Executive summary
To support the House of Commons Transport Committee’s inquiry into safety and security of the rail network, RSSB would like to make the following key points:
It is in this capacity, RSSB submits evidence to the committee.
All of RSSB’s activities and outputs are evidence based and independent of any single interest across its membership which spans the whole railway system. RSSB’s Board has three independent non-executives including the Chair of the Board.
This submission represents the views of RSSB and not its members.
The submission highlights where the industry and government bodies have, via RSSB, identified and implemented safety improvements in the areas relevant to the committee’s remit.
1 The current safety regime and RSSB’s role
1.1 RSSB was established in 2003 to address some important recommendations from the second part of Lord Cullen’s report into the Ladbroke Grove Rail accident. It was set up to address the need for a system-wide perspective on standards, research, and a range of cross-industry functions such as safety reporting. Cullen recommended that a body independent of the regulator and any single interest should provide a framework for collaboration to support industry manage its risk across interfaces.
1.2 RSSB is a not-for-profit, expert industry body with membership from GB rail infrastructure managers, passenger and freight train operators, rolling stock owners, infrastructure contractors, and suppliers. RSSB is independent of any single interest and works on behalf of all of its cross industry membership.
1.3 RSSB’s mission is to support its members and stakeholders to deliver a safer, more efficient and sustainable rail system. We achieve this by producing independent, evidence-based research, analysis, risk modelling and insight.
1.4 Under the current regulatory regime, the safety of the railway system relies on all duty holders managing the risk from their own activities, sharing information, and cooperating to deliver services safely and cost-effectively. To help industry stakeholders understand how the safety of the railway system is managed and measured, RSSB published a guidance document in 2015 which provides an overview of the safety regulatory regime. It also explains the how individual duty holders manage safety; their legislative obligation to cooperate; as well as the role of RSSB which facilitates industry collaboration and cooperation, and the Office of Rail and Road (ORR) as the safety regulator. Additionally the Rail Accident Investigation Branch (RAIB) independently investigates accidents to improve railway safety, and makes recommendations to the industry including RSSB and the ORR.
1.5 RSSB plays a key role in facilitating national, system-level collaboration through a framework of cross-industry, risk-focussed health and safety groups. It is the industry expert in the provision of safety performance, tools, and risk data and management of associated industry systems. We also publish good practice guides.
1.6 RSSB is responsible for developing cross-industry rules and standards on which the industry relies to design and manufacture railway assets and products and for operating and maintaining the whole railway system efficiently and safely.
1.7 RSSB provides research, insight, and analysis for the industry and an independent mechanism to collaborate and cooperate; reach collective decisions; and act in a coordinated manner to improve industry performance including safety.
1.8 It is important to recognise that the responsibility and the obligation to improve safety and make necessary changes emerging from ORR, RAIB or RSSB’s work, rests with the individual industry organisations. Of course, RSSB continues to support its members where required in meeting their objectives by using RSSB data, systems and outputs effectively and efficiently.
1.9 RSSB supports industry’s safety and security objectives through a range of activities including:
1.9.1 Managing industry’s safety reporting systems such as the Safety Management Intelligence System (SMIS) and reporting the industry’s performance in the Annual Safety Performance Report (ASPR). These activities help the industry identify relevant trends and key priority areas to focus on now and in the future. RSSB also produces guidance on measuring safety performance which helps rail companies identify the safety performance indicators most appropriate to their operations, and develops associated capabilities in safety risk modelling, management and decision making.
1.9.2 Managing industry standards that facilitate the most cost-effective, efficient and compatible means of rail system delivery across multiple interfaces, whilst providing for a safe railway.
1.9.3 Supporting the development of industry’s health and safety strategy ‘Leading Health and Safety on Britain’s Railways’.
1.9.4 Supporting the development of an industry cyber security strategy.
1.10 This submission highlights key activities relevant to the inquiry’s remit. We have highlighted where the industry and government bodies have, via RSSB, identified and implemented safety improvements, which have ensured Britain’s position as one of the safest railway in Europe. We have also identified areas where the industry is seeking to further improve and ensure it remains vigilant and non-complacent.
2 Responses to key areas of committee’s focus
In this section RSSB has provided its views on each item of the committee’s remit to aid its inquiry.
2.1 Actions to reduce harm at level crossings
2.1.1 The railways in Great Britain have one of the highest levels of safety at level crossings across Europe, and over the 10-year period ending 2015/16, the number of fatalities at level crossings has fallen in five of the last six years, with fewer than 10 fatalities per year.
2.1.2 This has been achieved by Network Rail, which owns and manages level crossings on the GB mainline network, through a combination of closures and other safety improvements.
2.1.3 RSSB plays a key role in facilitating the collection and analysis of safety and risk information relevant to level crossings; supporting the cross-industry Level Crossing Strategy Group; and managing industry research into level crossing safety.
2.1.4 The Transport Committee’s report on safety at level crossings published in 2014 made a recommendation (76) to the industry to clarify terms associated with accidents at level crossings. In response, RSSB, Office of Rail and Road (ORR) and Network Rail agreed that the term ‘deliberate misuse’ should be confined to events where the investigation has demonstrated the cause of the accident to be solely due to deliberate action on the part of the user, who was aware the action was incorrect and carried risk.
2.1.5 The term ‘user human error’ was agreed to be used in the case of events where the investigation has demonstrated the cause of the accident to be due to:
2.1.5.1 Deliberate action on the part of the user, who was not aware that the action was incorrect, or was not aware of the risk-related consequences of the action.
2.1.5.2 Unintentional action of the part of the user, which was not compliant with the crossing rules.
2.1.6 And also in the case of events where:
2.1.6.1 The investigation is not able to demonstrate the cause was deliberate misuse, and was not due to other causes such as equipment failure or rail operator human error.
2.1.6.2 The Committee had also identified RSSB’s work in the area of traffic signs at level crossings. This work has been published (T983, T756) and implementation issues are being managed by Network Rail in conjunction with the Department for Transport (DfT) and ORR.
2.1.6.3 Additionally, work to enhance the accuracy and functionality of the Network Rail’s All Level Crossing Risk Model (ALCRM) is currently underway as part of RSSB research project T936.
2.1.6.4 Finally, at the request of the DfT, the Law Commission for England and Wales and the Law Commission for Scotland examined the legal framework governing level crossings and had made recommendations to modernise, simplify and clarify the law. DfT published a detailed response in October 2014, accepting most of the proposals. Draft legislation to implement the report is still outstanding.
RSSB does not have any locus in this area.
2.3.1 The Railways and Other Guided Transport Systems (Safety) Regulations 2006 transpose the European Railway Safety Directive into UK law and complement general health and safety legislation. Railway-specific regulations such as the Common Safety Methods (CSM) on Monitoring and Risk Evaluation and Assessment prescribe processes for safety monitoring and assessing the risk from significant change. Taken together these regulations provide a risk management framework to work with.
2.3.2 In the areas of standards and safety reporting and risk analysis RSSB provides guidance, systems, and support to its members to effectively and efficiently discharge their legal obligations. Two examples of these are:
2.3.2.1 ‘Taking Safe Decisions’ which describes the consensus industry position on how companies in the GB rail industry take decisions that affect safety.
2.3.2.2 The suite of rail industry guidance notes on the application of the CSM on Risk Evaluation and Assessment.
2.3.3 RSSB promotes cross-industry collaboration and coordination by facilitating and supporting industry groups like the System Safety Risk Group (SSRG).
2.3.4 Current areas of focus for the group include risk at the platform-train interface, freight train derailments, signals passed at danger and road driving risk.
2.3.5 Supported by RSSB, the industry published its health and safety strategy in April 2016: Leading Health and Safety on Britain’s Railway – A strategy for working together. This has been endorsed by leaders of mainline rail companies and sets out their commitment to improve health and safety performance.
2.3.6 The industry’s Safety Management Information System (SMIS) is managed by RSSB and has been in place since the late 1990s. Currently around 75,000 safety-related events are reported into SMIS each year. There is a major programme of work, led by RSSB on behalf of industry, to deliver next generation safety reporting technology. The new SMIS system will go live on 5 December 2016 and is designed to make it easier for companies to report and track safety incidents and investigations. The second phase of this project will integrate close call reporting, and is due to go live in spring 2017. The Close Call System was launched by Network Rail in 2011 to improve the recording and management of those conditions, acts and behaviours that under different circumstances could have led to harm; its integration into SMIS will help drive improvements in safety culture and safety performance throughout the rail industry.
2.3.7 The information from SMIS supports national and local safety monitoring and has enabled the development of sophisticated risk models. RSSB’s network-wide Safety Risk Model (SRM) underpins much risk assessment work, while the Precursor Indicator Model (PIM) indicates trends in train accident risk. In addition, Network Rail’s Signal Overrun Risk Assessment Tool (SORAT) and the All Level Crossing Risk Model (ALCRM) support its risk-based approach to asset management.
2.4 The effect of the result of the EU referendum on the current framework for rail safety and security
2.4.1 It is too early to fully understand the impact of the EU referendum on rail safety and security without a greater understanding of the UK’s future relationship with the EU and UK’s ability to influence EU legislation and standards.
2.5.1 Over the ten-year period ending 2015/16, passenger journeys increased by around 48%. Against the backdrop of this rising trend, the rate of harm to passengers has generally reduced or remained stable. The likelihood of suffering an injury of any level of seriousness is lower than 1 in 200,000 journeys while the likelihood of suffering a fatal injury is lower than 1 in 300m journeys.
2.5.2 The above safety levels reflect the number of injuries and the change in passenger levels across the system as a whole. At a local level, it is possible that changes to infrastructure may result in changes to event rates, at least temporarily, but this is likely to be on a case-by-case basis.
2.5.3 In a wider context than safety, Britain needs a technologically-enabled railway which delivers efficient, affordable, flexible, and attractive transportation for the record number of customers who now use it and are predicted to use it in the future. The industry’s vision for how technology can be used to create a better railway is called the Rail Technical Strategy (RTS 2012). The RSSB Innovation Programme supports innovation to deliver the RTS.
2.5.4 The approach to delivering the RTS 2012 is to develop the industry’s capability to better respond to growth and changes in demand. A highly reliable and dependable train services that are better able to respond to changes in demand will help deliver a safer railway for all.
2.6.1 RSSB published a major report (Research project T1009) into Climate Change Adaptation, covering a look ahead over a 30-50 years’ time horizon from 2016. We are now working with the industry to support them on any implementation activities.
2.6.2 RSSB also continues to work with the rail industry on a range of research and innovation initiatives to improve how maintaining/operate assets in poor weather conditions. One research project T1046 ‘Review of the risks and opportunities from the application of sand during braking’ was completed last year and a significant number of TOCs have already modified their fleets in readiness for this autumn’s leaf fall.
2.6.3 Fatigue can have an adverse impact on various areas of health and safety and it is one of the priorities the industry has set itself in the Health and Safety strategy. A recent RSSB report found fatigue was a contributing factor in 21% of incidents. This report also highlights a systematic under-reporting of fatigue in the industry’s safety incident data, in which only 1% of incidents have fatigue as a factor. A strong link is also evident between fatigue and road driving risk.
2.6 4 RSSB has developed a suite of resources http://www.rssb.co.uk/improving- industry-performance/human-factors/human-factors-tools-and-resourcesand developed a good practice guide on the management of fatigue RS/504 (www.rssb.co.uk/rgs/standards/RS504%20Iss%201.pdf) which the industry can use to manage the complex issue of fatigue.
2.6.5 To address a recommendation in RAIB’s report on an incident involving train driver fatigue RSSB is also currently carrying out a programme of research to improve how fatigue is managed. The findings of these studies will be disseminated during the 3rd RSSB Fatigue Risk Management Forum, which will take place in November 2016.
2.6.6 Additionally, non-technical skills have been regarded as key to improving human performance in safety critical tasks in other industries such as aviation. In 2012 RSSB rolled out training materials and supporting documentation for members to train their drivers in NTS. Many members have integrated NTS into their training and competence development activities, and RSSB continues to support them by running training courses and developing useful guidance such as the industry good practice guide to NTS integration.
2.7 The adequacy of measures to protect persons at the platform-train interface
2.7.1 In collaboration with Network Rail, RSSB has created a cross-industry group, chaired by Network Rail and with TOC and FOC involvement to develop a national Platform Train Interface Strategy. The strategy was published in 2015 and sets out activities and vision over the next 30 years to improve performance, safety, capacity and accessibility at the PTI.
2.7.2 In 2015/16 there were ten fatalities in stations: eight passengers and two members of the public. When the number of non-fatal injuries is taken into account, the total level of harm occurring to passengers and the public in stations was 45.3 Fatality and Weighted Injuries (FWI) rate, compared with 41.8 FWI for the previous year. This comprises six fatalities, 53 major injuries and around 1,400 minor injuries.
2.7.3 None of those fatally injured were boarding or alighting from a train but as a result of individuals falling off the platform edge. Other accidents at the platform-train interface, such as falls from the platform or being struck by a train while standing at the platform edge, have accounted for a similar level of harm but a much higher number of fatalities (40) compared with boarding and alighting accidents (one fatality) over the past ten years.
2.7.4 RSSB facilitates the PTI Strategy Implementation Group (PTISIG) which provides direction and oversight for the implementation of the strategy. RSSB also manages a working group, made up of RSSB and industry experts, which is responsible for implementing the activities set out in the strategy.
2.7.5 To enable industry to better manage the safety risk and realise potential benefits in performance and accessibility the following have been delivered:
2.7.5.1 Lend a Helping Hand Campaign – Public safety campaign to help passengers understand the risks at the PTI.
2.7.5.5 T1054 which investigated platform edge gap fillers to reduce risk at the platform/train interface and T1062 which reviewed and updated the requirements for the under-platform recess and its effectiveness in mitigating the consequences of falls from the platform. The results are now being incorporated in the revision of relevant standards and guidance.
2.8 Progress on current initiatives to improve railway worker safety
2.8.1 In the period April 2015 to March 2016, there were no workforce fatalities occurring in 2015/16 within the scope of ASPR reporting. Over the 10-year period ending 2015/16, the maximum number of fatalities to the workforce in any one fiscal year has been three. The majority of fatalities have involved infrastructure workers, who are exposed to the risk from electrocution and being struck by train. When non-fatal injuries are taken into account, the level of harm per year has typically been around 30 FWI.
2.8.2 In more recent years, the risk from road driving has been more evident, with seven fatalities in total having been recorded as due to this cause since 2011/ 12 (up to August 2016).
2.8.3 The industry has increased focus on this area of risk, which has resulted in improved reporting over the latter half of the decade, and it is likely that other events may be missing from the data.
2.8.4 The industry has set up a Road Risk Group, which is improving the management of road driving risk by developing and sharing good practice, improving safety intelligence, and influencing relevant decision makers.
2.9 Preventing trespass and fatalities and injuries on the railways
2.9.1 The greatest number of fatalities on the railway arise from trespass and suicide. The occurrence of trespass and suicide fatalities is variable, and has ranged between 231 and 314 fatalities per year. While the latter half of the decade has seen generally higher numbers than the first half of the decade, the variability on a year-to-year basis means no strongly defined trend can be determined.
2.9.2 Since 2010, Network Rail and Samaritans have been working together in the delivery of a programme to reduce suicide on the railways. The programme has three key streams of work:
2.9.2.1 Prevention activities (designed to reduce the number of suicides).
2.9.2.2 Post-vention activities (actions to reduce the impact of suicide in terms of staff distress and delays/costs to services).
2.9.2.3 Activities to support a holistic community approach to prevention through collaborative relationships with local health authorities.
2.9.2.4 The industry is increasingly being viewed as a key player in the nation’s attempt to reduce suicides in the UK as a whole. This is reflected in its relationships with the Departments for Transport and Health, and the National Suicide Prevention Alliance. The rail industry’s initiatives in this area are now overseen by the Duty Holders Suicide Prevention Group which RSSB continues to support with the provision of data, intelligence and expertise.
RSSB is happy to assist the committee further as necessary.
October 2016
Floor 4, The Helicon 1 South Place London
EC2M 2RB
enquirydesk@rssb.co.uk http://www.rssb.co.uk
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