Digital copies of tank records and certificates are widely accepted by customers of tank owners/operators but have yet to be formally recognised in regulations. The text of the RID/ADR regulations, which govern the transport of dangerous goods by rail and road, currently assumes that tank records are being maintained on paper. However these days, operators usually file records directly into electronic systems. Now regulations are being adapted to reflect this culture change.
In September, United Nations (UN) experts met in Geneva at the Joint Meeting of the RID Committee of Experts and the Working Party on the Transport of Dangerous Goods (WP.15/AC.1).
At the meeting of the INF14 working group, the International Union of Wagon Keepers (UIP) proposed an amendment to RID/ADR 18.104.22.168.7, which covers how tank records are maintained for transport by road and rail. UIP proposed that electronic archiving systems be formally accepted into the RID/ADR regulation and it also put forward a number of recommendations on how a “suitable, tamper-proof digital system” might be standardised.
The existing RID/ADR 22.214.171.124.7 regulation requires that tank records ‘be maintained throughout the lifetime of the tank by the owner or the operator’, and ‘be retained by owner/operator for 15 months after the tank is taken out of service’. However, as was raised in a recent discussion on the ITCO LinkedIn group, original copies of documents fade with time – which is a problem, considering the average life-span of a tank container is 20 years.
During the working group meeting, it was agreed that tank records and the required attachments, such as periodic test certificates, could be in digital form provided they were stored in an acceptable format, like a scanned copy. The experts are now working on formulating detailed requirements of what this would entail. Experts will need to specify the minimum required data fields to ensure that sufficient information is supplied and to prevent human error.
Digitised tank records come with a myriad of benefits. In its proposal, UIP recommends the use of digital tank records systems as it “reduces the potential risk of data loss but also creates the opportunity of sending documents of any kind quickly and without complications worldwide, e.g. to workshops, control organisations, authorities, customers etc.” The ease of transferring electronic documents is a distinct advantage for tank container owners/operators. RID/ADR 126.96.36.199.7 requires that tank records be transferred to the new owner/operator after a tank is sold/leased, and that copies of tank records are made available to third parties, where necessary.
Now it falls to experts to outline what will constitute an internationally recognised standard of digital tank record-keeping. Who will have authorised access to digital tank records systems and how access will be granted? When and how can records be changed or extracted for use? UIP highlighted that an effective digital records system should be “tamper-proof” but how can this be pinned down in regulation? Do paper-based tank certificates still need to be kept after having been scanned and transferred to an electronic management system?
As experts iron out the finer details, the UN INF14 working group’s acceptance of digital tank records shows that the culture is changing. Will other regulations and jurisdictions follow suit? It will only be a matter of time.
MRI Intermodal offers features in its software to help customers with their electronic tank documentation such as the ability to link electronic certificate copies to individual tanks, attach the latest certificate to a release notification and centrally store all certificates related to a job, saving valuable time if multiple tanks were involved. Third parties can even gain access to certificates via a secure web portal. For more information, contact firstname.lastname@example.org or visit www.mriintermodal.com.