The importance of Interoperability in the design pase
At present, compliance with the
technical specifications for interoperability (ETIs) is a mandatory requirement
in most railway projects that require technical approval from the contracting infrastructure
manager and in a very special way by ADIF.
In Spain, Royal Decree 1434/2010 of 5 November is in force, on interoperability of the railway system of the General Interest Railway Network (RFIG), which transposes EU Directive 57/2008 into the Spanish legal system. As of the date of writing this article, the EU Directive 797/2016 is in the process of being transposed.
Point 4 of article 13 of Royal Decree 1434/2010 indicates "The notified body may issue intermediate verification declarations (DVI) to cover certain phases of the verification procedure or parts of the subsystem"
It should be remembered that the
structural subsystems contemplated by the Directive are the following:
- Control-command and signaling (ground equipment).
- Control-command and signaling (on-board equipment).
- Rolling material.
For each of the
subsystems there is one or more European Regulations (regulations with a
mandatory range without the need for transposition) where the technical
specifications for interoperability are set out. Thus,
for example, the technical specifications for interoperability of the
infrastructure subsystem are contained in Regulation 1299/2014 (infrastructure
TSI), Regulation 1300/2014 (accessibility TSI) and Regulation 1300/2014 (safety
TSI in railway tunnels) .
The same Regulation can also collect technical specifications for different subsystems, for example, Regulation 1300/2014 (Accessibility TSI) includes technical specifications on the infrastructure subsystem and also on the rolling stock subsystem.
In turn, within each TSI, different phases can be detailed where compliance with interoperability requirements must be evidenced. For example, Appendix B of the Energy TSI (Regulation 1301/2014) identifies the following phases for the verification of the subsystem:
Point 4 of article 13 of Royal Decree
1434/2010 indicates "The notified body may issue intermediate
verification declarations (DVI) to cover certain phases of the verification
procedure or parts of the subsystem". Point 2 of Annex VI of said
Royal Decree also identifies the stages covered by the verification of a
However, the reality is that despite being regulations that have more than 10 years since their publication, many projects take longer than usual and it is not until the execution phase or months before commissioning. (Procedure regulated by Order FOM / 167/2015) when the actors that are part of a specific project are not aware of the need to comply with the ETIs.
Changes to demonstrate compliance with the interoperability requirements that must be executed during the assembly / work phase are usually complicated by deadlines and very expensive, and may delay commissioning and the necessary obtaining of the CE certificate by a notified body ( NoBo) and the associated CE Declaration.
Addressing TSI compliance from the earliest stages of project design is essential. To do this, as indicated in the previous paragraphs, it is possible to issue an intermediate verification declaration in the design phase (DVI) that guarantees compliance with the requirements demanded by the TSIs in the design phase that may be incorporated later in the certification. CE of the complete subsystem.
From Leedeo we offer our experience in the design of projects that fully comply with the interoperability regulations of the different subsystems. In addition, we take care of document management with the notified body (NoBo) and of coordination with the different areas of the project to guarantee the completeness of the project and avoid the need for costly changes in the assembly / work phase before commissioning. service.
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