Select Committee on Transport Written Evidence

Supplementary memorandum by Alan Osborne (FOR 124B)


  My apologies for sending this information to you in dribs and drabs but I have thought of a few additional examples relating to the above. I have tried to focus on issues of cost rather than perverse regulatory logic but there are quite a few examples of this also.

  Whilst I was at the HSE I influenced three developing situations relating to possible excessive costs.

  The first related to short platforms. As you will be aware there are quite a few platforms across the country that are now shorter than the trains they serve. HSE had adopted a fairly aggressive policy of compliance on this and required details from the relevant dutyholders of when such platforms would be extended. As I'm sure you will appreciate, new works associated with extending platforms are very expensive and disruptive. I intervened in this situation and changed the policy to the effect that manual (but preferably automatic) Selective Door Opening (SDO) was acceptable in the longer term. Up to this time HSE only considered SDO (either manual or automatic) to be acceptable as a short-term mitigating action with only an extended platform being acceptable in the long-term. This policy was putting Train Operating Companies off from introducing new services because of the probable significant increase in costs—thus making the service economically unviable. So this is an example of what could have been very problematic for the industry but was averted.

  The second related to the introduction of the new Pendolino trains. HSE served an Improvement Notice on Virgin to add sanders (to aid adhesion of train wheels to the rails in adverse weather conditions and leaves on the rails) to the trains at a reasonably late stage of production. The price tag for this was to be over £20 million and possibly a lot more because of contractual issues with the manufacturer. With the braking characteristics and overall design of these new trains the addition of sanders was of questionable benefit. Based on further risk analysis the Improvement Notice was eventually withdrawn.

  The third related to TPWS. The Committee heard evidence from Network Rail about the increase in cost of the TPWS project. HSE directly caused through the Railway Safety Regulations 1999 (and through their further interpretation) the blanket fitment of TPWS to all signals controlling conflicting moves regardless of risk. This resulted in fitment to 40% of signals increasing the cost by some 30%. There was also a refusal by HSE to exempt signals in areas where line speeds were less than 25 mph despite private railways being exempted. TPWS was also mandated at buffer stops and this has caused service difficulties as well as increased costs. I influenced the granting of exemptions to these regulations whilst at HSE to address the blanket fitment issue but significant cost increases were still incurred. There was a mindset within HSE that any cost saved must be ploughed back into additional safety features demonstrating that HSE's motivation is to continue to ratchet up safety standards without a full understanding of risk and when something is safe enough. The HSE Policy and Operations divide was at its worst on TPWS. A further example can be seen with level crossings. Automatic level crossings are more expensive in the UK than anywhere else in the world (examples costing over £1 million). A "one size fits all" approach drives up cost as often simpler, cheaper solutions can achieve most of the safety benefit.

  A number of these issues relate to out of date Railway Safety Principles and Guidance documents issued by the HSE and are not a reflection on the HMRI staff involved in these examples. When the Director General informed me that the revision to these documents had been put on hold (essentially because of HSE cost problems) this was of great concern given the potential for out of date (and not risk assessed) standards to add to cost.

  Indeed a new and specific example has emerged in the last month relating to these documents. A new single platform station has been built at Newcraighall in Scotland but the gradient at the station is now apparently under scrutiny by HSE. It apparently does not meet the gradient limit required by Railway Safety Principles and Guidance for new build stations (many stations across the UK do not meet this limit but they have "grandfather rights"). When all the other technological advancements are factored in, such as the layout of the track, modern braking systems etc, the risk of a runaway train is very small. I do not know the full circumstances of this as it has emerged after my time but it is an interesting case.

  It is very important these HSE documents are revised using risk-based thinking. This is the kind of attention to detail work that is important to rail safety and yet it has a low priority with the HSE framework.

  I trust this additional information is useful.

Alan Osborne

14 January 2004

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