HomeRail NewsTime to improve rail safety by cutting down on 'essential paperwork'

Time to improve rail safety by cutting down on ‘essential paperwork’

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My memory is long enough for me to remember when engineers used slide rules and mechanical/electrical calculating machines. We generated far less paperwork than we do today and for the sake of safety, cost, time and accountability I believe it is time for us to review and look to reduce the “essential paperwork” we now accept as necessary. Writes Colin Wheeler

PICOP or paper responsibility?

The current Network Rail Safety Central website includes IGS Bulletin 268 dated 26th October. This refers to a recent incident but unfortunately fails to give us the details that would bring the potential dangers home to readers.

The instruction refers to the “Line Clear” verification process used in areas controlled by axle counter signalling. It emphasises the importance of the filling in of a VMF (Vehicle Management Form) recording movements from and into possessions with the COSS, ES, PICOP, (Controller of Site Safety, Engineering Supervisor, Person in Charge of Possession) and Signallers all having input before being scrutinised by the PICOP when restoring track to traffic.

The Bulletin says, “in a recent incident, track would have been handed back clear and safe to run but for a call from a tamper operator with a tamper standing on the line – invisible to the
signaller as Engineering Possession Reminders were in use”.

It calls for paper versions of the VMF to be used not the electronic versions in future! If there were no forms surely the PICOP would feel bound to ensure all work groups were clear by obtaining assurances or even walking through?

Paperwork too detailed!

I am indebted to the reader who told me of a formal inquiry that identifies numerous defects in the setting up of a safe system of work. The COSS record gives one name as COSS but another was added later. Only the relevant month is given on the form with no specific date.

The authorisation of the COSS pack is blank, the COSS declaration unsigned, and Green Zone working arrangements are shown, although the work areas were within two metres of running edge. Is it just possible that being a practical person, the real COSS gave up on the task of checking everything in detail and instead accepted what he was given, in the knowledge that he could safely organise the work without relying on the paperwork?

Or maybe he was motivated to take risks and work within two metres of the running edge without suitable lookout protection to get the job done? My reader believes it is the latter!

Only the paperwork those on site want

If the paperwork is worth having then those doing the work of PICOP, COSS and ES will want it, and surely ought to be involved in compiling it? They will then own it and make sure it includes what they need and nothing more.

Mandating its compilation by others increases the tendency for those on site to look for “better” ways of getting the job done. The assumption being that the person in the office doesn’t really understand what it’s like on site!

“Human Factors” is the de-personalising phrase that tends to be used. I prefer to think of it in more intimate terms. Knowing the people you are leading and managing is all important; as is an understanding of their hopes, fears and motivations at work.

The Rail Accident Investigation Branch (RAIB) recently published their report into a near miss on a level crossing at Four Lane Ends, near Burscough Bridge in Lancashire on Friday September 28th.

The barriers are hand operated from the Signal Box, kept in the down position and are raised to let vehicles across. They were in the raised position when the road vehicle and a train travelling at 60 mph were involved in a near miss due to “human error”. RAIB are focussing their attentions on the current design of crossing. Was the cause just a mistake or as I suspect, were there other reasons?

The cost of paperwork

Still more paperwork is on the way for the lawyers and even those working on our railway. December 12th will see the arrival of rule book updates. Consequently, the NCCA (National Competency Control Agency) has sent out notification to training organisations telling them that they must now purchase new Track Safety Training and Assessment packs at £500 plus VAT each (or £75 less for members of the Association of Railway Training Providers).

Do we need the revised rules and are they significant enough to warrant the replacement of the existing track safety training and assessment packs rather than the issuing of cheaper updates?
What will be the cost of issuing the Rule Book amendments and changing the training plans and assessments? Who will be most affected, those working on the railway or those involved in the assurance records after things go wrong?

Tandem Lifting – RRV TV

The Safety Central website features a Tandem Lifting video described as the First Episode of RRV TV! It demonstrates the process to be followed when lifting with two road-rail vehicles (RRVs). A Lift Planner is briefed and a site visit arranged.

Track gradient, cant, lifting points, line-side hazards and obstructions are taken into account. It emphasises that the choice of plant rests with the
planner who should choose suitable plant after discussion with the plant hirer, rather than by price! Will that really happen?

The compilation of a step-by- step Safe System of Work and a Crane Controller’s Brief comes next, with the latter being discussed with the Crane Controller. This late involvement of the Crane Controller concerns me. The video stresses that only the Planner may change the arrangements.

For me the credibility fell short when a track scene showed a track patroller waiting for permission to walk past the load until the machines had been brought to a standstill. However, I welcome the advertised availability of Tandem Lifting Guides for what can be a hazardous job. But planning the work in that detail without involving the Crane Controller from the outset is surely a wrong principle?

Close Call System controlled by principle contractors

Network Rail’s Safety Central website claims “the Close Call System gets even better from 29th October”. The Close Call System started back in June last year, but from 1st August this year membership of it has been mandated on all Principal Contractors registered with Network Rail.

Presumably this was done to ensure a flow of close call reports to satisfy the regulatory authorities. A design group including the principal contractors’ Infrastructure Safety Liaison Group, Railway Safety and Standards Board (RSSB), IBM and Network Rail developed the new system.

RSSB is offering “super user training lasting just one day”. A pdf is available to explain the details and the website www.closecallsystem will host the reports. The intentions are good. However, I am concerned for all who work for organisations that are not registered Principal Contractors.

Their reporting route must now be through the relevant principal contractor. How often will such reports be altered or even supressed to ensure that only the subcontractor or agency staff are shown up as culprits? If an inquiry follows an incident will all relevant employers be represented on the panel or just the principal contractor?

The real danger is of even more suppression of information due to commercial pressures.

When will track safety start to improve?

Last month I posed the question, “When will we begin to see an overall improvement in safety culture and performance”. I support the simplification indicated by Network Rail’s Life Saving Rules and welcome the support which I believe is to come from railway trades unions on this initiative.

I again question the need for a Rule Book. Without it, would we need regular re-issue of Track Safety Training plans and assessment tools? We have over the years amassed more and more rules and procedures and with them a mountain of paperwork.

I recall suggesting that every site needed a rail mounted wheelbarrow merely for transporting the paperwork!

Saving money and paper too!

Surely the time must now have come when a serious attempt is made to not only reduce the paper but more importantly give back the responsibilities to those who spend their working lives on site doing the work?

In the early days of the old Track Safety Strategy Group they relied on a group of hands on supervisors to accept or reject safety improvement ideas and more importantly come up with their own sensibly unprofessional initiatives. It worked. Track staff respected and accepted their safety initiatives.

Our objective should be to win respect for the skills, abilities and motivation of track staff. Get that right and safety culture and performance will at last improve, administration and legal costs will fall and far less paper will be wasted!


  1. I have worked in the railway industry for 42 years. The thing I would point out is how many track workers have been killed in the last 5 years? Compared with the number killed in my first 5 years it is a vastly significant lower number. We had no real track safety training when I started you learnt from your peers. Sadly there was a COSS/Site Warden killed just before Christmas. The previous trackside fatality was the distant lookout at Whitehall in Leeds with was December 2009. So I think the Rail Industry, RSSB and Network Rail must be getting something right.


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