Document GRSG-113-03
NGV comments on the proposed amendments to UN Regulation No. 110
Submitted by NGV

Comments from NGV Global on the proposals from Italy (GRSG-112-28) and Germany (GRSG-112-33) regarding the testing and inspection of CNG cylinders.

Discussions and Outcomes
176th WP.29 session (12-16 Nov 2018)

114. The Chair of GRSG presented proposals on ECE/TRANS/WP.29/2018/123 to ECE/TRANS/WP.29/2018/126 under agenda items 4.7.4 to 4.7.7, to amend UN Regulations Nos. 46, 67, 105 and 110. The World Forum recommended their submission to AC.1 for voting.

This proposal (WP.29/2018/125) was adopted by the World Forum. Forty Contracting Parties out of the 50 applying UN R110 were present for the vote by AC.1. Forty voted in favor with zero against and zero abstaining.
114th GRSG session (9-13 Apr 2018)

23. The expert from Germany introduced GRSG-114-08 on the recent meeting of the task force on gas-fuelled vehicle regulations held in Cologne (Germany) on 6 and 7 February 2018. He added that progress had been good on UN Regulation No. 110, but the amendments to UN Regulation No. 67 were still under considerations.

29. The expert from OICA presented GRSG-114-26 proposing to amend the specifications for inspection of CNG-cylinders / LNG-tanks and their accessories. GRSG did not support the proposal.

113th GRSG session (10-13 Oct 2017)

39. The expert from Germany introduced ECE/TRANS/WP.29/GRSG/2017/17 to improve the specifications for the installation and inspection of Compressed Natural Gas (CNG) cylinders or of Liquefied Natural Gas (LNG) tanks and their accessories. GRSG welcomed the proposal and noted that WP.29 and the Administrative Committee of the 1997 Agreement were expected to consider and adopt ECE/TRANS/WP.29/2017/134 on a new UN Rule on Periodical Technical Inspections of motor vehicles using CNG and/or LNG in their propulsion system. The proposal from Germany received a number of comments, especially on the need to align the recommendations for the periodical technical inspections of such vehicles with the specifications for the re-qualification of the CNG cylinders or LNG tanks. GRSG noted the comments received by the experts from NGV Global (GRSG-113-03) and OICA (GRSG-113-20).

112th GRSG session (24-28 Apr 2017)

32. Reporting on some cases of structural failures of cylinders in his country, the expert from Italy proposed amendments to Annex 3A on the test requirements for the periodic requalification of cylinders (GRSG-112-28). The expert from Finland stated that these test requirements on periodical inspections of CNG/LNG vehicles in use were only recommendations to be taken into account during the type approval procedure of a new type of vehicle. GRSG noted that Contracting Parties were used to perform on their national level the periodical technical inspections in different ways. Referring to GRSG-112-32 presented under agenda item 7 (see para. 26 above), the expert from Germany introduced GRSG-112-33 proposing to also strengthen the requirements in UN Regulation No. 110 for the installation on vehicles of CNG-cylinders, LNG-tanks and their accessories as well as for their subsequent inspection of without the need of disassembling the containers.

33. GRSG noted general support on the proposals. The Chair invited all GRSG experts to send their comments, in due time, to the experts from Germany and Italy. GRSG agreed to resume consideration of this subject at its next session on the basis of official documents, prepared by Germany and Italy, taking into account the comments received.