership agreement with Comatec ensures we have sufficient expertise concerning rolling stock,” says Antti Karhu.
“The operations of a notified body are international. A supplier may order an assessment in any EU country, but it is often practical for the body carrying out the assessment to be close at hand. So it is a good thing that this service is now available in Finnish,” states Matti Lanu.
“There is a clear need for a notified body here,” confirms Jorma Nordfors.
TEKSTI: TAINA SYRJÄNEN