Understanding the need for common safety methodology and its practical application on risk evaluation and assessment

Executive-level safety expert Andrew Petrie of Network Rail Consulting was among the speakers at the Rail Safety 2015 Conference at the Langham Hotel, Melbourne. Together with his colleague Kevin Thompson, they gave an extensive discussion on safety risk management from an international perspective.

Network Rail and Network Rail Consulting

Network Rail operates, maintains and develops UK railways, infrastructure tracks, signalling, tunnels, bridges and level crossings.  They do not operate or offer passenger and freight services , Network Rail undertakes their maintenance and other related activities.

With these primary responsibilities, Network Rail is tasked to oversee the operation of 20,000 kilometres of track, 29,000 bridges, 48,000 signals, and 700 tunnels; carrying 20,000 train movements daily; and the operation and maintenance of UK’s high-speed rail infrastructure.

Owning 2,500 stations and operating 17 major stations, the second-busiest railway network in Europe and the fifth-busiest in the world, Network Rail employs around 35,000 people across all rail-related disciplines. Over the last decade of their operation, Network Rail has considerably enhanced the railway infrastructures and substantially improved their services.

Formed in 2012, Network Rail Consulting forms the international consultancy board of Network Rail. In its aim to deliver quality and value, it has since been operating under the mandates of using and sharing Network Rail expertise and knowledge with the rest of the world, building partnerships with other railway organisations internationally, providing opportunities for employees to work and gain experience abroad to encourage retention of key staff in the organisation, and applying lessons learned overseas to improve local operations.

The European Union

Andrew Petrie explained the significance of getting an extensive knowledge on the European Union to understand the European railway network and its common safe methodology.

As the name suggests, the politico-economic congregation more popularly known as the European Union is the union of 28 member states that are primarily located in Europe. The EU operates through a supranational institutional system largely dependent on decisions from across various governments of the member states.

Of the 28 member states, 26 have railways and railway networks. With 24 official languages spoken in the EU, implementation of the legislation is even made more difficult. The European Railway Agency however is not bound to serve the members of the European Union alone nor the states and countries within the state borders. It was created to be of service beyond the immediate borders of where they actually are.

The European Railway Agency

The construction of a safe and revolutionary railway network is one of the primary objectives of the European Union. Under this objective is the aim to have high-quality railways that are more competitive in terms of providing end-to-end services that are not bound by any national border.

The European Railway Agency was founded in 2004, and it took a few years before it went fully operational in 2006. Established to create an integrated railway system for the region and as the system authority for the European Rail Traffic Management System, the agency carries out projects and programs that are geared towards achieving the following goals:

• Support for Cross-Border Interoperability. The European Railway Agency was built with the primary purpose of helping the establishment of an integrated railway with the fundamental focus on safety and interoperability. This technical interoperability enables the seamless operation of trains between countries and across member states. To illustrate, a signalling system used in Spain can also be used in Italy and Germany for example.
• Integration of Common Approach to Safety.  The agency pursues to cultivate safety regulations, accident investigations and a common approach to safety with the integration of safety certification conditions, targets and assessment methods for the system.
• Reduction of International Barriers. The European Railway Agency promotes the reduction of international barriers to encourage free and uninterrupted railway operations across state borders.
• Facilitation of International Competitiveness. The agency promotes continuous technical and operational advancement of the European rail system to facilitate its participation in the international arena. These advancements are aimed at spreading that margin wider for the UK railway system to remain competitive.

Three national bodies oversee rail operations in the UK. They are the Department of Transport, the government body responsible for railways; the Office of the Rail Regulator, an independent statutory body that regulates the rail industry’s health and safety performance; and the Rail Safety and Standards Board.

The Rail Safety and Standards Board

After the privatisation process in the late 1990s, the railway network was split into many different organisations – infrastructure, train-operating companies for passenger operations, freight-operating companies for freight operations, to name a few. Eventually safety was set aside and taken for granted.

It was in April 2003 when the Rail Safety and Standards Board was established as part of the recommendations in the report submitted along with the investigation of the Ladbroke Grove accident.

The RSSB brings together train operators, infrastructure managers, rolling suppliers and leasers, and its members from across the mainline railway network to come up with one common decision for the entire organisation. The RSSB aims to eliminate unnecessary costs, design longstanding strategies, and enhance safety and business performance.

The European Union railway safety legislation

The Railway Safety Directive
As amended, the Railway Safety Directive 2004/49/EC aspires to put in place a common European regulatory framework for the maintenance of safety management systems (SMS). This is in line with the objective to have a unified approach that will eliminate barriers to the creation of international transport operations and propose a single market for all European rail transport services.

The Railway Safety Directive was implemented in the United Kingdom by the following entities:

• Railways and Other Guided Transport Systems (Safety) Regulations 2006 (ROGS)
• Railways (Safety Management) Regulations (Northern Ireland) 2006; and the Railways (Accident Investigation and Reporting) Regulations 2005
• Railways (Access to Training Services) Regulations 2006

Common Safety Methods
The European Railway Agency developed common safety methods (CSMs) to promote the creation of a single market that will solely cater to rail transport services and guarantee that safety is constantly upheld at the highest level and improved when and where reasonably practicable and necessary. These targets and methods provide a common procedure on safety level evaluation and assessment of operator performance at the EU as well as in the member states.

Under ROGS, all infrastructure managers and transport activities must conform to these common safety methods below as part of their safety management systems. The European Commission adopts the CSMs and have these published as regulations that every member state should comply with.

• Common Safety Method for risk evaluation and assessment (CSM REA)
• Common Safety Method for assessment of achievement of safety targets
• Common Safety Method for assessing conformity to obtain railway safety certificates
• Common Safety Method for assessing conformity to obtain railway safety authorisation
• Common Safety Method for monitoring to be applied by railway undertakings, infrastructure managers, and authorities in charge of maintenance
• Common Safety Method for supervision by national safety bodies

The need for CSM REA

In Europe, there are three main methods of managing and demonstrating safety, and these acronyms summarise these methods:

• France: GAMAB, which stands for Globalument Au Moins Aussi Bon or “Overall at least as good”; used to compare overall risk with a reference system
• Germany: MEM, which stands for Minimum Endogenus Mortality; also a way of comparing risk to a reference point.
• United Kingdom: SFAIRP, which stands for So Far As Is Reasonably Practical

These methods pose some problems however because protection is a big issue in Europe. If Spain is building a new railway system, they will obviously want trains to be built in Spain so money eventually goes back to their local economy. Apparently, they would want to put barriers up for trains coming from Italy.

And as such, the safety argument can now be used as an excuse to this, and they can say that all trains have been approved in France but is not SFAIRP. Hence, the rolling stock provider will now go to the extent of doing a whole series of safety case in the UK legislation and maybe another safety case in Germany if they want rolling stock to be approved there as well—and that’s just one reason why CSM is needed.

Risk management process: A detailed look into the different stages

The Common Safety Method for Risk Evaluation and Assessment (CSM-REA) is applied when any operational, technical, or organisational change is being proposed for implementation on the railway system.  Using the following criteria, the proposer (the person trying to make the change) must determine whether the change is significant enough or has a considerable impact on safety to be implemented:

• Additionality: evaluation of the significant taking into consideration all safety-related changes recently implemented into the system under assessment that were not considered significant
• Complexity of the Change
• Failure Consequence: taking into consideration safety barriers outside of the system, what is the most credible worst-case scenario in the event that the system under assessment fails
• Monitoring: the ability/inability to monitor the change throughout the process of implementation and the capacity to make the necessary interventions
• Novelty: what is new in the railway sector or innovative for the organisation attempting to implement the change
• Reversibility: the ability/inability to revert to the original system

If no impact on safety is likely to be seen with the change, there is no need for the risk process in the CSM REA to be applied and the proposer should make the proper documentation on the decision was achieved.

Step 1. System Definition
The risk management process starts with system definition, which enumerates the critical parts of the system that is being changed that may include the proposed system’s purpose, interfaces, functions, and any existing safety measures that may have any influence on it.

Other than those defined under the safety requirements, the system definition may change due to changes in scope, changes in the client’s initial requirements, changes in design definition, and implementation of proposed changes by suppliers and contractors.

The system definition should be able to properly address the following issues as part of the risk management process:

• system objective
• relevant system functions and elements
• system boundary including other interacting systems
• physical and functional interfaces
• system environment
• existing safety measures
• assumptions that will determine the limits for the risk assessment

Step 2. Hazard Identification and Classification
The hazard identification and classification process, which should be carried out in a systematic and structured manner, aims to identify all potential hazards that are eventually evaluated further in the next steps.

There are several popular techniques used for the process, but it is important to note that whichever technique is used, it is critical to have the right balance of competence and experience to ensure objectivity and impartiality (Risk Ranking).

Hazards that are “broadly acceptable” are added to the Hazard Record and need not be assessed further, while those hazards that are not broadly acceptable will be assessed and included in the next steps.

Step 3. Risk Evaluation and Risk Acceptance
Risks or hazards can be evaluated and analysed with the use of the acceptance criteria, which include the application of codes of practice (does it meet standards?), comparison with reference systems or outside resources, and an explicit risk evaluation (qualitative or quantitative estimation).

Step 4. Safety Requirements and Hazard Management
One of the six guidelines that the Rail Safety and Standards Board created on how the CSM REA should be applied in the UK in Safety Requirements and Hazard Management (GE/GN8644). The guideline aims to provide practitioner level management on the application of the risk management process set out in the CSM REA.

The guidelines are intended to help railway undertakings and infrastructure managers in the implementation of CSM RA to formulate safety requirements, comply with them, demonstrate the compliance, and manage all hazards. The steps are enumerated as follow:

• Introduction to safety measures and safety requirements
• Introduction to hazard management
• Documentation of safety requirements
• Demonstration of compliance with requirements
• Management of safety requirements
• Compilation of the hazard record
• Management of hazards
• Involving others

Step 5. Independent Assessment
As per the requirements of the CSM RA, an independent assessment must be carried out by an independent assessment body to review how the risk management process is applied and all the results from the risk management process. The appointed assessment body be able to undertake the following:

• Have a full understanding of the change and the processes.
• Design and undertake an assessment programme
• Deliver an assessment report
• Review the processes that were used

The assessment body’s role in overseeing the above functions does not discard the proposer’s responsibility for overall safety. In all cases, the proposer remains solely responsible for safety and for taking the decision to implement the change proposed.

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On adopting the CSM REA

The adoption of CSM REA is definitely a good process that can be intelligently used for all changes. Below are some important points to keep in mind with the process:

• For those organisations following Engineering Safety Management principles then, any changes will be minor.
• Network Rail has just recently updated the Hazard Record or the Log process to record and document the risk evaluation and acceptance criteria.
• The EN50126 suite of standards are currently being updated to incorporate CSM REA.

One of the key things that has to be kept in mind with this approach is not to lose focus on the system level by simply breaking down into low-level hazards.

CSM REA and the UK Law

UK legislations such as the Management of Health and Safety at Work Regulations 1999 require the undertaking of a “suitable and sufficient risk assessment.” The UK Office of the Rail Regulator (ORR) believes that there exists no conflict between local requirements for a risk assessment to be suitable and sufficient with the level of risk requirement as required by the risk management process under the CSM REA. They have assumed that compliance with the CSM REA establishes a suitable and sufficient risk assessment.

The same is true with the Health and Safety at Work Act (1974) that emphasises on everyone’s “duty to reduce risks so far as is reasonably practicable,” where compliance with standards or existing reference systems has always been as a way to demonstrate SFAIRP. It however still leaves the question: Is there anything more that could have been reasonably done?

Andrew Petrie believes this will remain the case with the CSM REA and may only be tested in court.

As an industry expert on rail safety and safety risk management, Andrew Petrie has worked on a large variety of world-class, multibillion-dollar railway and network projects including the Tube Lines (London Underground), the East London Line (ELL) Project, the North West Rail Link, among others.

Network Rail Consulting comprises the international consultancy board of Network Rail. Know more about the organisation’s team and expertise in the rail industry on their website.

The RISSB Rail Safety 2015 Conference, which was themed “Rail safety is everyone’s responsibility,” aimed to bring together key personalities to share their knowledge, expertise, and opinions and enable smooth collaboration for the advancement of safety on the railways.