Document GRSG-113-20
Proposal for amendments to UN Regulation No. 110 - Periodic requalification
Status: Superseded
Submitted by OICA

Proposal to improve provisions for the visual inspection of CNG cylinders, LNG tanks, and their accessories. Germany has proposed (document GRSG-112-33) the prohibition of components or parts of protective housing which must be disassembled during inspection. Italy has proposed (document GRSG-112-28) that visual inspection of cylinders Include access inside any protective covers of the cylinders. Based upon field experience, OICA believes that corrosion damage between support straps, brackets, and pads and the cylinder can be readily identified during visual inspection. Such corrosion requires cylinder replacement. Therefore, OICA proposes clarifications to inspection procedures to address the German and Italian concerns.

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.

28. The expert from Germany introduced GRSG-114-10 on the outcome of the task force on ECE/TRANS/WP.29/GRSG/2017/17 which was on improving the provisions for installing and inspecting Compressed Natural Gas (CNG) cylinders or Liquefied Natural Gas (LNG) tanks and their accessories. The expert from Italy preferred a more accurate inspection of such containers without the removal of structural parts (GRSG-114-19). After discussion, GRSG agreed to add design requirements that allow easy periodical technical inspections. The expert from the Netherlands requested that container manufacturers provide more detailed recommendations for periodical technical inspections and for periodic requalification tests, and requested that these recommendations be stored and made available for all inspections.

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.

30. Finally, GRSG considered a revised proposal (GRSG-114-10-Rev.1) and adopted ECE/TRANS/WP.29/GRSG/2017/17 as reproduced below. The secretariat was requested to submit the proposal to WP.29 and AC.1 as draft Supplement 1 to the 03 series of amendments to UN Regulation No. 110 for consideration at their November 2018 sessions.

Insert a new paragraph, to read: the provisions of paragraph 18.1.6., it shall be possible to make an external inspection (e.g. for Periodic Technical Inspection) of the CNG cylinder or LNG tank and their accessories according to the specifications of the manufacturer, without the use of tools to dismantle, but with visual aids, e.g. lamps, mirrors or endoscopes.

31. The expert from Italy, in reference to ECE/TRANS/WP.29/GRSG/2017/29, proposed to amend Annex 3A of the Regulation, i.e. the test requirements for the periodic requalification of CNG cylinders to avoid structural failures during their service life (GRSG-114-32), including new provisions for a mandatory impact damage test for all cylinders without the use of shoulder pads. GRSG welcomed the specific test reports provided by Italy on CNG4 cylinders (GRSG-114-07, GRSG-114-14, GRSG-114-15). GRSG noted concerns and comments. Finally, GRSG agreed to refer it to the task force and to resume consideration of this subject at its next session on the basis of a revised official document.

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).

40. The expert from Italy proposed to amend in Annex 3A of the Regulation the test requirements for the periodic requalification of CNG cylinders to avoid structural failures during their service life (ECE/TRANS/WP.29/GRSG/2017/29). The expert from the Netherlands raised his concern on the access by inspection centres to detailed provisions for the inspection of such cylinders. Thus, he underlined the need that cylinder manufacturers should make available cylinder inspection manuals. GRSG welcomed the offer by Germany to take the lead of a Task Force to review ECE/TRANS/WP.29/GRSG/2017/17 and ECE/TRANS/WP.29/GRSG/2017/29. It was agreed to also involve the International Motor Vehicle Inspection Committee (CITA) in the discussion and to resume consideration of this subject at its next GRSG session in April 2018.

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.