Additional written evidence submitted by RSSB (RLS0032)
Additional information and analysis following oral evidence session on rail safety
Following my appearance at the Transport Committee on 28th November 2016 and further to the evidence I provided to you on 12th December 2016 this letter presents some further reflections, and subsequent analysis to assist with your evidence collection.
RSSB's work is undertaken on behalf of the industry to support the key principle that, in order to achieve the best outcome, safety risks must be evaluated and understood, and a rational, evidence based approach taken to determining whether or not they are acceptable. This further evidence covers topics that have not been prominent in the discussions of the committee to this point but which are considered crucial to a balanced, and evidence based consideration of railway safety risk.
The legislative framework for safety management on Britain’s railways is, as for other industrial sectors, underpinned by the Health and Safety at Work Act 1974. The Act places a duty on all employers "to ensure, so far as is reasonably practicable, the health, safety and welfare at work" of those exposed to risks created by their work activity. This involves an appraisal of the level of safety risk and the costs of further reducing it: absolute safety cannot be guaranteed and residual risks are inevitable. This general approach has ensured the safety of UK industry has improved substantially over many years, and this is certainly true in the case of rail, where UK rail safety is amongst the very best in Europe. The document ‘Taking Safe Decisions’, which was cited in the evidence of both Network Rail, and the ORR describes how safety is ensured ‘so far as is reasonably practicable’ in the UK rail industry. Whether or not companies are compliant with these explicit requirements locally is a matter for the companies and the Office of Rail and Road but this is a separate consideration to whether or not the risks of running a railway are tolerable in a general sense, and these issues should not be confused.
On this latter point and, as a substantial amount of questioning at the session on 28th November was around the topic of the safety of train dispatch, I would like to illustrate the key risks on this topic to assist with an informed debate.
The first analysis presented deals with the question of safety of driver controlled operation as a method of train dispatch. As outlined above local assessments are undertaken to ensure that risks are as low as is reasonably practicable. In this context RSSB has undertaken further supporting analysis using the national data set. It shows that, based on incidents reported into SMIS between 2010 and 2015, 97% of train dispatch risk was from personal accidents to passengers and the public. Specifically, this observed risk was found to be slightly lower at platforms that are staffed. It was also found to be slightly lower when dispatching a driver only operated train compared to dispatch involving a driver and guard. This is shown in Figure 1 in the annex below.
However, given the very small number of events seen in comparison with the huge number of passenger journeys (approximately 1.7 billion per year), the principal conclusion of the analysis is that there is no evidence of any significant difference in the risk associated with train dispatch between driver only and with a driver and guard. This evidence is based purely on available data so is not influenced by subjectivity or opinion.
In addition, RSSB has developed two ‘infographics’ (figures 2 and 3) which enable the widely differing scale of the risks relevant to this issue to be better understood. Specifically, by looking at the data in this way, key conclusions are:
• Total GB rail passenger commuter risks are significantly smaller than those experienced on other railways in Europe, and other modes of transport in the UK.
• The risks from train dispatch are a small proportion of the risks the average UK passenger faces when commuting on the railway.
• The estimated risks that might be prevented by the ‘safety critical’ aspects of a guard’s role are a small subset of those dispatch risks.
Rail companies must ensure that their risks are as low as is reasonably practicable as part of their certified safety management systems. Given this, for a residual risk to be significant enough to curtail that company's business (in this case stopping the running of trains) it should be 'intolerable'. This is clearly not the case for the risks discussed here. According to the HSE document 'Reducing risks, protecting people':
"For members of the public who have a risk imposed on them ‘in the wider interest of society’ this limit is judged to be an order of… 1 in 10 000 [fatalities] per annum."
The total fatality risk per year to a regular commuter is estimated as 1 in 400,000 and that associated with train dispatch in its entirely is approximately 1 in 6.7 million per year. Therefore, as long as a railway is being run in accordance with its documented safety management system (as it must be) there is no case for curtailing the running of driver controlled trains on safety grounds.
In lay person's terms, the current fatality risk from dispatch, even for regular commuters, is a very small fraction of the risk they face in their everyday lives. As a benchmark we have seen three dispatch related fatalities in the last 6 years whereas three people are struck by lightning per year, on average.
I do hope the infographics and commentary has provided useful context both in how we measure and assess risk levels to ensure informed decision making and on the topic of the risk from driver controlled operation.
April 2017
Annex: Supporting Charts and Analysis
Figure 1: Data analysis of risks associated with different methods of train dispatch (NB The error bounds show the range of risks levels given differing assumptions about the incidents where the dispatch method could not be identified).
Figure 2: Putting GB rail passenger fatality risk in context
Figure 3: Contributors to GB rail passenger fatality and injury risk