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Interpretations Transitional provision for 9.3.x.53.1

"64. The  Safety  Committee  agreed  with  the  interpretation  of  the  term  “electrical equipment”  in  column  3,  sub-paragraph  (d)  of  the  transitional  provision,  as  stated  in section C, paragraphs 12 and 13, i.e.:
“The term “electrical equipment” is used in ADN 2019 as it was used in the version of the ADN applicable until 31 December2018. This is a reflection of the provisions which have been valid up until that date.
The same applies to the term “electrical equipment” in sub-paragraphs (a) and (b) of the paragraph applicable to on board vessels in service whose keels were laid before 1 January 1977.”
para. 64

"22.    The Safety Committee confirmed that the Contracting Parties could choose the recommended ADN classification societies that they agreed to recognize from the list referred to in, and were not obliged to recognize all of the societies."
para. 22


"14. The Safety Committee considered that the operator, as mentioned in section 1.16.0, is the party who has legal and economic responsibility for the vessel’s technical equipment. It can therefore only be a party operating a vessel in line with the bareboat charter procedure, and not a party who use a vessel under a time charter procedure. It also considered that other different contractual relationships should be taken into account when identifying the operator. 
15. The Safety Committee concluded that this interpretation only applied to the definition of operator within the scope of Chapter 1.16 and related references to this chapter in other parts of ADN."
paras. 14 and 15 (Note 2)
"13. The Safety Committee noted that it was the responsibility of the consignor to properly classify  the  dangerous  goods  presented  for  carriage  according  to  their  properties  and  the criteria set out in the applicable regulations.
14. Several  delegations  considered  that  the  current  criteria  were  clear.  In  their  opinion, note2 under was only applicable to substances listed under UN 1202 with a flash point above 60°C and not more than 100°C. They additionally pointed out that classification of  heavy  heating  oils  was  made  based  on  their  hazardous  properties  to  the  aquatic environment  and  not  on  their  flammability  and  therefore  considered  that  carriage  under  a Class 9 entry (UN 3082) was justified.
15. The Safety Committee took note of the opinions expressed during the discussion and noting that the criteria in note 2 to was applicable to all land modes, concluded that proposals for clarification of that text, if needed, should be considered by the RID/ADR/ADN Joint Meeting."
ECE/TRANS/WP.15/AC.2/70 paras 13-15


"14.     The Safety Committee considered that, if a given substance is not listed in Table C, carriage in tank vessels can take place only with special authorization issued under the procedure in 1.5.2. On the other hand, if a substance is listed in Table C, its carriage by tank vessel cannot be subject to less strict conditions than those provided in the Regulations except under bilateral and multilateral agreements under 1.5.1. In that case there is no need to apply the procedure in 1.5.2.

71.       On paragraph 3 (d) of the report, the Safety Committee considered that it was for the classification societies, not the owner, to withdraw the list of substances authorized for carriage in the vessel when a change in the characteristics of substances leads to the prohibition of carriage of a substance in a specific vessel.

72.         The Safety Committee confirmed the interpretations proposed in paragraphs 6 (a) and (g), namely that a stability booklet can be issued for 3 or 4 different densities, otherwise a loading instrument has to be installed on board, and that regarding firefighting installations, non-return valves cannot be installed in service spaces, accommodation or engine rooms and shall be installed outside the protected area (9.3.X.40.1).

74.         It was pointed out that paragraph 6 (l) meant that the design characteristics of Type C tank vessels did not need to be taken into account when using a Type G vessel for carriage of a Type C product. On the contrary, all conditions of carriage, including equipment, should be observed."


"56.       EBU pointed to a problem of interpretation in which arose when substances that could be transported in Type N open tank vessels were transported instead in closed (Type C or N) tank vessels.

57.         The Safety Committee indicated that in the case in question the safe depressurization of the cargo tanks could be ensured by using the devices required by the third indent of (a) (for Type N closed tank vessels). However, it could also be achieved by opening the devices required under the first and second indents of (a) (for Type N closed tank vessels), as long as the same level of safety could be assured using the devices required under the third indent and that steps were taken to prevent an accumulation of water and its penetration into the cargo tanks."

ECE/TRANS/WP.15/AC.2/46 paras. 14, 71, 72 and 74

ECE/TRANS/WP.15/AC.2/44 paras. 56 and 57

"16.    The Safety Committee accepted the interpretation of the Netherlands concerning (vapour return pipes). It was also mentioned that the gas-freeing process should at the same time cover piping and shore facilities. The interpretation did not apply to vessels with gas-free certificates or open vessels."

"18.    The interpretation relating to the supervision of loading and unloading operations (8.6.3, question 10) was adopted as well. However, the Safety Committee considered that in that case there was no need to amend the Regulations. The amendment of in respect of supervision, proposed by Germany, was adopted (see annex I)."
paras. 16 and 18
"19. The Safety Committee adopted the amendment to the second indent of in informal document INF.26, for the 2021 edition of the ADN (see annex I). In the meantime,and to facilitate a common understanding of (b) in the 2019 edition of the ADN, the Safety Committee agreed on the following:

“On the interpretation of the phrase “the results of these measurements shall be recorded in writing” at the end of the second indent of, as adopted for entry into force on 1 January 2019 (see ECE/ADN/45), the Safety Committee confirmed that the obligation to record the measured concentrations only applies when:
(a) the conditions described in that indent are not met; and
(b) the vapour return piping is not used.”
para. 19
The Safety Committee was of the opinion that a fire extinguishing system could be considered ready for operation if:
(a)    The hose assembly was connected;
(b)    The hose assembly was unwound on board the vessel;
(c)    The jet/spray nozzle was connected to the hose assembly;
(d)    The valves were open or closed, as decided by the boat master or the expert on board of the vessel, taking weather and safety considerations into account; and
(e)    The system controls could be activated at any time.
para. 12
"13.    The Safety Committee considered that the term “work on board” covered all the work carried out on the structure of the vessel and its equipment, including, for example, the propeller and the anchor chain."
para. 13
"61.    The Safety Committee endorsed the interpretation of the word “space” used in 9.3.x.40.1 to mean “enclosed spaces or the deck areas located fore and aft of the cargo area, but not the entire deck”.
ECE/TRANS/WP.15/AC.2/76 para. 61
"In the situation with independent tanks is mentioned. In this case additional reinforcements as prescribed in are no more necessary as the requirements of the distance of 80 cm are already met."
para. 16
"In it is mentioned that the maximum allowable tank capacity may exceed the values as given in 9.3.x.11.1, and the minimum distances given in and may be deviated from provided the requirements of 9.3.4 are being complied with. The calculations as mentioned in may be used for all ship sizes."
para. 16
Interpretations for stability and load calculations
Interpretations for stability and load calculations (At its fourteenth meeting (30 January 2015) the ADN Administrative Committee endorsed the interpretations submitted by the Recommended ADN Classification Societies as reflected in paragraphs 24 to 33 of ECE/TRANS/WP.15/AC.2/54). However, at its fifteenth meeting (28 August 2015) amendments to this document were endorsed by the ADN Administrative Committee as reflected in ECE/TRANS/WP.15/AC.2/56 paragraphs 22 and 23 of . A new version of the document with amendments in track-changes can be found here.
ECE/TRANS/WP.15/AC.2/44 paras. 24 to 33
ECE/TRANS/WP.15/AC.2/56 paras. 22 and 23
Interpretation for appropriate ventilation systems

(a)    Ventilation systems do not strictly mean active systems, it is therefore not necessary to install fans;

(b)     The class rules require a ventilation pipe for void spaces (openings could no longer be used and must be replaced by ventilation systems);

(c)     An opened hatch cover is an undefined opening (situation) with respect to stability calculations and cannot be consider as appropriate solution for ventilation of void spaces;

(d)     Two appropriately positioned ventilation openings with regard to stability requirement (e.g. ventilation hoods) per room are appropriate “ventilation systems”;

(e)     A goose neck is an appropriate “ventilation system”;

(f)     It is not necessary to install flame arresters in the ventilation openings of tank vessels of type N open with flame arresters and type N closed.

ECE/TRANS/WP:15/AC.2/80 para. 18

Other national interpretations NOT endorsed by the ADN Administrative Committee