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Do rules keep trackworkers safe?
by David Shirres

Before he retired from Network Rail last year, David Shirres had worked on track safety initiatives for ten years and had been frustrated at the lack of action to address the underlying causes of track safety incidents which were often blamed on individuals who had made a genuine mistake whilst working in difficult conditions. To highlight this issue he wrote the following article which appears in the August 2010 issue of 'Modern Railways' magazine. He is also giving a presentation to a rail safety conference run by the Institution of Occupational Safety and Health in November. To help him prepare for this presentation, he would welcome ideas on how track safety can be improved and any comments on this article. Please send these, in confidence, to -
A remarkable scene of industry at a worksite in Polmont.
Photo: David Shirres

The risk to trackworkers is close to the HSE’s upper limit of tolerability and improving possession productivity is a key element of Network Rail’s Strategic Business Plan. Despite this, arrangements to manage engineering work require significant improvements.   

Track safety rules are in various Rule Book modules whose scope is not clear. For example the difference between 'Protecting Engineering Work' (module T2) and 'Possession of the Line for Engineering Work' (module T3) is not apparent. The 'Possession' of module T3 is primarily concerned with the Engineer having possession of the line to control engineering train movements. As a result, a full set of rules to control engineering work requires rules to be bolted on from other Rule Book modules resulting in rules that can be both impractical and unclear. Emphasis on train movements also results in the following misleading terminology -

  • Person in Charge of Possession (PICOP) - the PICOP takes Possession of the line from the Signaller and authorises worksites to be set up but has no authority over the work that takes place within Possession Worksites.

  • Engineering Supervisor (ES) - the ES controls train moves within a Possession Worksite and is not necessarily either an Engineer or a Supervisor.

  • Controller of Site Safety (COSS) - the COSS controls site safety in respect of train movements but does not control the actual work.

  • COSS’s Site of Work - the area controlled by the COSS which may only be part of a Possession Worksite.

Lack of clarity of allowable speeds in Possession Worksites is illustrated by a letter to Modern Railways in April 2008 from Andrew Sharpe of RSSB which incorrectly states that in possession worksites "when the safe system of work does not depend on lookouts, trains must proceed at extreme caution". This statement applies to the COSS’s Site of Work rather than the Possession Worksite which normally includes both the COSS’s Site of Work and the access point which may be some miles away. Moving at extreme caution for long distances in a Possession Worksite where no-one is working unnecessarily reduces productivity.

A Rule Book that defines possession safety arrangements in separate modules is symptomatic of the lack of a holistic approach to track safety. Another example of this disjointed approach is specifying limits in possessions in different ways as shown below -

Specified by
Signals and/or points numbers
Possession Worksite
COSS's Site of Work
Possession rules do not require COSS’s Site of Work to be defined
Isolation limits
Electrification mast numbers
Access points

Control of risk in possessions requires both rules and effective supporting processes. This is another area needing improvement as demonstrated by the following -

  • Situational awareness - A lesson from many possession incidents is that it is essential for personnel to have situational awareness of all aspects of the possession. This is particularly important for project contractors who may work throughout the rail network. Diagrams are an effective way of providing such awareness; with various limits specified in different ways it is difficult to see how a complex possession can be managed safely without diagrams. There is however no requirement to produce possession diagrams and it would seem that Network Rail has no process to meet its legal obligation to provide contractors with the required information to produce such diagrams (e.g. location of signals).

  • Facilities for PICOPs and ESs - Many possessions are managed from a van by PICOPs and ESs who have to rely on their memory and local knowledge. In contrast the Signaller has a panel with the required information. For complex Possessions, suitable facilities are essential to reduce risk from reliance on human memory. As appropriate this could include an office, magnetic marker board with diagram. One ES advised "I’d rather control a complex worksite with facilities such as this than a simple worksite from the back of a van."

  • COSS competency - The COSS’s function in both Possessions and on the open line is to establish a safe system of work to protect the workgroup from trains. On the open line this is a demanding role requiring one of eleven different safe systems of work to be established. In a Possession with all lines blocked the safe system of work has already been established and the COSS’s role is to authorise work to start when permission is received from the ES. In comparison with work on the open line this is straightforward task. Although many COSSs only work in possessions, to do so they must be have the full range of COSS competencies. This presents a risk as competence to work on the open line will only be retained if practised regularly. The lack of an 'all lines blocked' Possession COSS competency wastes significant training investment and makes it not being feasible for many who supervise work in possessions to hold a COSS competency. As a result possession workgroups will often have both a COSS and Site Supervisor responsible for their site safety. 

  • Complexity of communications - In addition to the above, the Rule Book requirement for each COSS to hold an isolation permit can further complicate possession communications as the COSS cannot start work without the ES’s authority as shown below. 
Authority to Work communications
Current arrangements
(1) Nominated Person issues isolation permit (2) Assumes 50% of Site Supervisors do not hold COSS competency
Proposed arrangements

Given its importance, these and other deficiencies within controls for engineering work are surprising. One reason for this is perhaps an industry culture focused on rule compliance. Although this is a great strength, it can lead to a blame culture that does not tolerate genuine errors made by competent individuals working in difficult conditions. Thus lessons may not be learned from incidents which may be deemed to be the individuals' fault.

...lessons may not be learned from incidents which may be deemed to be the individuals' fault.

Network Rail is the employer of all who work on the track and so has the legal duty to control work on track, including the specification of Rules. However Track Safety Rules are Railway Group Standards produced by RSSB in accordance with the Group Standard Code that requires widespread stakeholder consultation. As a result rules changes can take years. Track Safety Rules are produced by RSSB’s 18-member Traffic Operation and Management Standards Committee, only three of whom are from Network Rail. The main concern of this committee is real-time train operations which is a very different matter from planned engineering work. Group Standards are required for processes involving cooperation between rail duty holders. It is not clear why Track Safety Rules should be a Group Standard as this is under Network Rail’s control. With Track Safety Rules produced by RSSB and Network Rail responsible for supporting processes, there is a lack of focus for the specification of Possession risk controls.

Do rules keep trackworkers safe? Although the Rule Book enshrines much good practice, the examples in this article and other issues show that there is a requirement for improvement in both Track Safety Rules and supporting processes. This requires a cohesive approach with Network Rail taking ownership of all track safety risk controls. Unless this is done it is likely that the risk to trackworkers will remain at the upper limit of tolerability and Possession rules will continue to unnecessarily reduce productivity. This is a situation that should not be allowed to continue.

Story added 1st August 2010

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