Peer review: Ian Prosser
Director of Railway Safety, ORR
Chris gives a clear view of how the standards regime for the main line railway fits together. To a lay observer it might seem quite complex, with its various layers, but in many ways it reflects the complex world within which the main line railway in this country now operates - ranging from the influence of Europe through to the need for multiple companies to co-operate safely and efficiently to maintain system safety. European interest is focused on opening markets, improving efficiency, and harmonising safety across the sector through standardisation.
I recently heard from some quarters that standards are leading to a gold-plated railway and causing enhancement costs to rise unnecessarily. But when I look at our railway system, as I often do through cab rides and by visiting project and maintenance teams across the network, I see little evidence of what I would call gold-plating - much of our infrastructure still dates from its Victorian origins and comprises very basic component materials!
It is often the need to move to a common standard European gauge to enable interoperability that could drive costs, although this only becomes a factor at major renewal when associated costs can be minimised. More recently, there has been a welcome move to modernise standards to optimise the ‘whole-life’ infrastructure costs - unlike occasions in the past, when things were built to a minimum initial capital cost without consideration of whole-life safety, maintenance, renewal and decommissioning costs. An example is the installation of new electrification equipment that can be maintained both efficiently and in a legally compliant and safe way.
However, I believe further improvements can always be made, and I praise the work Network Rail is doing to simplify and improve its company standards through what it is calling its Business Critical Rules Programme. This will lead not only to improved efficiency, but also improved safety, particularly as it helps to ensure a clearer line of sight between the risk posed and the risk controls codified by standards.
Another myth that exists is that present standards leave little scope for applying competent engineering judgement, or do not take into account different usages of the infrastructure. This is far from the case. For example, track is categorised on the basis of its service capacity usage, and so the commensurate maintenance and inspection regimes used reflect this categorisation.
On innovation, it is interesting to reflect back on the McNulty study, which showed that the industry was perceived as having gone backwards since privatisation. I believe that “standards” do not hold back innovation - they set a reliable and efficient baseline for achieving basic legal compliance, best practice and providing scope for innovation through a positive focus on outcomes and not outputs.
From my own experience in the industry in the past 15 years, I think it has more to do with weaknesses in risk management culture. The industry, with the support of the RSSB and the Regulator, is taking bolder steps to address this via increased DfT funding and the collaboration now being facilitated by RSSB and led by the Technical Strategy Leadership Group. A number of innovative projects are up and running which I am sure are going to drive both the industry’s safety and efficiency.