Document GRSG-114-26
UN R110: Proposal for amendments with regard to visual inspections
Status: Rejected

Proposal to delete the reference to visual inspection under the support straps of the cylinders from the text under consideration. Such inspection would require dismantling of the cylinder installations which would contravene the consensus decision to avoid such exhaustive dismantling.

Submitted by OICA
Discussions and Outcomes

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 18.1.6.1., to read:

18.1.6.1.Notwithstanding 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.

GRSG-113-03
GRSG-113-20
GRSG/2017/17
GRSG/2017/29

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.