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Safety - what inconveniences are committed in thy name
Let's start the year with a humble confession – I have run out of ways of dealing with the stupidity and obtuseness that runs like a virus through our industry's safety regulators. I've tried scorn, irony, satire, ad hominem abuse and ridicule: I've even been reduced to appeals to commonsense. All to no effect; it just goes on getting worse.
Of course, it's not new. The inquiries into the Clapham accident and the Kings Cross fire contained their fair share of stupidities and it is understandably difficult for railway managers, whose operation has killed people, to challenge inquiry findings. But that does not mean that common sense should be abandoned when those recommendations are implemented.
An issue raised in the report into the Maidenhead IC125 fire in September 1995 was the use of on board communications in the event of an emergency. The Inspecting Officer called for improved access to guard/driver and passenger announcement (PA) systems and added ‘the possible use of pre-recorded or automatic announcements should be considered'.
A moment's thought suggests that a ‘one announcement fits all' pre-recorded PA message is a potential risk to life and limb rather than a safety aid. In a collision, for example, the leading coaches can be a bloody shambles while 100 yards or more away, passengers at the back of the train are just shaken. So how does the guard in the middle of the train, say, know what button to press?
Of course, in lesser incidents, say a slow speed derailment, train failure, or even when controlling overcrowding during service disruption, the PA is an important safety tool.
Recommendation 12 of Professor Uff's report into the Southall accident called for all train-borne safety equipment to be clearly designated as to whether or not it is vital to the continued running of the train.
Railtrack was also required to ensure that Rules and Group Standards applicable to operators, including drivers, were clear and unambiguous. In particular, ‘Railtrack should urgently complete the review of operating Rules to ensure they are workable in the privatised, fragmented industry'.
In fact, Railtrack Safety & Standards Directorate already had a project underway to completely review the Rule Book by the end of 2002. The parallel rolling review of all Railway Group Standards included revising the rules for safety critical on-train equipment by October 2000. This review, was to provide ‘a clear designation as to the importance of particular train-borne safety equipment to the continued running of the train'.
Two more of Uff's recommendations are worth mentioning before this column goes ballistic. No 15: ‘All parties must emphasise the need to comply with the Rule Book and must not condone departures' and 69: ‘All parties in the industry must ensure that paper-based procedures do not become divorced from reality. This should include senior managers maintaining a direct knowledge of the situation in railway workplaces'
Railtrack introduced the new Rule book on 2 December 2000 . Obviously, the over-riding aim was to ensure that, as happened at Southall, trains did not stay in service if the Automatic Warning System failed. Before Southall, remarkably, AWS was a category B item of safety equipment, ranking behind, for example, such Category A equipment as windscreen wipers and horns.
Under the new Rules, if the AWS fails, passenger trains must be terminated at the ‘next suitable station'. And here's the first blood pressure alert: according to Informed Sources S&SD had a hell of a battle with Her Majesty's Building Site Inspectors (aka the Health & Safety Executive) over the qualification ‘suitable'. Such is the level of railway experience and commonsense at Rose Court that stopping at the ‘next station' was considered the safest action.
Just think about it. A northbound evening IC225 is passing Potters Bar at full pelt when the AWS fails. Allowing for braking the next station is Brookmans Park which is sans staff, sans much shelter, sans taxis, sans everything at that time of night, ready to receive 400 passengers. No doubt readers could come up with even more ludicrous scenarios.
But even ‘suitable' gets me worried. Who determines what is suitable? If it is the driver, what training is provided on determining ‘suitability' that will satisfy Sir Sneering Pomposity QC at a possible public inquiry, should the driver make an ‘unsuitable' decision?
For example, supposing the AWS fails as the last all-stations Kings Cross-Welwyn Garden City train leaves Brookmans Park at 00.17 hours. Is the next suitable station Welham Green (a mere halt), Hatfield or slow line at 20mile/hr, say to the terminating station?
Yes, I know what common sense says, but this is the Rulebook which has to be obeyed to the letter it is to be of any use (Uff Recommendation 15).
Think I'm being picky? Look at the box on what the Rule book says about public address systems?
What the rule book saysX.26.1 When entering service A train must not be permitted to enter passenger service if the Public Address system is defective in any vehicle in which passengers will ride.
X.26.2 When in service If the Public Address system becomes defective on a train which is in passenger service, the Driver must:- • report the circumstances to the Signaller at the first convenient opportunity • act in accordance with the instructions given. The Guard (the Driver on a DO train) must, if possible, transfer the passengers to an unaffected vehicle. |
A train can't enter service if the PA is defective in any vehicle open to passengers. That seems unambiguous. It means that in the first four days after the rules came into effect Virgin West Coast cancelled three trains including the last Liverpool-Euston service of the day.
Railtrack's initial reaction to these cancellations was that Virgin was misinterpreting the rules. A cross S&SD source exclaimed ‘I do get irritated when people can't read. The train is allowed to run until the end of the day but it must not go into service without the PA working'.
But that isn't what Rule X.21.1 says. As train drivers' PA scripts at the end of journeys say ‘This train terminates here and comes out of public service'. Logicaly it then re-enters passenger service before the next journey. And Irritated of Euston , whose blushes I am sparing during the season of goodwill, was back shortly after to admit that Railtrack appeared to have ‘shot itself in the foot a little bit'.
According to Informed Sources the wording of Rule X.26 is to be changed. Hurrah for sanity. But it won't be easy, given the fun we had with the definition of Light Maintenance Depot (LMD) in the context of that other threat to sensible operation the Rail Vehicle Accessibility Regulations.
You will recall that those Regulations said that failures of the disability equipment had to be corrected within six days or when the train visited a depot. But some trains are stabled overnight at an LMD which is no more than a fuelling point, a ‘Depot' in name only. And the RVAR meant if a train had come in with defective equipment and stayed overnight at an LMD it could not re-enter service next morning.
So, this column having led the successful fight to get the RVAR changed, Rule X.26.1 takes us back to square one. Once again, passengers face the prospect of standing at the station early in the morning watching the first train of the day they were hoping to catch, leaving empty because the PA isn't working. And if you think that common sense will come to their rescue you haven't been paying attention
But X.26.1 pales into insignificance in the brain-dead stakes compared with X.26.2. Let's play a few scenarios.
When travelling, I have been known to tell Guards or Conductors that the PA in a coach is not working. I won't do it again, I assure you, but if I did, the guard would tell the driver who would report the circumstances to the Signaller at the first convenient opportunity.
First of all, how should drivers interpret ‘convenient' with an eye to a possible Inquiry? Does it mean the next signal post telephone consistent with a normal service brake application? Does it mean use the Cab Secure Radio after you have negotiated a tricky junction containing a multi SPADed signal? A driver's freedom could depend on the interpretation.
Suppose I wait until the end of my journey and trot forward and tell the driver as he waits for the off that the PA isn't working in the third coach of his Driver Only Operated multiple unit. What does he do? How does he check that the PA really isn't working? Does he make an announcement, then go back to the coach and ask if passengers heard the message?
Anyway, having told the signaller, the driver has to act in accordance with his instructions. You can imagine the conversation in the morning peak: ‘I've got a full and standing train at Effingham Junction with a defective PA in one vehicle, what are your instructions?' ‘Dunno mate, what does the Rule book say?'Well the Rule book says that the Guard or the Driver must, if possible, transfer the passengers to an unaffected vehicle.
So, conductor goes into first class vehicle of inter-city type train. ‘Ladies and gentlemen, may I have your attention, the public address has failed in this vehicle. For your health and safety, I must ask you to transfer to another vehicle'. Can you imagine the reaction?
Or try it with a comfortably full, off-peak DMU or EMU. And in either case what if someone says ‘I'll take my chance and stay here thank you'?
And once again we have a qualification that could turn out to be critical in court, putting the onus on the judgement of a junior employee. What on earth does ‘if possible' mean in the context of the rule book? And what happens if the PA has failed totally?
What price ‘All parties must emphasise the need to comply with the Rule Book and must not condone departures' when the Rule book depends on the definition of ‘possibility'? If the train is full and standing, moving passengers is clearly ‘im'-possible but otherwise the guard or driver is required to do something that passengers will regard as risible. The Rule book on which safety depends, becomes an ass.
What's the answer? In an industry hag ridden by safety, fear of litigation and endemic CYA you have to remove generalised qualifications like ‘suitable' and ‘if possible' and codify actions.
In the case of AWS failure a printed list of authorised stations for each route in each cab solves the problem. If the AWS fails you stop at the next station on the list.
As for the PA, well, for a start it is not vital for the safe running of the train, but it is nice to have. Does the Signaller need to know it isn't working? Not really.
Should it fail in one or more vehicles, Control, not a signaller should be notified so that the failure can be rectified at the terminating station. Otherwise the train continues as normal because the risk to life and limb of a non working PA is insignificant.
Railway safety, as with disability provision, is weakened when those framing the rules are unable to think through the real life effects of their good intentions. Engaging brain before any activity is always advisable.