"Railway Engineers Forum"
Briefing Note Ensuring that the Railway employs competent people is a challenge and there are a range of approaches in use for the different disciplines, both engineering and non-engineering. Some convergence on competence ‘rules’ may be required by European legislation. The Engineering Institutions, as represented by the Railway Engineers Forum, are well placed to independently review the current situation and are willing to take a role in designing suitable competence regimes, and in the setting of professional standards for railway engineers. The Institutions have valuable experience of other industries where safety is paramount, and where the lessons may be transferable. Railway Engineers Forum Engineering Competence in the UK Rail Industry Introduction The Railway Engineers Forum (REF) has carried out an analysis into the means currently used to achieve competence in the engineering disciplines of the railway. The result shows considerable diversity of approach and this study concludes that the industry should work towards the adoption of a common standard for assuring the competence of staff. The REF is a cross institution liaison group acting to promote railway engineering matters and to provide a common voice on behalf of the Institutions. The constituent members are the Institution of Civil Engineers, the Institution of Engineering &Technology (formerly the Institution of Electrical Engineers), the Institution of Mechanical Engineers (Railway Division), the Institution of Railway Signal Engineers, the Permanent Way Institution and the Railway Civil Engineers Association (ICE, IET, IMechE, IRSE, PWI, RCEA). The objective is to promote cross institutional interest in railway engineering matters and concerns of the day. The Need for Competence? Competence has become an important word in the engineering and operational dictionary of the Rail Industry. The requirement is simple enough: to be able to ensure that only competent people are allowed to work on or operate the complex systems in both infrastructure and rolling stock. In the past when a single state controlled railway existed, competence was managed by the hierarchical command and control structure. Staff tended to work in the industry for their entire career, building up competence as skills were learned from more senior work colleagues within the group. People worked in regular teams dedicated to specific task areas, which changed only slowly over time. Tasks were allocated down the chain in line with the perceived ability of subordinate staff. Critical work such as fault finding was kept away from those with lesser competence until it was proven that they had the right knowledge and experience. The system was not foolproof and instances of incompetent work REF Competency Stmt v11 16-11-06 1 occurred where the task would not be done satisfactorily and would have to be done again. Such instances were managed out locally. So what has changed; why is it now necessary to formally require competence of individuals to be measured and recorded? Five prime reasons emerge: 1. The rail system is no longer managed by a single legal entity of national government. It is a shared system managed by a multitude of autonomous private organisations each playing its own part according to legislation and contracts. A structure is required so that the public, government and the other industry parties who depend upon the safety integrity of any organisation‟s activities may be assured that they are being performed competently. 2. Because most industry relationships involve some form of performance measurement, which may include an incentive regime, expected performance is defined and measured across the contractual boundaries. Output standards are higher and shortcomings are much more visible with potential expensive consequences. 3. The extensive use of contractors makes it impossible for managers within Infrastructure Management or Train Operations who are ultimately responsible for the safety of the operation, to know and control which individual members of staff will be assigned to any given task. Instead, safety is assured by a comprehensive and regular audit of the suppliers‟ management systems. 4. Recent accidents have demonstrated the increased tendency to seek out „someone to blame‟ and to pursue criminal charges through a court of law. To have employed someone later discovered to be incompetent can have damaging results both for the individual and the employing organisation. Organisations must be able to demonstrate that they have mechanisms for the pro-active control of competence. 5. The increased focus on safety at all levels means that competence must be assured if safety is not to be compromised. What is Competence? So what is competence? It is often confused with knowledge and whilst there are overlaps between the two, they are essentially different. Knowledge will test the theoretical and academic expertise of an individual; it will prove that he/she on a particular day has amassed enough facts and data to be able to pass a (normally) written based examination, which will often stand good for life. There are people who have such knowledge based qualifications who would be very ill suited to venture out to the ground level and implement their knowledge in a practical way. Competence is all about being equipped with the right level of skill, training and equipment to be able to do a particular job successfully and reliably day after day, to the required level of quality and safety. The competent person may not need to know exactly the in depth design details of a piece of equipment, but should know how it fits in to the overall operation of the system. Specific expertise is required to enable the equipment to be installed, tested or maintained in the context of system operation. Since engineers will never work on the same types of REF Competency Stmt v11 16-11-06 2 equipment for an entire career, a competence qualification will not be for life, and competence will need to be periodically reviewed to ensure that engineers and technicians remain able to demonstrate their ability to do the duties required of them. Reference should be made to the Safety Critical Work and Railway Safety Case Regulations, both now replaced by the ROGTS, Railway and Other Guided Transport Systems Safety Regulations. These require that formal competence methods are in place for staff when undertaking work where public and system safety is of the highest importance. Methods of Assuring Competence Depending upon the level of risk of the activity there are three levels of rigour that may apply to general competence management. 1. Normal day to day competence is ensured through the “duty of care” to employees and the public that is enshrined in general health and safety legislation. Competence is also specified in the formal quality standards (e.g. ISO 9000) for products and services. 2. Where a task has safety implications such as road vehicle driving or flying an aeroplane, then government may impose an obligation upon the individuals wishing to carry out an activity to be subject to an initial formal assessment of their competence by accredited assessors to laid down standards. – The individual must obtain a “licence”, which will be subject to regular review and renewal procedures to comply with the ISO17024 standard. 3. The most rigorous competence control used only for industries deemed “high hazard” (such as nuclear, chemical and rail) is to impose an obligation upon companies within the industry to have a documented and approved Safety Management System or “Safety Case”. Under this regime all aspects of an organisation‟s competence management (training, assessment, ongoing assurance of competence) must be documented and approved by a government regulator. Compared to a licensing system (which itself may well be part of a Safety Management System) this approach has the benefit of providing continuous (as opposed to snapshot) control of competence with the responsibility focussed upon a single entity, the employer. It has one downside in that the personal competence certification is specific to an employer and is therefore not readily transferable between, or recognised by, all employers unless a common licensing system is integrated into it. In today‟s railway, these three elements of competence are part and parcel of the Safety Management System required by the regulatory authorities for Infrastructure and Train Operating companies alike. To assure competence, four principal activities have to be fulfilled: Training Assessment of Competence REF Competency Stmt v11 16-11-06 3 Accreditation of Competence Assessment Ongoing Verification of Continuing Competence The organisation obtaining and maintaining measured competence for its staff may choose how to undertake these four activities. By the organisation itself By an independent third party By a government accredited third party e.g. a Notified Body By a government agency Each has advantages and disadvantages. A key factor is that the responsibility for safety can never be delegated or contracted out, only its delivery. This means that where an organisation does not itself carry out an activity it must assure itself of the competence of the party carrying out the activity (unless the party is part of government such as a road driving test examiner) Using an “independent” 3rd party for assessment has strengths and weaknesses. Independence gives transparency to the process and gives a level of comfort that internal processes might not achieve. On the other hand the duty holder may have difficulty in ensuring that the standards and competence of the “independent” body are adequate, especially if it is truly independent. To rely upon an organisation over whom the duty holder has little control for such a critical activity is not without risk. This dilemma is however avoided if the “independent” organisation is a government agency or has been accredited by government, but this is only credible if the organisation employs or contracts in the necessary technical experts. Notified Bodies are required to guarantee that they employ persons with the right professional qualifications and an appropriate level of technical experience in their stated area of expertise. The Competence Model That competence is very important in rail engineering is a given presumption. However, the UK government (DfT Rail) and many within the industry are making it known that they consider that costs of undertaking railway projects are far too high both for infrastructure and rolling stock provision. Implied in this is a concern as to the overall competence of the industry, which must embrace the total delivery of engineering: design, implementation, commissioning, maintenance and technical support. In all of these, if the end result is an over engineered product or system with adherence to standards or complex processes not appropriate for the work being undertaken and at a cost that bears no relationship to the benefits being obtained, then the engineers involved are perhaps considered not to be competent by their business management colleagues. UK railways have to be affordable and there is no reason why engineering activity in the UK should be any less value for money than elsewhere in Europe or the developed world. There is a cost to ensure competence, but competence delivered properly should deliver net cost benefits. Role models of the oil and gas industries have successfully demonstrated this. REF Competency Stmt v11 16-11-06 4 Competence for the rail engineering disciplines comprises three basic elements General Engineering System to include generic competence for types of work and non specific equipment Equipment Specific to include proven competence on products from different manufacturers This model may be compared with that for driver proficiency General, including Competence Rules and Operating Principles Route Rolling Knowledge Stock Knowledge General Engineering competence will include trackside safety training and knowledge of railway rules and regulations. Should competence be applied in a consistent manner between disciplines by both infrastructure and rolling stock owners/operators? In the past each of the engineering disciplines and industry organisations has been free to decide what is best to ensure competence for their particular application but is this right? Moreover, is it sustainable into the future? REF Competency Stmt v11 16-11-06 5 Professional Qualifications in the Engineering Industry Four of the REF member Institutions (the ICE, IMechE, IET and IRSE) are licensed by the Engineering Council UK and can provide professional engineers with a route to demonstrate their competence by becoming registered as a Chartered Engineer (CEng), Incorporated Engineer (IEng) or Engineering Technician (EngTech). A professional registration also means that the individual has to follow a code of conduct relating to engineering and business ethics. Obtaining these qualifications is not easy and candidates must prepare a portfolio of evidence to include experience and training. A professional review interview will take place at CEng and IEng level and is discretionary at Eng Tech . The qualification is for life but members of the professional institutions are required to follow a „Continuous Professional Development‟ plan to ensure that their knowledge and experience is kept up to date. The qualification, whilst useful, is broad based and will not guarantee competence when working on specific systems and equipment. It should mean however, that a person with a professional qualification is aware of his/her limitations, and will know when to call for assistance if the task is outside his or her knowledge base. The Role of BS5750 and ISO 9000 British Rail in its latter days as part of its safety and quality initiative, required its rolling stock and engineering infrastructure business units to achieve the BS5750 quality accreditation. This required each unit to consider the processes by which it operated and the standards that needed to be achieved. This initiative forced production units to look how they managed their engineering processes and to systematically address the issue of competence as an essential pre-requisite for reliable operation of any engineering activity. Most units succeeded in getting the BS5750 „badge‟ and real improvements were recorded, which carry forward today. A sense of ownership and pride was instilled in the workforce. The structure required by BS5750 (now ISO 9000) continues to make sure that in designing / developing a process and the associated allocation of tasks, the required competence is specified as part of that process. Most of those units became privatised but kept their quality registration, migrating to the ISO 9000 series standard when appropriate. The system works best when the organisation is relatively small (e.g. a TOCs Engineering Activity) and the management processes are in „bite size‟ chunks with the business goals clear for all to see. Large organisations can attempt an overall registration but face an uphill task because of their organisational complexity and multiplicity of inter- dependent organisational units. Network Rail is typical of this situation but is by no means unique. Competence Systems within the Rail Engineering Disciplines Signal & Telecommunications. Signal & Telecommunications engineering competence is underpinned by a Licensing Scheme operated by the IRSE that predates the „Safety Case‟ regime put in place at privatisation. Accredited to the ISO17024 standard for personnel competence, the scheme was borne out of the Clapham accident of 1988 and is the standard for S&T engineers and technicians REF Competency Stmt v11 16-11-06 6 working on Network Rail and LUL, including contractors. The scheme is „generic‟, so as to provide a person with a licence that gives assured competence in a particular task area, but not aligned to particular models or makes of equipment or employer. Licences cover the various tasks of installation, maintenance, testing, design, project engineering and management, within a hierarchy of Technician, Team Leader, Engineer and Manager levels. The scheme covers the latter two stages of the competence process with the workplace assessment being usually done by the individual‟s line manager who produces an initial evaluation, followed by an independent competence assessment done by a vocationally competent qualified assessor approved by the IRSE and who is independent from the individual‟s daily tasks. All individuals are required to have and maintain a Log Book in which is recorded all training, experience and significant work based activities. A number of Assessing Agents are approved by the IRSE to undertake the management, verification and administration work prior to recommending that the IRSE issues the licence. All of this requires considerable commitment, not only from the IRSE but also from the employers in the profession and the individuals themselves. Licences are valid for 10 years and includes a mid life surveillance review at 5 years. The assessment costs have to be borne by the employing organisation, but the cost of licences as issued by the IRSE, is quite small. The IRSE Licensing Scheme represents the classic „independent‟ 3rd party approach. Electrification Infrastructure. Electrification engineering has no formal method for assessing competence in the rail workplace but relies instead on external qualifications in power systems, plus the professional qualifications of those involved. There are relatively small numbers of people employed in this sector, covering design, provision and maintenance of electrification infrastructure. A competence / skill matrix is used to decide the right people for the various tasks. A formal licensing or registration system is not seen as necessary beyond the use of recognised professional qualifications. Electrification systems have a common feature of high voltages and currents and the risk of electrocution and injury to staff is significant, thus perhaps ensuring the necessary competence of the individuals involved. Traction and Rolling Stock. T&RS competence has some parallels with the automotive industry, but with the addition of requiring an overall safety management system to be in place. Engineering staff receiving in depth training for the various types of rolling stock, following which a build up of knowledge and experience is gained. The ROGTS Regulations and the former Safety Critical Work Regulations require that formal and structured competence assessment and records are kept. Each „business‟ unit is small enough for tight controls to be in place to ensure competent staff by means of records for all assessed training and this fulfils the ROGTS requirements. Normally the TOC‟s Safety Management Systems require that key personnel are Members of the IMechE or IET. This provides rail industry employers with confirmation that the senior rolling stock engineers managing the operation have achieved a defined level of academic and professional qualifications and REF Competency Stmt v11 16-11-06 7 engineering competence, together with the ability to make sound independent judgements. Permanent Way. Engineering competence for track work needs to cover design, installation and maintenance. No formal industry wide scheme exists at present and current efforts are focussed on raising the profile of training and particularly the profile of the trainers. The PWI is producing new textbooks or updates to existing textbooks aimed at explaining the intricacies of modern day permanent way work. Network Rail has devised its own system for ensuring competence for Permanent Way staff. This is a single stage assessment process based upon knowledge and experience as recognised and recorded within the line management chain. Civil Engineering. Assured competence is required to cover the design, construction and maintenance of bridges, structures, earthworks, cuttings, embankments and drainage. The engineering knowledge required for these activities is not necessarily unique to the rail industry and civil engineering professionals can rely to some extent on their CEng, IEng or EngTech competence qualifications. Whilst the ICE maintains a dialogue with the rail industry to ensure the standards associated with these qualifications meet railway requirements, there is currently no specific competence scheme envisaged for civil engineers working solely in the rail sector. Membership of the ICE does however provide rail industry employers with confirmation that civil engineers have achieved a defined level of academic and professional qualifications and engineering competence, together with the ability to make sound independent judgements. Network Rail applies a similar competence regime to that for Permanent Way in respect of bridge work and other railway civil infrastructure. Pragmatically, any such railway specific competence registrations should not be necessary for other civil work away from the „running line‟, e.g. the construction of car parks. In practice, local Network Rail management may choose to insist on the use of registered competent persons regardless of the work being undertaken. The London Underground Situation With Metronet and Tube Lines now established, LUL has decided ( and the ROGTS Regulations require it) that all engineering and technical staff involved in infrastructure and train maintenance work will need to demonstrate competence in any activity involving safety. This is to be achieved by the introduction of a mandatory Competence Assurance standard. Some initial work has already been done. Metronet have introduced a licensing scheme for professional engineers engaged in the design function and will roll this out to other activities in due course. Tube Lines is also rolling out a competence assurance scheme across its professional engineering functions. LUL already used the IRSE licensing scheme for its S&T staff, so these licences have transferred with the staff to the new employers. European Requirements REF Competency Stmt v11 16-11-06 8 The “main-line” railway is now covered by the European Safety and Interoperability Directives, which require that in order to obtain Safety Certification (Train Operators) or Authorisation (Infrastructure Managers) organisations must have a Safety Management System approved by the Safety Authority. A key element in achieving this is to have in place a verified training and competence management system. In addition, new infrastructure and rolling stock before being placed into service, must be verified by Notified Bodies (NoBos), appointed by government, to confirm that products or installations conform to the necessary standards. In Great Britain, NoBos are authorised by the DfT on the advice of UKAS (United Kingdom Accreditation Service) and as such are Government driven. Work is underway at the European Rail Agency (ERA) on a scheme for the accreditation of Rolling Stock Maintenance Workshops. The recently set up UK Railway Industry Supplier Accreditation Scheme, which looks at competence down the supply chain, is a precursor to this. The ERA is also looking at the accreditation of all types of training facilities. In parallel a directive that envisages a state supervised training and licensing regime for train drivers is also nearing its final stages of development in the European Council and Parliament. Because all these initiatives are under the auspices of a single agency (ERA) an increasing alignment between the requirements as applied to different disciplines can be expected. It will be important however to make sure that responsibilities are clear and not overlapped or duplicated. In particular it is essential to make clear how licensing of individuals by external parties (usually government) fits with the overall Safety Management System of a Train Operator or Infrastructure Manager. Will a TOC or Infrastructure Company be content to rely upon external verification of an individual‟s competence i.e. a licensing scheme? If not, then it is unclear as to what value the independent verification adds other than to give the public some degree of re-assurance. External Accreditation A question often asked is whether competence schemes should be externally accredited, regardless as to who operates the scheme. Such accreditation will give the scheme a recognised mark of approval with the implied confidence that this gives to the public, customers and regulators. However, the risk is that the accreditation authority will concentrate more on the administration and procedures of the scheme rather than on achieving effective competence and that the responsibility for ensuring competence may become blurred. It is a moot point as to how much liability would be taken on by the 3rd party in the event of an accident. Would the accreditation amount to a warranty for the scheme? To test these issues, the IRSE Licensing Scheme sought and obtained accreditation by UKAS, which is a government body established to bring credibility to certification schemes in general. It has no government funding and has to meet its costs through charging for inspections and assessments. Thus, REF Competency Stmt v11 16-11-06 9 external accreditation is not cheap. Guidelines are given on how to meet ISO17024, but these are open to interpretation. Little guidance will be given by UKAS as to how a specific competence scheme should be designed. UKAS will assess the merits of the scheme and, if it meets the standard, will grant accreditation. The process is similar to gaining ISO 9000 accreditation. The demand to add all embracing and what sometimes appear to be overly bureaucratic procedures, can give the impression of adding little benefit to the level of competence being sought. The result can be frustrating process. The costs of external accreditation and the likely increase in complexity need to be set against the potential additional robustness in the verification process and the correctness of the competence element. This can be a fine balance. The Way Forward The assurance of competence has to be achieved by all organisations working in the UK rail sector and it is a legal requirement placed upon Network Rail and the Train Operators that their competence management systems shall be documented and approved by HMRI. For those organisations outside of this regime (mainly contractors and suppliers to the industry) the question of formal competence measurement needs to be considered in all sections of the railway engineering disciplines. The requirements should be to: Produce a competence assurance system Provide a means of competence certification Be personal to the individual and relate to their specific competencies Be capable of withstanding audit Recognising that structured competence management is at the heart of all European Train Operators and Infrastructure Organisation Safety Management systems and that they all use the same suppliers, the question of developing a common regime that spans across all disciplines arises. It makes sense for all disciplines to work towards having a consistent philosophy that underpins management of competence. This would need to meet both the legal requirements and to assure transferability and mutual recognition. To be effective, a common competence assurance system needs to be recognised as part of the Train Operators and Infrastructure Managers safety management and supply chain systems, together with some form of governmental endorsement and accreditation. Key decisions are on how to comply with the relevant international standards and what form of accreditation against those standards might be adopted. The Professional Institutions already provide the base for awarding professional engineering qualifications (CEng, IEng, Eng Tech) and some are contributing to the operation of competence schemes for engineers and technicians. The Institutions have specialist technical knowledge that is independent from employing and supplier organisations. The IRSE has shown that a transferable REF Competency Stmt v11 16-11-06 10 licensing scheme can be made to work in a part of the industry with a huge amount of labour mobility. There is recognition that licensing does represent an additional cost, principally due to the assessment process. This process however must be done properly and there will be similar costs regardless as to how it is achieved. As duty holders, the Train Operators and Infrastructure Managers are legally responsible for the competence of employed and contracted staff and this responsibility cannot be transferred in totality to another body. The Engineering Institutions are ready to work with the rail industry to assist with developing common and transferable competence standards and processes that can be used by all. As has been seen, the subject is complex and will require a concerted effort by all, both in the UK and within Europe, to understand the real issues so as to prevent duplication of work and an over zealous expensive result. Clive Kessell Chairman, Railway Engineers Forum November 2006 REF Competency Stmt v11 16-11-06 11