Joint letter from ASSOFERR and UIP to ANSF – Italian National Safety Authority
UIP, the International Association of Wagon Keepers and ECMs, shares your opinion that the derailment in Brixen and, in particular the results of the investigation process, are relevant and require thoughtful discussions at European level. However, having read the NIB report, we are very surprised about the conclusions and especially your requests towards RUs which are partly in contradiction with the ANSF requests in 2012 (12/07299 and 12/07875).
We reiterate our concerns that despite the entry into force of legislation 445/2011/EC on a system of certification of Entities in Charge of Maintenance for freight wagons, many National Safety Authorities still focus only on Railway Undertakings for ensuring safety. We are facing again a situation where a letter concerning “vehicle maintenance processes” is addressed to RUs without taking into account the existing ECM responsibilities (Art. 14 (a) of the Safety Directive)) and their defined role, i.e. ensuring “that the vehicles for which it is in charge of maintenance are in a safe state of running by means of a system of maintenance”. This may result again in non-manageable requests by RUs to ECMs, as the former may feel responsible (e.g. supported by the content of your letter) for a part of the safety processes they don’t need to manage and for which they have no information.