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Railway Group Guidance Note GA/GN6510 Issue Two Date June 2001

Guidance on Submitting Material Revisions to Railway Safety Cases

This Guidance Note has been produced by Standards Project Manager

Authorised by Controller, Railway Group Standards

Synopsis This document provides practical advice to members of the Railway Group on submitting material revisions to railway safety cases.

This document is the property of Railway Safety. It shall not be reproduced in whole or in part without the written permission of the Controller, Railway Group Standards, Railway Safety. Published by: Railway Safety Evergreen House 160 Euston Road London NW1 2DX © Copyright 2001 Railway Safety

Uncontrolled When Printed

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Railway Group Guidance Note GA/GN6510 Issue Two Date June 2001 Page 1 of 19

Contents Section Description Page

Part A

Issue Record 2 Technical Content 2 Application 2 Health and Safety Responsibilities 2 Supply 2

Part B

1 Purpose 3 2 Scope 3 3 Definitions and Abbreviations 3 4 What Constitutes a Material Change 4 5 Making Non-Material Changes to a Railway Safety Case 8 6 Submitting a Material Change 9 7 The Assessment/Acceptance Process 11

Appendix A Assessment Criteria for Material Revisions to Railway Safety Cases 15

References 18

R A I L W A Y S A F E T Y 1




Part A Issue Record

This document will be updated when necessary by distribution of a complete replacement.

Issue Date Comments One August 1999 Original Document – supersedes

GA/RC6505 Two June 2001 Revised to reflect introduction of RSC

Regulations 2000. No amendment bars have been used because the document has been extensively revised.

Technical Content

Approved by:

K Sutton, Railway Safety Case Assessment Manager, Railway Safety

Enquires to be directed to Railway Safety – Tel: 020 7904 7518

Application

Railway Group Guidance Notes are non-mandatory documents providing helpful information relating to the control of hazards and often set out a suggested approach, which may be appropriate for Railway Group* Members to follow.

* The railway group comprises Railtrack PLC, Railway Safety, and the train and station operators who hold railway safety cases for operation on or related to infrastructure controlled by Railtrack PLC.

Health and Safety

Responsibilities In issuing this document, Railway Safety makes no warranties, express or implied, that compliance with all or any document published by Railway Safety is sufficient on its own to ensure safe systems of work or operation. Each user is reminded of its own responsibilities to ensure health and safety at work and its individual duties under health and safety legislation.

Supply

Controlled and uncontrolled copies of this document may be obtained from the Industry Safety Liaison Dept, Railway Safety, Evergreen House, 160 Euston Road, London NW1 2DX.

2 R A I L W A Y S A F E T Y




Part B 1 Purpose

The purpose of this document is to give guidance to the duty holder of a Railway Safety Case (RSC) which has been accepted pursuant to either the Railways (Safety Case) Regulations 1994 or 2000, in order to revise its contents whenever appropriate and send the proposals of any material revision to Railtrack PLC (known as Railtrack) and Railway Safety for assessment and HSE for acceptance.

2 Scope 2.1 Scope of this Guidance Note This Guidance Note applies to material revisions made to the Railway Safety Cases of train and station operators that are assessed by Railtrack and Railway Safety and accepted by the HSE. It also applies to material revisions made to Railtrack’s Railway Safety Case that are assessed by Railway Safety and accepted by HSE.

Railway Safety’s assessment criteria for train and station operators’ railway safety cases are described in GA/GN6509 and for Railtrack’s Railway Safety Case in GA/GN6508. These same Guidance Notes also explain the respective assessment/acceptance processes for a new railway safety case or a three-year review of an already accepted railway safety case. The reason as to why the three-year review process is outlined in GA/GN6509 and GA/GN6508 rather than this document is because Railway Safety expect operators and Railtrack as part of this review, to consider changes made to the assessment criteria since the duty holder’s previous three-year review (or if the first such review, since the RSC was accepted).

3 Definitions and Abbreviations

3.1 Definitions 3.1.1 Railway Group The Railway Group comprises Railtrack, Railway Safety and the train and station operators who hold railway safety cases for operation on or related to infrastructure controlled by Railtrack.

3.1.2 Railway Group Standards Comprise: (i) technical standards with which railway assets (or equipment used on or as

part of railway assets) must conform (ii) operating and management procedures with which all operators of railway

assets, including the infrastructure controller, must comply.

3.1.3 Railtrack controlled infrastructure The infrastructure which falls within the geographic boundaries of Railtrack’s operational railway, includes the permanent way and land within the lineside fence, and plant used for signalling or exclusively for supplying electricity for operational purposes to Railtrack’s operational railway. It does not include stations, nor does it include depots, yards or sidings owned by, or leased to, other parties. However, it does include permanent way at stations and plant within these locations used for signalling Railtrack’s operational railway or exclusively for supplying electricity for operational purposes to the operational railway.

3.2 Abbreviations ATP Automatic Train Protection CCTV Closed Circuit Television ETA Event Tree Analysis FMEA Failure Modes and Effect Analysis FTA Fault Tree Analysis HAZOP Hazard and Operability Study HSE Health & Safety Executive





JDs Job Descriptions OTM On Track Machine QRA Quantified Risk Assessment Railtrack Railtrack PLC RGS Railway Group Standard – Produced by Railway Safety RMMM Rail-Mounted Maintenance Machine RRV Road-Rail Vehicle RSC Railway Safety Case RSC Regs 1994 Railways (Safety Case) Regulations 1994 RSC Regs 2000 Railways (Safety Case) Regulations 2000 SMS Safety Management System SWIFT Structured What If Technique SRSs Safety Responsibility Statements TPWS Train Protection Warning System

4 What Constitutes a Material Change

Railway Safety defines a material change as any change to the duty holder’s

• Operations / scope

• equipment

• organisation

• control measures

• or maintenance policy

which has the potential to increase risk on Railtrack’s controlled infrastructure. It should be noted that a material change can arise even if the existing RSC does not specifically mention the detail of the current operations, equipment, organisation or control measures, for which the change is being proposed. A material revision to a RSC is the corresponding amendment to the RSC related to that change.

The following are examples of material and non-material changes in each of the above categories:

4.1 Change in scope of operations 4.1.1 Material changes a) Introduction of new operations

i) The introduction of passenger services by a duty holder who previously operated only freight services, or vice versa.

ii) The introduction of on-track machine, Road-Rail Vehicle (RRV) or Rail-Mounted Maintenance Machine (RMMM) operations by a passenger or freight operator, or vice versa.

iii) The introduction of on-track machine operations by a duty holder which has previously only operated RRVs and RMMMs.

iv) The introduction of special, charter, parcels, steam operations where such trains were previously not operated. Also, scope to carry out testing of rail vehicles (see GM/RT2000 and GM/RC2559).

v) The introduction of dangerous goods, piggy-back or container train operations where previously not operated.

b) Introduction of new risks

Any change to the scope of operation which introduces a type of risk which the duty holder does not currently manage. This type of change includes running trains on overhead or conductor rail electrified lines where previously this was not





the case, stopping at sub-surface stations or stations with short or low platforms, introduction of driver-only operation, etc.

c) Modifications to existing operations

(Note: If the duty holder’s RSC describes the change management arrangements for identifying new or changes in risk, and demonstrates how these risks are reduced to as low as reasonably practicable as a result of a modification to the existing operation described below, it will not be necessary to submit a material change.)

i) Any significant extension of the geographical scope of operation (eg increases the overall route mileage operated over by more than 10%, or for OTM/RRV/RMMM operators, geographical area coverage increases by more than 20%). (Note 1: this applies to cumulative increases since the last accepted RSC.)

ii) As a general principle, any increase of more than 20% in the total mileage of trains operated over a particular route or the numbers of vehicles operated. (Such changes should initially be discussed with the assessing/acceptance bodies as a higher or lower figure may be applied depending on the nature and location of the duty holder’s existing scope of operations.) (Note 1:This applies to cumulative increases since the last accepted RSC.)

iii) Any extension or change to the scope or nature of operations which causes a significant increase in any particular risk currently managed by the duty holder (eg a significant increase in the number of sub-surface stations, short or low platforms which the duty holder’s operated trains call at, etc).

d) Use of hired-in resources

i) Operation of vehicles or use of safety critical personnel hired from other Members of the Railway Group where not provided for in the duty holder’s RSC.

ii) Operation or use of resources hired in from other than suppliers who are the holders of a RSC assessed by Railtrack and Railway Safety, (ie outside of the Railway Group) where not provided for in the duty holder’s RSC.

4.1.2 Non-material changes Any minor extension or change to the scope of work that does not introduce a new type of risk that the duty holder does not currently manage, and is not defined above as a material change.

4.2 Changes to new or used equipment 4.2.1 Material changes a) Introduction of new equipment

i) The introduction of new classes of traction, rolling stock or vehicles which introduce a new type of risk which the duty holder does not currently manage (eg slam door stock, power operated doors, central door locking, overhead or conductor rail electrified stock, multiple units, loco hauled stock, tilting trains, selective door opening, in-cab CCTV for train despatch, cranes).

ii) Introduction of automatic ticket gates (ATGs) at a duty holder’s operated station.

(Note: It is the intention to publish a Railway Group Standard detailing criteria for the installation of ATGs at stations. Publication of this RGS will result in many ATG schemes not requiring a material change to the RSC to be submitted, provided the RSC describes the process by which each ATG scheme is planned, validated and implemented.)

b) Modifications to existing arrangements for use of equipment





The introduction of powered platform vehicles at a station. (Note: If the duty holder’s RSC describes the process by which the introduction of powered platform vehicles at a station is safety validated, it will not be necessary to submit a material revision.)

4.2.2 Non-material changes i) The introduction of new classes of traction, rolling stock or vehicle that do not

introduce a new type of risk which the duty holder does not currently manage. (Note: the duty holder must still complete the necessary vehicle acceptance and route clearance processes.)

ii) The fitment of on-train data recorders on classes of traction.

iii) The fitment of sanders on classes of traction.

4.3 Organisational changes

4.3.1 Material changes

(Note: if a duty holder is proposing an organisation change as described in this section, the duty holder should always contact the RSC assessment/acceptance bodies in order to determine whether the proposed change will be considered material)

The following organisation changes may be considered material: i) Significant changes to the responsibilities, competence requirements or

position/level in the organisation of professional heads/informed buyers. This includes arrangements to contract out any/all of the professional headship responsibilities or vice versa.

ii) Significant changes in resource levels of staff/contractors carrying out safety critical work, or directly supervising or managing safety critical work, or supporting professional heads, or within headquarters safety departments or line safety support staff. (Note: generally a reduction in resource level of 10% or more should be considered significant. Note that this applies to cumulative changes since the last accepted RSC. Where the reduction in resource levels relates to a genuine reduction in workload, the change should still be submitted but the change may be deemed non-material.)

iii) Synergies with another RSC duty holder’s organisation that affect any of the organisational arrangements described in the respective RSCs for the management of safety.

(Note: In order that the RSC assessment/acceptance bodies might be able to determine that an organisation change described above can be considered as being non-material, the duty holder should describe within its RSC the change management arrangements for ensuring new or changes in risk associated with the organisational change are reduced to as low as reasonably practicable.)

4.3.2 Non-material changes i) Changes to those parts of the organisation not directly involved in carrying

out, supervising or directly managing safety critical work or supporting professional heads of fleet engineering, train or station operations or occupational health and safety.

ii) Minor changes in resource levels of staff or workload carrying out, supervising or directly managing safety critical work. (Note: generally a reduction in resource level of less than 10% is considered minor.)





4.4 Changes to measures for controlling risk 4.4.1 Material changes a) Introduction of new arrangements

i) Introduction of arrangements for the despatch of trains which are not covered fully in the Rule Book (GO/RT3000).

ii) Introduction of remote booking on or lodging for traincrew.

b) Modification to existing arrangements

(Note: If the duty holder’s RSC describes the change management arrangements for identifying new or changes in risk, and demonstrates how these risks are reduced to as low as reasonably practicable for any of the modifications to arrangements described below, it will not be necessary to submit a material change.)

i) Significant changes to policy, standards or procedures for controlling those risks identified in the duty holder’s RSC as being high category risks.

ii) Significant changes to procedures for the recruitment, selection, training, assessment and monitoring of safety critical staff/contractors.

iii) Increases to the working hour limits for safety critical staff.

iv) Significant changes to operational procedures, eg division of responsibility for train preparation between traincrew/maintenance personnel/contractors, merging of the train operator’s control with that of another duty holder’s control, freight train loading procedures.

v) Significant changes to the arrangements or facilities available for the evacuation of trains.

vi) Significant changes to supplier/contractor qualification and management processes, particularly of vehicle and safety critical resource, service or component suppliers.

vii) Significant changes to driver briefing arrangements, including any proposal to reduce the frequency of briefings.

viii) Significant changes to the arrangements for engineering or route acceptance of trains or vehicles, design control, safety related defect monitoring and response.

ix) Significant changes to key interface arrangements, such as change in Railtrack Lead Zone or reduction in frequency of key interface meetings with Railtrack, other operators, key contractors or suppliers.

x) Significant changes in audit procedures.

xi) Significant changes in the arrangements for remote booking on or lodging for traincrew.

4.4.2 Non-material changes i) Changes to arrangements for controlling minor risks.

ii) Minor changes to arrangements for controlling high category risks (eg marginal changes to control measures that may be identified during the review process).

iii) Changes to procedures required ensuring compliance with altered legislation or Railway Group Standards.





4.5 Changes to the Maintenance Policy 4.5.1 Material Changes a) Introduction of new arrangements or equipment

i) Contracting out of vehicle maintenance.

ii) Operation of hired in vehicles or vehicles operated on behalf of Railtrack (where previously not operated).

iii) Operation of new classes of train or vehicle that introduce new maintenance risks that require controlling.

b) Modifications to existing arrangements

(Note: If the duty holder’s RSC describes the change management arrangements for identifying new or changes in risk, and demonstrates how these risks are reduced to as low as reasonably practicable for any of the modifications to arrangements described below, it will not be necessary to submit a material change.)

i) Significant changes in the roles and responsibilities for those posts responsible for the execution of the maintenance policy.

ii) Significant changes to the maintenance arrangements and procedures described within the maintenance policy.

4.5.2 Non-material changes i) The introduction of new classes of traction, rolling stock or vehicle that do not

introduce a new type of maintenance risk which the duty holder does not currently manage.

ii) Minor changes to organisational responsibilities or maintenance arrangements described in the maintenance policy.

5 Making Non-Material Changes to a

Railway Safety Case 5.1 Making non-material changes Examples of material and non-material changes are included in section 4. Where the change clearly falls into one of the categories identified in section 4 as being non-material, the duty holder should make the non-material revision and send out controlled copies of the amendments to the RSC in accordance with their document control process. There is no requirement to submit the proposed revision in advance to the HSE, Railtrack or Railway Safety. Should a duty holder present details of a non-material revision to any of the assessing/acceptance bodies, confirmation will be sent to the duty holder that the proposal is non-material. However, a revision number will not be allocated to non-material revisions, as had been the practice by Railtrack under the RSC Regs 1994.

5.2 Doubts as to materiality of a change Duty holders will appreciate that it is not possible for the HSE, Railtrack or Railway Safety to anticipate in advance every type of revision that a duty holder may wish to make to a RSC and there will, therefore, always be a grey area between the two definitions. In this case, the duty holder will have to submit the revision to the HSE and Railtrack with a copy to Railway Safety for them to decide whether or not the proposal is material. The assessing/acceptance bodies will always be willing to discuss any proposal with the duty holder to clarify any doubt. In the event that Railtrack and Railway Safety consider a change to be non-material whilst the HSE consider that change to be material, the change will be assessed as a material revision by all of the bodies involved. Similarly, if HSE consider a change to be non-material but Railtrack and Railway Safety have





reasons for classifying the change as being material, all bodies will process the change as material.

6 Submitting a Material Change

6.1 Meeting to discuss a material change The assessing/acceptance bodies will make arrangements to meet a duty holder to discuss the nature of a material change should a duty holder make such a request. Advice will be provided on the documentation that will be required to accompany the submission and whether the assessing/acceptance bodies are likely to determine that the change or elements of the proposal will not be recommended for acceptance/accepted. Should a duty holder wish to make use of this facility, it is recommended that an approach be made to Railtrack or Railway Safety. Arrangements will be made for a meeting with the duty holder and HSE will be consulted by Railtrack or Railway Safety to see whether they would wish to be represented at such a meeting.

The principal contacts on all matters relating to the assessment and acceptance of Material Revisions to RSCs are as follows:

Organ- isation

Contact Address Tel No.

Railtrack

TOC Railway Safety Case Manager

Railtrack House, DP06, Euston Square, London, NW1 2EE

0207 557 9352

Railway Safety

Railway Safety Case Assessment Manager

Evergreen House, 160 Euston Road, London, NW1 2DX

0207 904 7717/8/9

HSE

Railway Safety Case Administration Manager

HM Railway Inspectorate, Health & Safety Executive, Rose Court, 2 Southwark Bridge, London, SE1 9HS

0207 717 6133

6.2 Documentation required for a material change It is recommended that each proposal should contain the following information:

a) A description of the change.

b) A suitable and sufficient risk assessment of the change.

c) Details of any additional control measures.

d) Details of any additional temporary monitoring arrangements.

e) Confirmation that any required consultation has been carried out.

f) Details of the actual amendments to the RSC.





6.2.1 Description of change Those proposals which contain a clear and concise description of the change, are likely to be accepted more quickly than those that consist only of the amended pages to the RSC.

6.2.2 Suitable and sufficient risk assessment of the change The proposal should contain a suitable and sufficient assessment of the risks associated with the change and the implications for other hazards and control measures. This should include a description of the risk assessment methodology and a justification for that methodology, demonstrating that suitable techniques of hazard identification and risk assessment, appropriate to the type of change being proposed have been applied. The assessment should be of sufficient depth and breadth of analysis in relation to the risk and with reference to relevant data and information to support the assessment. Further guidance, contained in Appendix A of this document, outlines the assessment criteria which Railtrack and Railway Safety will apply when validating changes.

The type of risk assessment will depend on the nature of the change and the availability of data and information. In some cases it may be a simple verbal argument supporting the change. For more complex changes, some form of numeric risk ranking or quantified risk assessment may be appropriate. It may also be appropriate to refer to risk assessment work and other studies carried out by other parties. In these cases, the sources of information and data should be clearly referenced. For more complex assessments, it is useful to include a summary of the risk assessment in the form of an argument supporting the changes. In all cases the duty holder should reach a clear conclusion on the effect that the change has on overall risk. He should also state that where there is some increase in risks, these are reduced as low as reasonably practicable by additional or amended control measures.

Depending on the nature of the change being proposed and the results of the risk assessment, it may be necessary for the duty holder to amend the existing risk assessment section of the RSC.

6.2.3 Additional control measures Where the risk assessment indicates a significant increase in risk due to the change, the document must contain a description of additional or amended control measures that the duty holder will introduce to reduce the risk as low as reasonably practicable. The duty holder should provide enough information about the additional or amended control measures, including organisational arrangements for implementing them, to give the respective assessment/acceptance panels the assurance that these measures are capable of reducing the risks as low as reasonably practicable.

Depending on the nature of the change and the confidence the duty holder has in the risk measurement, it may be prudent to introduce temporary additional monitoring or control arrangements that will give early indication of problems associated with the change. These measures should be described in the proposal, including details of who will be responsible for carrying out the monitoring and taking further action if required. The proposal should also indicate for how long the additional monitoring will be carried out.

6.2.4 Consultation Each proposal should include confirmation that, where required, consultation with other parties has been completed, or will be completed prior to implementation, and that the views of these other parties have been, or will be, taken into account. Particular attention should be given to consultation with staff as required by the RSC Regs 2000, the Health & Safety (Consultation with Employees) Regulations 1996, the Safety Representatives & Safety Committee Regulations 1977, and also any other party whose activities interface with those of the duty holder on Railtrack’s infrastructure and who may be affected by the change.

6.2.5 Actual changes to RSC The proposal for material change should make clear the actual amendments to the RSC. The proposal should include the present and proposed versions of

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each part of the RSC affected by the change. This should include paragraphs deleted, amended paragraphs and additional paragraphs. Revisions should be indicated by some means, such as a margin bar, underlined or identified in italics.

It is important that the duty holder carries out a review of the entire RSC to identify all parts of the RSC affected by the change. Particular attention should be paid to possible amendments required to the description of operations and/or equipment, the assessment of risks, the control measures described in the safety management system, responsibilities of professional heads and other key safety management posts, and arrangements for managing interfaces.

The duty holder should also check that the revised arrangements in the RSC are consistent with the relevant assessment criteria described in either GA/GN6508 or GA/GN6509, as appropriate.

7 The Assessment/ Acceptance Process

(Note: Material changes to Railtrack’s Railway Safety Case are only assessed by Railway Safety.) 7.1 General 7.1.1 Submission of the material revision When the material revision is ready for formal submission, the documentation must be sent to the HSE and to Railtrack, at the addresses shown in section 6.1. This requirement meets regulation 7(3) and 2(10) of the RSC Regs 2000. Documents may be sent electronically.

In addition, to enable Railway Safety to commence their assessment process as required by regulation 7(10) as quickly as possible, a copy of the material revisions should be forwarded to them at the address shown in section 6.1. To also speed the process along, it is helpful if a copy is sent direct to the Railtrack Lead Zone. The submission that goes to Railtrack should indicate that copies have been sent to both Railway Safety and the Railtrack Lead Zone.

The duty holder will receive confirmation from both HSE and Railtrack that their submissions have been received. There will be no acknowledgement from Railway Safety or the Railtrack Lead Zone. A unique reference number is issued by Railtrack that is adopted by all organisations involved in the assessment/acceptance process. This unique number will take the form of the duty holder’s RSC certificate number and a revision number. All revisions under the RSC Regs 2000 will start at 101 for each train and station operator. Separate referencing applies to changes to Railtrack’s RSC.

Where an electronic copy of the submission has been sent, it is not normally necessary to forward a hard copy.

7.1.2 Initial assessment of the RSC by Railtrack and Railway Safety Both Railtrack and Railway Safety immediately on receiving the submission, begin their respective assessment processes. The assessment will take the form of a scrutinisation of the documentation required by section 6.2 as well as referring to the relevant parts of GA/GN6508 or GA/GN6509, where this is necessary. The respective assessment processes are undertaken by a panel of RSC assessors experienced in the relevant aspects of train and station operations or infrastructure control and the management of health and safety.

The respective panels consist of:

a) a chairman, normally the TOC RSC Manager in the case of Railtrack, the RSC Assessment Manager in the case of Railway Safety

b) a process manager, and a number of specialist assessors are appointed jointly by Railtrack and Railway Safety.

The specialist assessors are experienced and competent managers in the fields relevant to the matters to be assessed in the proposal, such as train or station

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operations, vehicle engineering, asset management, risk assessment or health and safety management systems and requirements. Railtrack also involve the Lead Zone in their assessment. Competency criteria are set for panel assessors.

Where both Railtrack and Railway Safety are satisfied from their initial review that the submission meets the requirements of the criteria described above, the arrangements described in 7.1.6 are applied. However, for the majority of submissions reviewed, the respective panels during the review of the RSC, identify issues to be resolved prior to a recommendation for acceptance being made. Railway Safety’s issues are in the form of a report, as required by Regulations 5(3) and 7(10) of the RSC Regs 2000, which is forwarded to Railtrack. Railtrack incorporates these issues into a joint Railtrack/Railway Safety issues log that is forwarded to the duty holder.

7.1.3 Initial assessment of the RSC by HSE Details of the HSE’s initial acceptance process are described on the HSE’s website address at www.gov.uk/railway/rihome/htm.

The assessment/acceptance process allows for the HSE panel assessors to conduct a review of the joint Railtrack/Railway Safety issues log. The purpose of this review is for the HSE to identify any issues which in their view, should have been raised by either Railtrack or Railway Safety in their scrutiny of the submission within the scope of Regulation 2(4) of the RSC Regs 2000.

7.1.4 Requirement for a panel meeting For those material revisions that are proposing to introduce a new type of risk or control measure to the controlled infrastructure, the duty holder is invited to a panel meeting. There may also be other occasions when Railtrack and Railway Safety determine the need for a panel meeting. Examples of such occasions may be major organisational changes that the duty holder wishes to introduce, franchise migration of a passenger train operating company or where there is concern with the duty holder’s safety performance.

This meeting is normally conducted jointly by Railtrack and Railway Safety. HSE are also invited to attend but may determine that they will conduct their own separate panel review meeting. The purpose of the Railtrack/Railway Safety panel meeting is:

a) to allow the applicant to present his material revision proposals and any additional information deemed relevant

b) to explore issues of clarification as required by the panel

c) to indicate and discuss any major issues that may affect Railtrack or Railway Safety in making a recommendation that the material revision should be accepted

d) to assess the ability and commitment of the applicant to deliver the RSC commitments being proposed.

Following the panel meeting, the joint Railtrack/Railway Safety issues are updated to incorporate any amendments, etc. agreed at the panel meeting. This is then sent to the duty holder. Where Railtrack and Railway Safety determine the need for a panel meeting with a duty holder, an internal preliminary meeting is held involving the Railtrack and Railway Safety panel assessors. At this meeting, a draft joint Railtrack/Railway Safety issues log is prepared which is then forwarded to the duty holder in advance of the panel meeting with the duty holder himself.

7.1.5 Closing of Issues Railtrack (Railway Safety in the case of material changes to Railtrack’s RSC) enter into an iterative process with the duty holder on the closing out of issues. On each occasion that an updated issues log is received, the duty holder must amend the submission in accordance with the requirement(s) of each issue. When the duty holder considers that all issues on the issues log have been addressed, a revised submission together with the updated issues log must be





sent to both Railtrack and the HSE. This iterative process continues until all issues on the issues log are closed. The duty holder should indicate clearly where in the revised proposal each issue is addressed. All documents should be dated and changes sidelined to allow the acceptance panel to differentiate between the original proposal and any subsequent amendment and to ensure a clear understanding between the duty holder and the assessment panel as to which version of the proposal is finally accepted.

With regard to the closing out of Railway Safety’s issues that appear on the joint issues log, Railtrack may determine that it undertakes this aspect of the process itself. However, Railtrack normally requests Railway Safety to review a revised submission to assess that its originally raised Issues have been closed out. Indeed, the Railway Safety panel assessors can insist that they be consulted on the closing out of any issues they have raised. On the basis that this arrangement is applied in the majority of cases, the duty holder is encouraged to also forward the documentation referred to in the first paragraph of this section (7.1.5) to Railway Safety. Regulation 14(3) of the RSC Regs 2000 requires Railtrack to forward a record of the process it has applied to the assessment of each material revision to HSE. This requirement ensures that the HSE are advised where Railtrack has determined that issues raised by Railway Safety are indeed closed.

If the duty holder fails to address all the issues to the satisfaction of the Railtrack/Railway Safety panel and cannot agree a way forward on the outstanding issues, the duty holder may either withdraw the proposal or indicate that the most recent submission is the final submission. Should such a situation arise, Railtrack and/or Railway Safety will make a recommendation to the HSE that the submission should not be accepted, stating the reasons for this decision. The HSE will either accept the revision, or formally advise the duty holder in writing that the proposed material revision is rejected and shall state its reasons for rejection in accordance with regulation 7(7). The duty holder may then appeal to the Secretary of State in accordance with regulation 15(1) of the RSC Regs 2000.

7.1.6 Recommendation for acceptance On satisfactory completion of the Railtrack and Railway Safety assessment processes, Railtrack forwards to HSE its own recommendation for acceptance together with that made by Railway Safety. The documentation and statements required by Regulations 7(4) and 7(5) of the RSC Regs 2000 are also forwarded to HSE. Additionally, Railtrack is required by Regulation 7(6) of the RSC Regs 2000 to forward copies of both sets of recommendations to the duty holder.

7.1.7 Acceptance of the RSC by HSE Details of the HSE’s final acceptance process are described on the HSE’s web site address shown in section 6.1 of this document.

In accordance with Regulation 7(7) of the RSC Regs 2000, the HSE notify Railtrack as well as the potential/existing operator when the RSC has been accepted. If the HSE do not accept the RSC for the reasons shown in Regulation 7(7), the HSE process described on their web site is instigated, including liaison with Railtrack and Railway Safety as necessary.

On acceptance of the RSC by the HSE, the duty holder is then required to distribute hard controlled copies of the revised RSC pages to:

a) Railtrack (1 copy)

b) Railway Safety (1 copy)

c) Railtrack Lead Zone (1 copy)

d) HSE (2 copies)

e) Each train and station operator affected by the duty holder’s scope of activities (1 copy).





An electronic copy of the revised RSC pages should also be sent to Railtrack, Railway Safety and HSE at the E-Mail addresses specified in the respective close out correspondence received from Railtrack and HSE.

7.2 Timescales for assessment/acceptance The HSE have published on the website specified in 7.1.3 of this document performance standards for their RSC acceptance process. Accordingly, both Railtrack and Railway Safety have agreed to the following timescales:

a) Railtrack acknowledge receipt of the formal submission to the duty holder within 2 working days.

b) Railtrack and Railway Safety complete their initial assessment of the submission within 22 working days of receipt of the submission.

c) Where Railtrack and/or Railway Safety determine the need for a panel meeting with the potential/existing operator, this normally takes place within 30 working days of receipt of the submission.

d) The timescales for re-assessment of a submission that attempts to address issues raised on the joint Railtrack/Railway Safety issues log depends on the number and nature of the issues originally raised by the respective panels. However, both Railtrack and Railway Safety (where requested by Railtrack), complete this part of the assessment process within 15 working days of receipt of the revised submission.

Obviously, when a submission is back with a duty holder to address issues, the matter of timescales is outside of the control of Railtrack and where necessary, Railway Safety. However, all bodies involved in the assessment/acceptance of material revisions to RSCs will normally request from the duty holder a timescale as to when it is intended to re-submit the document.

Where it is not possible for Railtrack or Railway Safety to meet the timescales identified above, the duty holder is advised of the reasons why it has been necessary to resort to a revised timescale. It is not the intention of any of the organisations involved that timescales should be lengthened.





Appendix A: Assessment Criteria for Material Revisions to Railway Safety Cases

The following information is issued to Railtrack and Railway Safety RSC panel members as guidance on the criteria they may wish to propose when reviewing material revision to RSCs.

A.1 Quality of Documents Submitted

1.1 Does the submission contain an adequate description of the changes being proposed?

1.2 Does the submission contain a summary of the risk assessment with a conclusion as to the likely change in risk levels (if any)?

1.3 Where the risk assessment indicates a significant increase in risk, is there a description of additional or amended control measures to reduce this risk as low as reasonably practicable?

1.4 Does the submission clearly show the proposed amendment to the RSC?

1.5 Does the amended RSC continue to meet all the requirements of the RSC Regs 2000, the relevant parts of Railtrack’s/Railway Safety’s RSC assessment criteria published in GA/GN6509 and Railtrack’s RSC?

1.6 Does the amendment contain sufficient detail to enable an appropriate level of control? Generally additional control measures should be cascaded through the SMS section of the RSC to at least the same level of detail as existing control measures.

A.2 Risk Assessment 2.1 Methodology Have suitable techniques of hazard identification and risk assessment, appropriate to the type of change, been applied? Has a description of the methodology used and a justification for that method been provided?

a) Full QRA should only be considered where appropriate.

b) 5 x 5 matrix is generally suitable only as a broad risk ranking tool.

c) Qualitative risk assessment may be used provided information is suitably referenced.

d) Have subjective assessment techniques been used in preference to pure guesswork?

e) Appropriate use of recognised specialised techniques such as FMEA, FTE, ETA, HAZOP, SWIFT, etc.

f) Is use of the above tools part of a risk assessment framework?

2.2 Is there sufficient depth and breadth of analysis in relation to the risk? a) Does RA cover a broad enough range of parameters?

b) Has analysis of each parameter been of sufficient depth?





c) Is level of detail sufficient in relation to overall risk?

d) Sensitivity to assumptions made and data used.

2.3 Is there reference to relevant data and information? a) Has there been reference to sufficient data and information?

b) Are sources of data and information used, clearly referenced?

c) Is data and information used relevant to the arguments?

d) Is the argument within the scope of the data and information?

e) Are assumptions identified and justified - have assumptions been used where data and information could reasonably have been obtained?

f) Has data and information been used in the proper context?

g) Is reference to data and information unbiased, ie has unsupportive data and information been omitted?

h) Have the views of staff, or other persons with practical experience of the activities and risks involved, been considered?

A.3 Additional or Amended Control (where

necessary) 3.1 Does the proposal demonstrate that additional or amended controls are sufficient to reduce any increased risk as low as reasonably practicable?

3.2 Does the proposal contain enough detail on how the controls will be implemented and an assurance that other documents such as JDs/SRSs, procedures, interface arrangements, emergency plans, etc, have been amended where necessary?

A.4 Monitoring Arrangements

4.1 Where full QRA has not been possible and future risk levels cannot be confidently calculated, have special monitoring arrangements been specified which measure safety performance indicators for a specified period before and after implementation, with boundary levels clearly defined at which specific action will be taken by specific individuals?

A.5 Communication and Co-operation

5.1 Have staff and safety representatives been consulted where appropriate?

5.2 Does the change affect any other train or station operator and, if so, have they been consulted? Should a material change proposal from an affected operator be assessed in conjunction with the proposal being reviewed?





5.3 Is the amended RSC consistent with Railtrack’s RSC as well as the arrangements described in other operators RSCs that are affected by the proposal?

5.4 Does the change affect any other organisation and, if so, have they been consulted?





References Railway Group Standards

GA/GN6508 Criteria for the Assessment by Railway Safety of Railtrack’s Railway Safety Case

GA/GN6509 Guidance on Assessment by Railway Safety of Train and Station Operators’ Railway Safety Cases

GO/RT3000 Master Rule Book

GM/RC2559 Code of Practice – Safe Testing of Rail Vehicles on Railtrack Controlled Infrastructure

GM/RT2000 Engineering Acceptance of Rail Vehicles

Railway Group Safety Plan

Railway Group Standards Code

Catalogue of Railway Group Standards

The Catalogue of Railway Group Standards and the Railway Group Standards CD-ROM give the current issue number and status of documents published by Railway Safety.

Railtrack:

Railtrack’s Railway Safety Case

Acts & Regulations:

Health & Safety at Work etc Act 1974

Railways (Safety Case) Regulations 2000

Management of Health & Safety at Work Regulations 1999

Railway Safety Regulations 1999

Railways (Safety Critical Work) Regulations 1994

Safety Representatives & Safety Committees Regulations 1977

Fire Precautions (Sub-Surface) Regulations of 1989

Carriage of Dangerous Goods by Rail Regulations 1994

HSE Guidance:

HSE Railway Safety Cases - Guidance on the Railways (Safety Case) Regulations 2000

Further Reference Material Information HSE Guidance etc:

HSE Railway Safety Critical Work - Guidance on the Railways (Safety Critical Work) Regulations 1994

HSE Carriage of Dangerous Goods by Rail - Guidance on the Carriage of Dangerous Goods by Rail Regulations 1994

HSE Management of Health and Safety at Work Approved Code of Practice on the Regulations

HSE Safety Representatives and Safety Committees

HSE Successful Health and Safety Management





HSE Human Factors in Industrial Safety

HSE Quantified Risk Assessment: Its Input to Decision Making



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