Supplementary response by Rail Freight
Group (TS 45)
INTRODUCTION
1. The House of Commons Transport Committee
has requested further evidence from the Rail Freight Group in
respect of rail freight and transport security. This paper comprises
RFG's response.
2. The issues of transport security in respect
of freight has become a much higher profile issues in the last
five years. Freight is different from passenger security in several
ways which reflect the global freight market and the types of
risks encountered.
3. As a starting point, we refer the committee
to the Opinion of the European Energy and Transport Forum "European
Policy on security in energy and transport, including Financing",
published on 10 November 2005. A copy is attached for ease of
reference.
4. The freight sector may be affected in
two main ways, either as the cause of incidents or as a result
of disruption to critical supply chains which may affect the economy
of the country or region. It may also be affected as a consequence
of action taken in respect of other modes such as passenger transport.
5. The paper considers briefly the above
issues, including the risks and possible mitigating actions, and
then draws conclusions.
RAIL FREIGHT
AS THE
CAUSE OF
INCIDENTS
6. Firstly, it is worth pointing out that
all transport of goods involves risk; the amount of risk depends
on the cargo, the type of transport and of course the security
procedures in place along the supply chain. The extent of such
procedures will depend on the actual cargo and the transport chosen.
7. Rail freight is generally more secure
than road freight since the loading, transporting and unloading
is much more tightly controlled at depots and there is little
if any ability for cargo that is part of a freight train to "disappear"
or be diverted en-route. It is also not easy for other parties
to determine the content of a train or its exact timetable; sometimes
its route also changes due to engineering works or for other reasons.
8. We would therefore argue that, in comparison
with road and possibly sea transport, rail freight generally has
significant security benefits. If Government believes that tighter
security measures in the freight sector are justified, then it
should ensure that they are proportionate to the threat and risks
incurred by each mode. They must resist the temptation to impose
stricter controls on rail freight because they can more easily
do so than on road freight. This will inevitably make rail freight
less competitive and as a consequence cause the transfer of such
freight to a mode which has a higher risk.
9. There have been a number of issues raised
about the ability of rail freight to be the cause of incidents.
These include the proposal at the time of the Olympic bid for
the 2012 Games to prohibit all rail freight through Stratford
because it might be full of explosives. The inference in this
and other cases is that the risk of a train not only containing
"dangerous" cargo but also the ability of such a cargo
to be detonated at a particular point or time makes the risk of
transport by rail unacceptably high and that, as a consequence,
this should be regulated or prohibited, or the cargo sent by other
means.
10. This assumes not only that the security
at the point of loading is poor, but that the timing of the train
along its journey is such that it could forecast with a high degree
of accuracy. Both these assumptions are false. The loading of
rail freight into wagons or containers is tightly controlled,
the location of particular wagons in trains is generally uncertain,
as is the timings and routes of trains. Freight trains do not
sit for long periods in predetermined unprotected sidings or loops,
so the threat of tamper of a train on its journey is considerably
less than that of a truck parked whilst the driver has a break
or meal.
11. The above example came from the Olympic
Bid team without, as we found out afterwards, their even consulting
with or being aware of the existence of TRANSEC. When informed
of this, TRANSEC could not have been more helpful, and in the
end the threat of banning freight was withdrawn.
12. We therefore believe that there is no
argument for imposing additional security conditions on rail freight
that are any more severe than on road freight. Because the number
of rail freight terminals is much smaller than the number of road
freight terminals it will tend to be easier to increase security
and "make rail freight more secure" when, as stated
above, it is already generally more secure than road. This must
be resisted since rail freight needs fair and even handed competition
with road.
TRANSPORT OF
NUCLEAR PRODUCTS
13. Concern continues to be expressed about
the transport of nuclear products by rail. Such movements are
necessary if nuclear power stations are to continue to operate
and, when the time comes for decommissioning, to remove dangerous
items for disposal or secure storage elsewhere. We cannot here
get into the debate about whether or not the UK should have nuclear
power stations or not but, assuming that these materials have
to be transported anyway, the question becomes—how should
this be achieved?
14. For many years, rail has been used for
such transport. There are extensive security regulations and controls
governing such movements and the trial collision between a freight
locomotive and a nuclear flask demonstrated the robustness of
the flask in a situation involving a rail accident. Beyond this,
the risk of a rail accidents has reduced significantly over the
years, caused in part by the successful introduction of TPWS.
The operators of these trains, Direct Rail Services, who are themselves
owned by the Nuclear Decommissioning Authority (NDA) have long
experience in operating such traffic and always use two locomotives
for added reliability.
15. Options for such movements include road,
sea, rail and air. Since most nuclear installations are located
near or on the coasts, it could be argued that maritime transport
is a better option. However the problem remains that many installations
have no local means of loading onto ships, so transport by road
or rail to a suitable port would be necessary. We question whether
this is any safer than moving it all the way by rail.
16. We conclude therefore believe that the
risk of a serious incident involving nuclear traffic on the rail
network are extremely low, and lower than if other modes were
used.
THE EFFECT
OF A
SECURITY INCIDENT
ON OUR
ECONOMY
17. The other main concern about security
of the transport chain is the effect of an incident on the UK,
European or global economy. An example might include the closure
of the Channel Tunnel, which we address separately below, but
also of a major port or airport which might affect established
trade patterns, lead to shortages, higher prices etc. This can
apply equally to general commodities which move around in single
wagons or containers, as to bulk materials such as oil, gas or
building materials.
18. Examples of such include the recent
fire at the fuel storage facility near Hemel Hempstead and, some
time ago, the fire which closed the Channel Tunnel for a number
or months. Clearly such incidents can cause major disruption to
people, their lives, their journeys and their ability to do their
jobs effectively. We do not cover these aspects here, since they
are different from freight issues. Business has every incentive
to find alternative means of keeping going, whilst at some stage
seeking compensation, if that is appropriate, from those responsible
for the damage. These are all serious, if generally local or regional,
issues but are not national ones.
19. Of generally greater concern, and one
brought out in the EETF Opinion referred to above, are fears that
a major transport link could be disrupted and out of use for an
extended period. For example, what would happen if, a major port
such as Dover or Felixstowe ceased to be able to operate for several
years? How would this affect freight and would this adversely
affect our UK or European economy and, if so, what can be done
about it?
20. We believe that, whereas 10 or 20 years
ago, there could have been serious consequences, the international
and domestic logistics business is now so efficient and global
that it will be able to respond quickly and effectively to any
such incident by diverting to other routes or modes.
21. For example, if a major rail-connected
port had to be closed, then traffic would switch to alternative
ports. It is then likely that, as the other major ports reached
saturation, there would be more feeder traffic to our smaller
ports, some of it transferring from continental ports such as
Antwerp and Rotterdam. If the West or East Coast Main Lines were
severed, there would again be disruption, but the railways have
demonstrated over the years that they are good at finding alternative
routes.
22. The rail freight industry has the flexibility
to accommodate such changes and would be at the forefront of seeking
solutions to and from other ports that might be able to accommodate
the traffic. The rail freight community is particularly good at
this, since every day it has to create and manage over 1,000 train
journeys, often very different on various days of the week.
23. Of course, any such incident would have
short term consequences whilst the new supply chains were set
up or expanded, and there might well be short term delays, shortages
and cost increases which would have to be passed on to customers.
Nonetheless the freight would continue to reach market.
CHANNEL TUNNEL
24. The Channel Tunnel has its own bi-national
safety and security structure codified in the Channel Tunnel (Security)
Order 1994. At the time when these regulations were being discussed,
the Channel Tunnel was thought by many to be the key to the UK's
economic success, taking perhaps 50%+ of our trade and continental
passenger travel needs, and would lead to the decimation of the
ferries and of the short haul air services. Clearly in these circumstances,
the highest possible security was thought to be necessary. Such
work of course had to be done with the French authorities who
had very different, but we would suggest no less adequate, security
policies.
25. The result is a highly bureaucratic
and expensive structure. For example, is it really necessary to
have all rail freight terminals in the UK subject to special requirements,
procedures etc including fences buried in concrete underground
(to avoid people trying to tunnel in) when road freight can cross
the Channel at will by ferry? Such measures reduce the choice
of inland terminal and may in turn disincentivise use of the Channel
Tunnel rail services.
26. We believe that these regulations and
procedures are now out of date because, contrary to thinking twenty
years ago, there is wide range of means of getting rail freight
between the UK and the close continent. As set out above, in the
event of an incident, alternative supply routes would be quickly
established to compensate.
DEALING WITH
THE SECURITY
AND POLICE
AUTHORITIES
27. We have no further comments on these
issues beyond what we have said in our original evidence.
CONCLUSION
28. From these arguments, we believe any
review or proposed changes to the level of security of all the
major transport links or nodes must ensure that:
— the protection proposed is proportionate
to the threat and risk;
— that freight businesses are not made
to suffer because of protection proposed for passengers which
is not required for freight;
— that all freight modes are treated
equally in respect of security considerations—particularly
not penalising rail freight because this is more easily achievable
than with road freight; and
— the cost of enhanced security measures
is not expected to be borne by the rail freight sector—this
will be likely to force traffic onto road where, arguably security
is more difficult to ensure.
29. This would possibly involve reducing
some security whilst increasing others; for example on Channel
Tunnel security.
May 2006
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