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We ask the rail safety experts…

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In preparation for this year’s Rail Safety Summit, we sat down with leading figures from the rail safety industry and asked them a series of pressing questions about safety practices within the rail industry.

Today’s question is:

Would a dramatic reduction in the number of rules, regulations and standards benefit both our safety culture and performance?


Willie Baker, Emergency Incident Consultant:

Probably not! The advantage in having procedures is that they can help to focus attention on what is important, and let us not forget just how inherently safe the railways are in the UK.

The disadvantage is that they can be sometimes viewed as a backside covering exercise and no one benefits from this.

The important point for me is about having rules, regulations and standards that are clear, relevant, concise and understood by all, and to achieve this requires frequent, high quality training delivered at an appropriate level to the appropriate audience.

As an eminent professor once said, you can tell a person of any age anything‚ as long as you pitch it at the right level!

Seamus Scallon, Safety Director, UK Rail, FirstGroup:

Certainly there is scope for simplification and removal of some actions which don’t actually control risks.

However, for generations the industry has relied on Rules, Regulations and latterly Standards for  controlling of risk.

Changing from a dependent to an independent or interdependent safety culture is a massive step that needs to be supported by a gradual transition plan, which ensures a collective understanding of risk and a full commitment to safety both from an individual and team perspective.

Steve Diksa, Assurance Services Director, Bridgeway Consulting:

A significant effort has gone into Rule Book simplification since I received my first issue of my first red Rule Book in 1978.

The Railway Safety and Standards Board (RSSB) have recently made positive progress with the latest tranches of the rule book modules and these have been well received by frontline operational staff.

I’m sure that there is more to be done to ensure that staff know and adhere to the rules and I’m aware that London Underground have achieved much success with the simplification of their rule book, perhaps this is an ideal situation for collaborative working between Underground/Overground in order to share lessons learnt and good practice.

It’s important that our staff can understand why the rules are being simplified and how they will carry out their duties and what the content of their training will be. Complex as they may be they are a life line that the staff will not want to let go of until they have another line to grasp and trust.

The recent RAG (Red, Amber, Green) grading of Network Rail Standards have also been viewed in a positive way and the combination of NR/L2/EBM/STP/001 and NR/L3/STP/002 is also a welcome move in providing a single User Manual for the end user.

So to summarise, I believe the UK rail industry is moving in the right direction but lets keep listening to the feedback from the end users and really understand what they want and lets not assume that we think we know what they want.

Catherine Behan, Head of HS&E Capital Programmes, Transport for London:

Yes; the underlying principles of many rules, regulations and standards are the same, so I’m sure there is opportunity for rationalisation. This approach would reinforce those key principles as a general mantra and addresses the cries that there’s just too much for companies to comply with.

Documents such as ACOPs or industry specific materials can then be used to provide a steer on the application of the principles to specific circumstances which I feel would be viewed more positively.

This in turn should result in a more positive attitude to health and safety and ultimately the culture and performance required to keep people safe.

Jeff ‘Odie’ Espenship, President, Target Leadership:

Reviewing current policy and regulations is a matter of good housekeeping. In order for safety rules, regulations and standards to be effective, they must be perceived as having integrity by those who are required to adhere and follow them.

If the integrity of a safety system is bogged down by the sheer weight or volume of rules, regulations and standards‚ then YES, a methodical and systematic reduction is not only advised, it is required.

When there are so many rules and regulations on the books that it becomes impossible to follow all of them, then the system is broken and needs to be repaired. It is critical that employees perceive that the system works.

Steve Enright, Head of Safety and Operational Standards, Southern

Simplification is generally a good thing as this helps with understanding which in turn can change behaviour.

Care must be taken to ensure that key safety standards are not diluted so a dramatic reduction in number may not be an effective route. Consultation on and involvement in any process would be necessary to support the cultural support for this.

Dr Liesel Von Metz, HM Inspector of Railways:

There is no doubt that we could benefit from streamlining rules and standards. We’ve inherited a rule-based safety culture, and a proscriptive Standards regime.

Although it is important in a safety-critical industry to set a minimum baseline through core standards, Rules and Standards do not of themselves create the maturity and ownership that is necessary to achieve high performance whilst sustaining and improving safety.

There are promising signs that the industry has recognised the need for such a mature culture where controls are practical, proportionate and based on a proper assessment of risk; but the pace of this change does need to quicken.

ORR is supporting and encouraging the industry to move in this direction through development of the RM3 model and through collaborative working in key areas.

Christian Fletcher, Director, Zonegreen:

One of the problems we have is that there are so many rules and regulations that there is no one set rule book for safety in depots. Depending on who is designing the depot, depends on the safety and which rule book they are working from.

For example the 1992 Code of Practice is what some people work from but it doesn’t mean it’s right for depots in 2012 which are going to maintain trains for the next 25 years.

Tomorrow’s ‘We ask the rail safety experts’ will see our experts answer this question:

Should line managers and supervisors be rewarded for safety performance or does this lead to under-reporting?

The Rail Safety Summit is taking place on April 19th 2012 in Loughborough.

For more information, please visit www.railsafetysummit.com



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