Tank containers have not required registration in Roszheldor
Maria Surina, CEO, Spectransgarant:
Following the results of a meeting in Rostransnadzor it was recommended to Roszheldor to prepare the draft document on a method of operation and registration tank containers for transportation of dangerous freights. It is told in it about need of acceptance of a number of measures which demand the comment.
In particular, a question of additional obligatory registration of tank containers for dangerous freights is very difficult and it is absolutely not evident what aim is pursued by Rostransnadzor having initiated this project. In our opinion, before making the final decision or to ratify any document it is necessary to understand a situation in more detail and to understand what consequences can have such innovations.
First of all tank container is multimodal transport equipment used in international transport. At the same time all tank containers operating in Russia are registered by the Russian Maritime Register of Shipping (RMRS) which is supervisory authority according to the order of the Government of the Russian Federation No. 854-r of 20.06.2000. It means that all containers are already registered properly. Furthermore it can be exploited not only in Russia, but also in international or transit transport as RMRS is a member of the International association of classification societies.
If transportation of tank containers by Russian Railway network becomes possible only with obligatory registration in Roszheldor, isn't clear how will be transported tank containers going in transit. According to new requirements it won't be able to use tank containers on the territory of Russia or we will be able to use other mode of transport but railway. As a result transportion of tank containers will moved to motor transport. The volume of transit transportation of goods in tank containers on Russian Railway network and in Russia in general can significantly be reduced. And it directly contradicts the provisions enshrined in the Strategy of development of railway transport till 2030 where tasks of development of transport and transit capacity of our country are accurately formulated.
Secondly, Rostransnadzor, telling about obligatory registration of tank containers and appealing at the same time to the "Provision on Federal Agency for Railway Transport" approved by the government resolution No. 397 of July 30, 2004 and to "Administrative regulations of Federal Agency for Railway Transport of providing the state service in implementation of the number-specific accounting of the rolling stock and containers" doesn't consider the fact, that for tank containers with assigned numbers none of 14 reasons of registration specified in this document approach.
Proceeding from it, from our point of view, additional registration of tank containers in Roszheldor is legally not proved.
And, at last, there is a question why the registration subject in Roszheldor rises only in the relation with tank containers. Dangerous freights are transported also in GP containers. In this case the developed document has to be applied also to the all-purpose equipment. As the result there can be difficulties with passing of any type of containers across the territory of Russia at import and transit transportations. This volume makes about 300 thousand TEU, transit - 160 thousand TEU also continue its growing.
"RZD-partner" Magazine, №15-16, 2016