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Cost benefit analysis has no place in safety decisions - that's the new orthodoxy according to Uff and Cullen
What depressed me most about the joint inquiry into train protection systems by Professor John Uff QC FREng and the Rt Hon Lord Cullen PC, was the subordination of rational thought to political correctness.
Both men came with reputations for intellectual rigour and independence. I had hoped that they would take a dispassionate look at train protection and railway safety and come forward with a rational long term policy. Instead we have an emotion driven report responding to individual tragedies .
What on earth do we make of this passage, for example?
The costs of the safety measures currently under consideration will be met substantially from the public purse. The issue of priorities between one form of safety expenditure and another remains and is considered below in the context of cost benefit analysis. It needs to be emphasised however, that public subsidy substantially distorts the attitudes of operators, including Railtrack to the fitment of safety systems. The costs and benefits to them are quite different to the costs and benefits to the public at large. The interests of the public are represented most closely by HMRI and the Regulatory bodies and, in this joint inquiry, by the Passenger's Group
Now there is no way that the Passengers Group, which represents the bereaved and injured of the southall and Ladbroke Grove, represents the interests of the public. As I have remarked before, when writing about the Value per Prevented Fatality, at the back of my mind there is always the knowledge that this analysis of the cold numbers may be read by someone for whom no price would be too high to bring back a dead loved one.
True, the Passengers Group represents people who have suffered grievously. But the Group's concern is train protection and there are people have suffered equally from other preventable accidents due to other causes.
Uff and Cullen indeed say that the cold numbers are all about prioritising safety expenditure, where the money should go and where it saves the most lives. But, presumably because they were tasked with train protection, the possibility that other safety initiatives might save more lives is not on the agenda.
At the heart of the report is the fact that these razor sharp minds cannot live with the concept of cost benefit analysis in the form of Value per Prevented Fatality (VPF). They go out of their way to explain that this is not the same as putting a value on a life of an individual.
Their distaste is palpable, and, given their extensive exposure to the victims and bereaved of two rail accidents, understandable. But when you are laying down long term policy and recommending safety expenditure of billions you have to harden your heart, look beyond individual grief and take a magisterial over view. VPF is the best tool we have, or rather, had, for such evaluation.
As the Daily Telegraph bravely pointed out in a leader after Ladbroke Grove, national policy cannot be based on public outrage. And at the Joint Inquiry the national public interest was ably represented by the estimable John Cartledge for the then Rail Users Consultative Committee.
Readers may be shocked by my adherence to the cold numbers in the face of catastrophic accidents, but we should not confuse media-led outrage with the public mood. Ironically, Uff and Cullen make this very point with a reference in their Report to a research project set up to see whether the differential the Government has applied to road and rail VPFs over the years was justified.
Currently, the VPF used by the Department of the Environment, Transport and the Regions for evaluating the safety benefit of road schemes is £1.15million. Railtrack's railway safety case mandates the same VPF as road, but there is a multiplier of 2.8 for rail expenditure that would reduce the risk of multiple fatalities.
As the Report puts it, the multiplier is considered to reflect extreme public reaction to accidents involving multiple fatalities including the fact that the victims have no control over events. Really?
Take the case of the six people killed on 12 November last year when a Sainsbury's lorry ploughed into a group of vehicles on the hard shoulder of the A1(M) in Yorkshire . Were there multiple fatalities? Yes. Did the victims have control over events? No. Was there an extreme public reaction? Of course not.
In 1995, to their credit, the HSE, the then Department of Transport, the Home Office and the Treasury commissioned research to examine whether this differential applied to road and rail safety was supported by public opinion. Exposing its preconceptions, the Uff/Cullen report says ‘surprisingly' the survey afforded little or no public support for the differential. The surveys, which included reference to fire risk, were repeated after the Ladbroke Grove crash and substantially confirmed the original opinion.
Given that 10 people a day die on the roads and the real life maximum VPF for road safety schemes is £100,000, is it really ‘surprising' that the public – as opposed to the media – don't see why you should spend more to save a life on rail than on road?
Shortly after Hatfield, I was in a Great Western IC 125. As it accelerated out of Paddington, in the interest of research, I asked nine passengers – all strangers – the same question: ‘are you afraid that this train might crash and you might die'?
All nine were puzzled that I should ask. All said ‘no'. One added ‘Never give it a thought'. But two were seriously concerned that because of the current rail disruption their partners were having to put in long mileages on the M4, which they perceived as really dangerous.
In the end, though, the report ducks the issue of affordability and value for money totally. Both the Train Protection & Warning System and the European Train Control System (ETCS), the subjects of the report, are or will be, mandated by law. Uff and Cullen say that this legal requirement means that they were not ‘called on to come to any judgement on whether these systems satisfy a cost benefit analysis'.
Given that this column has been wittering on for a fair while now that the signal engineers have left the driver unprotected, why am I complaining about mandatory installation of ETCS since the Report says that the Treasury will cough up?
Well, apart from the practical issues covered below, it all comes down to the reason for VPF – prioritisation. Statistically, adding ETCS on top of TPWS will save one life a year. Of course, it might save 100 lives in one accident or it might save none, we don't know.
What we do know is that people die on the railway from various causes each year, level crossings for example. And we can calculate what it would cost to prevent or reduce these fatalities, for example replacing foot crossings with footbridges. And work out the VPF. And it might be that some of the money saved by phasing ETCS with signal replacement over a longer period, could be better spent.
Back in 1994, British Rail took 250 safety initiatives and ranked them in terms of VPF. Drawn as a graph the figures gave a flattened horizontal ‘S'.
At the left hand axis the graph climbed steeply from zero, representing the small number of schemes costing next to nothing. At the right hand axis the graph soared asymptotically with a few schemes having VPFs in billions.
And in the centre was a broad plateau of projects with VPFs (in 1994 money) of £1-2million. And that is why the cold numbers count. Because they help managers save the most lives for the finite resources available.
Surprisingly, I found no reference to the Railway Group Safety Plan in the Joint Inquiry report. This commits the industry to halving the risk of passenger fatality by 2009 and covers a range of initiatives. But, it now dawns on me, activities are not prioritised or subject to CBA.
So, with the Joint Inquiry focused on stopping SPADs at any price, but with three years allowed for consultation and trials leading up to the new regulations mandating the European Train Control System, it looks as though it is up to Railway Safety Ltd, to spearhead a rational, holistic approach to prioritising safety expenditure, with the overall aim of maximising the benefit.
If the new orthodoxy is that Safety Regulation means that the taxpayer foots the bill, an astute industry would be seeking Government support for its own safety agenda. Whether a fragmented railway in near permanent crisis can handle this task is another question. But if anyone can take a lead, it has to be RSL Chief Executive Rod Muttram. In rugby they call that a hospital pass.
We saw it coming
‘Had Morpeth 3 left 20 dead in a mass of highly telegenic wreckage can you imagine the Public Transport Minister explaining that while ATP would have prevented this tragedy, cost benefit analysis showed that such safety investment was not cost effective'
Informed Sources September 1994 |