Writing safety plans A guide for operators Spring A

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					Writing safety plans -
A guide for operators

Spring 2008
A guide to writing safety plans   2   Spring 2008
                                         Preface
This guidance document has been produced to accompany the Railway
Strategic Safety Plan (SSP) and will be periodically reviewed to ensure its
continued compatibility as the SSP is updated each year. As with the Plan,
this guidance is a transitional document, intended to facilitate the
development of safety planning over the next few years, to a position where
industry safety trajectories can be driven by what is achievable and affordable
by the transport operators involved in the industry themselves. This is the
third version of the guidance and follows version 2 published in Summer
2007.
The objectives in producing this guidance continue to be:-
•   To facilitate consistent and comparable safety planning across operators
•   To facilitate the best and most effective use of resources
•   To clarify the planning process
•   To encourage the use of common tools and data in planning
•   To ensure that operators remain in control of their decision making
•   To facilitate consistency of annual safety plans and reports
In recent years, thinking regarding safety decision making on the railways has
moved forward significantly. The addressing of certain significant risk
precursors and the consequent reduction in the risk of catastrophic accidents
has eased the critical public scrutiny the railways had been subject to during
the last decade. This situation has effectively given the railway time to think
for itself and to develop coherent arguments around the issue of safety
decision making 1 .
This guidance has been updated following the the publication of the 2008 – 10
SSP in January 2008. Feedback on earlier versions of the guidance has been
positive and as this and further updates are made it is the intention that
information will be built upon rather than replaced. This will ensure not only
that anyone with the latest version of the guidance has all the information that
has gone before, but also that anyone coming into a safety planning role for
the first time has a reference document that will help them whatever their
previous experience.
Statistical data behind the SSP is also available, in particular that which
defines the key risk areas in the SSP and also the provision of local risk
pictures. The first risk pictures were route based because route based
analysis was readily available but operator based risk pictures have now been
developed and are published in volume 2 of this guidance which will be
available to operators by June 2008.
It is clear that some of the terms used in today’s railway cause confusion.
Clearer and more extensive definitions of terms have been provided in the
text. Additional references have also been added to both the glossary and

1
 Taking safe decisions – how Britain’s railways take decisions that affect safety –
RSSB/TSD/001 – RSSB 2007


A guide to writing safety plans                3                                      Spring 2008
references section. Where an online definition of a term is available, a
hyperlink has been added to the glossary. Hyperlinks are also included in the
references and further reading section to facilitate access to documentation.
Hyperlinks were functional at the time of publication; they will be periodically
tested and the guidance updated accordingly. Anyone developing a safety
plan should ensure that they are aware of and understand the relevant
documents referenced in this guidance.




A guide to writing safety plans        4                              Spring 2008
 Contents

Preface .........................................................................................................................3
Introduction ................................................................................................................7
  Fig. 1 – Schematic plan of SSP development process .....................................9
Background ..............................................................................................................10
Basic requirements of a safety plan ..................................................................12
     Why write a safety plan? ..................................................................................12
     Principles of planning .......................................................................................12
  Fig. 2 – Schematic of safety planning process.................................................14
Process ......................................................................................................................15
     Establishing your risk profile............................................................................15
     Review the 9 Key Risk Areas for applicability ..............................................15
  Fig. 3 – Key risk areas from the SSP.................................................................15
  Fig. 4 – Table of key risk area FWI figures .......................................................16
     Assessing risk under the control of the operation ........................................18
     Identifying priorities for actions .......................................................................18
     Factors to consider in assessing risk .............................................................20
Developing trajectories .........................................................................................21
     Analysis of existing actions..............................................................................21
     Identification of new actions ............................................................................21
     A good idea is a good idea ..............................................................................21
     Liaison between Network Rail and other transport operators....................21
     Safety decision making ....................................................................................22
Structuring the plan................................................................................................23
     Format.................................................................................................................23
  Fig. 5 – Example of safety plan information needed for aggregation ...........23
     Content................................................................................................................24
Glossary…………………………………………………………………………….25
References and Further Reading........................................................................27
  Annex A – Duty holder data input sheet from RPB v5 templates..................28
  Annex B – ‘Control’ sheet from RPB v5 templates ..........................................29

Volume 2 of this guidance provides supporting data, including route based
and operator based risk pictures. It is available to operators on a controlled
distribution by contacting RSSB.




A guide to writing safety plans                                 5                                                Spring 2008
A guide to writing safety plans   6   Spring 2008
Introduction
Annual safety plans have been a feature of Britain’s railways since before
privatisation. In the past, Railway Group and Strategic Safety Plans have
often been able to set objectives based on the predicted outcome of major
initiatives, for example introduction of TPWS and replacement of Mark 1
rolling stock. Such initiatives have been very successful in reducing
catastrophic risk, with the result that the ‘big wins’ are now more difficult to
identify. Analysis of the PIM shows that the good levels of performance set in
2005 and 2006 were maintained in 2007. This shows that there have been
actions undertaken, within the industry, to good effect and emphasises the
need to identify and spread good practice. It is essential that where good
performance is happening there is an understanding of why it is happening
and a need to identify areas where reasonably practicable improvements can
be implemented both locally and on a national basis.
RSSB has a responsibility to lead and facilitate the railway industry’s work to
achieve continuous improvement in the safety performance of the railways, to
set standards, and to monitor and report on the railway industry’s health and
safety performance. This is set out in RSSB’s constitution agreement.
Essential to this role is an understanding of the overall risk level and risk
profile of the railway. RSSB needs this understanding to ensure that
Standards address the risk in a proper manner at a network level. In addition,
transport operators need information on risk to formulate their own safety
policies and plans. The joint aim is to reduce safety risk by removing or
controlling the precursors to accidents, so that the challenges in the SSP can
be met.

From 2007 onwards the SSP adopted a ‘trajectory’ based approach. This
process involves aggregating the planned effect of safety related actions from
each transport operator’s safety plan into a single set of combined actions.
For each set of combined actions there will be a reasonable prediction of the
overall reduction in risk based on the actions proposed by each transport
operator: a trajectory. The principle of this process is to base the Strategic
Safety Plan on planned achievable trajectories rather than unquantifiable
aspirations. Transport operators setting trajectories that run through and
beyond 2009 will need to take account of the Secretary of State’s High Level
Output Specification (HLOS). Further information on HLOS is available in the
SSP and from the Department for Transport’s (DfT) website. 2
This guidance deals with the production by transport operators of their own
safety plans. It is also intended to be entirely compatible with the requirement
for transport operators who share the control of a particular risk to cooperate
in managing that risk. There is a mechanism in place for liaison between
Network Rail and transport operators on its network to share in the
development of each other’s safety plans. Details of this mechanism are set
out later in this guidance.
Although in the past the objectives in the national plans have generally been
quantified, the plans of individual transport operators have tended to be less

2 http://www.dft.gov.uk/pgr/rail/strategyfinance/strategy/hlos/briefingnoteonthedevelopment3511



A guide to writing safety plans                   7                                       Spring 2008
so. Attempts to aggregate current operator safety plans into quantified
trajectories have shown that their content adopts variable forms, some of
which do not support quantification, measurement or comparison and
therefore, aggregation. In order to permit measurement and aggregation,
transport operators’ trajectories will need to adopt some common features.
Use of the safety risk model (SRM) templates to analyse and benchmark
performance will facilitate the linking of trajectories set by each transport
operator to the key risk areas in the SSP. The common measures needed for
comparison are fatalities and weighted injuries (FWI) predictions for the top
risks addressed by the transport operator’s trajectories, and the normalising
data required by the SRM templates (see Annex A). Any operator already
using the templates for safety planning should find that minimal additional
information will need to be supplied to RSSB. For those not using the
templates, this is the ideal opportunity to seek assistance from RSSB in their
use.
It is anticipated that the trajectory based approach will bring the following
benefits:
    •   Provide a reasonable degree of confidence in predicting future
        movements in industry safety performance
    •   Identify risks where effort can be adjusted to ensure the most effective
        application of resources
    •   Target actions on risks relevant to the individual operator
    •   Assist transport operators, RSSB and the Office of Rail Regulation
        (ORR) in both developing long term safety strategies and reporting
        their outcome
    •   Development of a structure and process that can readily respond to
        and meet the Common Safety Targets as set out by the European Rail
        Agency (ERA) from 2009
    •   Assist operators in meeting their obligations under the Railways and
        Other Guided Transport Systems (Safety) Regulations 2006. (ROGS)
    •   Result in an industry safety strategy that is appropriate to the risks,
        realistic and achievable.
    •   Demonstrate that the industry meets the requirement to reduce risk to
        as low as is reasonably practicable.
Figure 1 gives an overview of the development process for the 2008 – 10
SSP.




A guide to writing safety plans          8                               Spring 2008
                                  SIG = safety improvement group



                  Fig. 1 – Schematic plan of SSP development process



A guide to writing safety plans                 9                      Spring 2008
Background
The SSP needs to reflect the actions being taken by transport operators in the
key areas of risk facing the industry. Without this basis in reality the Plan can
be nothing more than aspirational. The exception to this would be where a
significant, national initiative was being undertaken for which the justification
was a known outcome, in terms of risk reduction. In reality the relationship
between the SSP and the aggregated plans from duty holders will be iterative,
or circular, each working off the other to develop and refine the actions being
taken and to spread good practice particularly in sharing what works, and
what doesn’t, in dealing with risk.
In 2007 transport operators produced the first annual safety reports (ASR) as
required by the Railways and Other Guided Transport Systems (Safety)
Regulations 2006 (ROGS). The ASR is an integral part of the safety planning
process including amongst other things, reports on safety performance, how
safety targets are met, the results of putting safety plans into effect and the
findings of safety audits. In May 2007 RSSB published guidance on the
production of ASRs under ROGS. 3
The 2008 - 10 SSP identifies that after analysis of the SRM. over 95% of the
total residual risk on the railway is accounted for by nine risk areas. These
areas were therefore selected as the key risk areas to be covered by the SSP.
Whilst this assists focus on the most significant risk areas there will be
variations in their relevance to individual organisations; not least between
railway undertakings and infrastructure managers. There will be further
variations in the influence a transport operator can have on a particular risk
due to the nature of its operation or equipment etc. They will not necessarily
be the top nine priority risks for any of the transport operators producing their
own safety plan. Each transport operator must structure its plan to deal with
the risks relevant to its own operation with particular emphasis on any risk of
fatality or catastrophic risk. It is recognised that transport operator’s plans will
be made up of a combination of local requirements and legislation driven
actions, as well as the nationally significant issues dealt with in the SSP.
A review of individual company plans has shown:
    •   Considerable variation in approach
    •   Variable use of the risk profile bulletin and safety risk model
    •   Variable use of measurable objectives
The purpose of this guidance is not to tell transport operators how to plan to
manage their own risks; they already know best how to do this; it is to
facilitate a common approach in responding to the key risks facing the
business in a way that enables an aggregated analysis to predict the effect on
overall risk on the network.
It should be noted that so far as ‘health’ is concerned the scope of the SSP is
currently restricted to health issues which directly affect the safety of the

3
 Guidance on the production of Annual Safety Reports under ROGS, RSSB, 2007
http://www.rssb.co.uk/pdf/guidance_annual_safety_reporting_rogs.pdf


A guide to writing safety plans          10                               Spring 2008
railway, and health issues arising out of safety incidents (e.g. SPAD resulting
from driver ill health and trauma resulting from witnessing a fatality). This
does not prevent individual transport operators from including other health
issues in their plans should they so wish.




A guide to writing safety plans       11                              Spring 2008
Basic requirements of a safety plan
Why write a safety plan?
There is no legal requirement for a company to produce a Safety Plan, but it
must have safety plans. ROGS Schedule 1 para 2(b) requires that a transport
operator’s safety management system include:
        ‘qualitative and quantitative targets for the maintenance and
        enhancement of safety and plans and procedures for reaching those
        targets’
ROGS also makes the hint that these targets should constitute a plan in
Regulation 20(1)(b) where it states that an annual safety report should
include:
        ‘the results achieved through putting the transport operator’s safety
        plans, referred to in paragraph 2(b) of Schedule 1, into effect;’
The SSP is something the industry chooses to produce through RSSB to
demonstrate its overall intent to manage and improve safety performance.
Some companies choose not to produce a document that is specifically titled
‘Safety Plan’, others choose to produce a clearly identifiable document as a
way of bringing together a summary of its specific actions and programme to
manage and improve safety performance. However, whatever method of
documenting safety actions is taken, all successful management systems
require a degree of planning and clarity of objectives.
Whilst success in managing health and safety is often expressed in terms of a
lack of undesirable outcomes, the reasons for any reduction in accidents,
losses or ill-health need to be understood. A management system is only
really successful in managing risk if a correlation can be made between the
actions taken and the outcome the action was intended to affect. For this to
occur then hazards and risks need to be identified, evaluated and either
eliminated or have appropriate control mechanisms put in place. Proactive
management is particularly important in situations where the risk may only
become apparent after a considerable period of time. Examples of this would
be where a gradual degradation of maintenance capability might result in a
catastrophic accident many years on or in the case of health risks which do
not show their effects for many years.

Principles of planning
All transport operators on the railway will have undergone a planning process
in order to develop their safety management system. To set qualitative and
quantitative targets to maintain and enhance safety, as required by ROGS,
the transport operator must establish:
    •   Where are we now?
    •   Where do we reasonably want to be?
    •   What do we need to do to get there?




A guide to writing safety plans         12                             Spring 2008
In order to identify where the transport operator is positioned in terms of
safety performance it is necessary to have accurate information about the
current situation, measurement criteria or benchmarks against which to judge
this and the competence to analyse the necessary data. Many transport
operators find the generic template spreadsheets produced to accompany
Railway Group guidance note GE/GN8561 Guidance on the Preparation of
Risk Assessments within Railway Safety Cases and the Risk Profile Bulletin
(RPB) helpful, but not all are using them to their full potential. Transport
operators are encouraged to make use of the template for establishing their
benchmark data on which to base their safety planning. Copies of the RPB
v.5 template have been issued to all RSSB members. In addition, RSSB will
run workshops as required on the use of the revised template. Further copies
and assistance with the use of the template can be obtained by contacting
RSSB. The Safety Risk Model v5 Templates User Guide is essential reading.
The ASPR naturally enough deals with events that have already transpired
and the SSP has traditionally dealt with actions to address those events. For
safety plans to become more proactive and for the SSP to deal with actions
that will mitigate against hazardous events before they occur then more ‘input’
measures must be taken into account. The development of the PIM takes this
forward and precursor trends are reported on in the ASPR. To ensure the
most proactive approach in preventing accidents, measurements of safety
management system performance must be addressed in safety plans. The
ASR now requires a report of the findings of audits carried out on the safety
management system of the operator. If such audits are carried out
competently they will identify shortcomings in the system which can be dealt
with in the safety plan before they ever become hazardous events.
The typical safety planning process can be summarised in the flowchart
shown in figure 2.




A guide to writing safety plans       13                            Spring 2008
                      Fig. 2 – Schematic of safety planning process




A guide to writing safety plans            14                         Spring 2008
Process
Establishing your risk profile
GE/GN8561 Guidance on the Preparation of Risk Assessments within
Railway Safety Cases has an outdated title but much of the guidance
contained within it is still relevant to understanding the anticipated risk profile
of a transport operator. The template spreadsheets, referred to in the
previous section, are designed to be used in conjunction with GE/GN8561
and the current version of the RPB. The templates will produce a
representation of the expected risk for an operation of the size represented by
the base normalisation data entered (see Annex A). The results then need to
be refined by ensuring that the scaled national data is modified with as much
actual data from the transport operator as possible. Real data and experience
should be used to inform a decision as to whether actual operational
experience differs from the profile presented.
Local factors must be taken into account such as prevalence of level
crossings and density of traffic to make the risk assessment more
representative of the actual operation. The more real data that is available
then the more reliable will be the representation in the model. The ’control’
sheet from the SRM templates which shows the simplicity of navigation of the
templates is reproduced in Annex B.

Review the 9 Key Risk Areas for applicability
The nine Key Risk Areas addressed in the SSP were chosen as together they
represent over 95% of the total residual risk on the railway as can be seen
from figure 3.




                           Fig. 3 – Key risk areas from the SSP




A guide to writing safety plans            15                           Spring 2008
The nine key risk areas are represented in figure 4, with their total figure for
fatalities and weighted injuries and an indication of which type of transport
operator would have a significant input to risk control in that particular area
(crime is broken down for clarity). This is only a guide; each transport
operator must decide the relevance of each risk area to its operation. As no
single organisation has the major role in all of the top 9 nine risk areas, the
chart in figure 3 can be used as an indicator of the next highest national risk
area that should be considered. It must be remembered that the figures on
which this assessment was made are fatalities and weighted injuries and not
actual fatalities. Consideration of action to be taken will need to take account
of this factor; for example shunters appear to be low on the priorities and are
not in the top 9 risk categories because there are disparities in the way the
Annual Safety Performance Report (ASPR) and SRM record and report the
relevant incidents. Preventing shunter fatalities will however rank much
higher in the priorities of a freight transport operator.

Key risk area               FWI/yr      TOC    FOC    OTM             NR
                             Public Behaviour
Crime – Assault                 31.90
Crime –Vandalism                  1.20
Crime – Trespass                48.59
Crime – Terrorism                  N/A
Level Crossings                 12.14
                               Passengers
Behaviour on stations           25.43
On trains                         3.43
                               Engineering
Infrastructure                    5.16
Trains                            4.09
                                Workforce
Train crew                      13.84
Trackworkers                    28.09
At Stations                     24.07
            See glossary for key to FWI, TOC, FOC, OTM & NR

                        Fig. 4 – Table of key risk area FWI figures
The ticks in figure 4 are indicative only. A more detailed breakdown of the key
risk areas in the table appears in volume 2 of this guidance.
Note: During 2008 a new weighting for ‘non-reportable minor injuries and
Class 2 trauma events’ of 1:1000 will be introduced for the evaluation of risk.
The FWI figures in this document do not reflect this and will be recalculated in
due course.
Volume 2 of this guidance gives additional information that can be used to
identify the main areas of risk exposure. As well as the breakdown of the key
risk areas, volume 2 includes risk pictures developed to indicate relative
differences in exposure between routes and individual train operators. Two
‘health warnings’ apply to use of the information in volume 2.



A guide to writing safety plans             16                        Spring 2008
•   It must be recognised that the key risk data is based on the SRM version 5
    whereas the local risk picture data is drawn predominantly from SMIS.
    The SRM gives a longer term analysis of risk and includes predictions of
    fatalities that have not happened, but could happen, based on long term
    trends in performance. SMIS is simply a record of actual events year by
    year.
•   Any database is only as good as the data entered. SMIS is no exception.
    Each operator should compare the risk picture output with their own data.
    If there is a major discrepancy then there could be an issue with input data
    quality. It goes without saying that any operator not making the relevant
    inputs to SMIS cannot expect relevant outputs.




A guide to writing safety plans        17                             Spring 2008
Assessing risk under the control of the operation
From the information the transport operator has on its own operations, the
analysis provided by the RPB template, key risk data and its own actual
accident and incident statistics a transport operator can identify its own
contribution to a particular national risk area. It is important throughout this
exercise that regular sense or reality checks are made of the emerging
picture. For example if a transport operator employs 10% of the national total
of train drivers but does not operate under overhead electrification it should
not expect to see 10% of risks to train drivers associated with overhead line in
its profile. On the other hand it may account for say 30% of the national
operation over 3rd rail.
A transport operator with reliable information about the safety performance of
their own operation from their own data could assess their risk based on the
data. The advantages of this approach are that the collected data will be
relevant to the dutyholder’s operation and the operator should have an
understanding of the integrity of the data set. Operator’s own data should
only be used where there is reasonable confidence about data quality. Whilst
the method of using the RPB templates will initially give a proportion of the
national figures based on SRM data, the greater the proportion of actual data
that can be input, the more representative of actual performance the output
will become.
Not all risks will be readily identifiable and quantifiable from the above
process. For example, any transport operator operating a large station will
have a significant number of visitors who are not travelling on the railway.
They may be using the concourse as a thoroughfare or buying a paper or
sandwich. Normalising slips and trips at such a station by passenger journeys
will give a worsened picture of risk to each individual. Normalising by footfall
on the station will give a more favourable picture but possibly distorted.
Visitors buying a paper will probably not be hurrying for a train, confronting
staff about delays, getting trapped in train doors etc.
Normalisation of an intensive commuter operation by train miles will clearly
give a dramatically different output when compared to an analysis normalised
by passenger miles. The ATOC train operators’ safety group (TOSG) has
adopted a standard set of normalisation criteria for the purposes of
benchmarking between operators. Where feasible the risk pictures being
developed for volume 2 of this guidance will follow the same normalisation
criteria.

Identifying priorities for actions
For each railway undertaking there are several risk areas where additional
effort and funding could be applied to reduce risk further. For each of these
areas, there are numerous possible risk control measures that could be
implemented. Hence it is useful to have indicators that help with prioritisation
of actions for further consideration. Such indicators include:
•   Hazards presenting high levels of absolute risk
•   Specific locations giving rise to disproportionate risk



A guide to writing safety plans         18                            Spring 2008
•   Hazards giving rise to catastrophic risks
•   Relatively poor safety performance compared to other TOCs
•   Groups with high levels of individual risk
Each of these is discussed below.
Hazards presenting high levels absolute of risk
This is the simplest of the indicators; the most significant risk areas are clearly
the primary starting point for the identification of additional control measures.
Specific locations giving rise to disproportionate risk
When an operator has assessed their risk, it is instructive to make an
assessment of how the risk from hazardous events is distributed across their
routes and activities. For example, most operators have a significant risk from
trips, slips and falls in stations and from assaults on passengers and staff.
Initiatives across all services and locations are unlikely to be cost-beneficial,
however, assessing the relative safety performance of particular locations,
routes or times may highlight particularly high risk activities. It is likely that a
significant reduction in risk can be achieved at a relatively small cost by
targeting the high-risk activities.
Hazards giving rise to catastrophic risks
Application of the re-weighting of minor injuries (see glossary) will have the
effect of giving less importance to the more minor accidents and therefore
providing greater focus on addressing accidents that are likely to result in
major injuries and fatalities. Accidents with catastrophic consequences also
incur commercial losses in addition to the immediate safety loss: in particular,
the cost of delays, asset damage, potential fines, legal costs and harm to the
company’s reputation. These additional factors mean that dutyholders should
prioritise precursors with catastrophic outcomes over hazards with minor
outcomes.
Relatively poor safety performance compared to other TOCs
The TOC safety data profiles presented in Volume 2 of this guide indicate the
relative safety performance of the TOCs for a range of accidents. Each of the
charts is normalised so that comparison can be made between TOCs on a
common basis. There are reasons for apparent differences in the safety
performance, such as inherently different service types: additionally, there are
issues with data quality which reduce the value of the data. However,
comparison may indicate areas where similar operators achieve better levels
of safety performance; hence there may be controls that other operators are
adopting that could be cost-effectively applied more widely.
Groups with high levels of individual risk
Although general priority would be given to the areas of highest risk on the
railway system as a whole, dutyholders may consider it appropriate to reduce
risk to groups exposed to high levels of individual risk. Shunting staff might
be an example. Their number are small and the risk to which they are
exposed to (in collective risk terms) is low compared with other risks on the




A guide to writing safety plans         19                               Spring 2008
railway; however, the individuals are actually exposed to a disproportionately
high level of risk compared to other groups of worker.

Factors to consider in assessing risk
Care must be taken when evaluating the risks presented to, and by, a
transport operator. The assumptions on which the SRM is based (published
in section 15.11 of the RPB) should be understood. For example it might be
considered reasonable to expect a much higher risk of being struck or
crushed by trains (HEM-14) amongst freight train drivers than passenger train
drivers. This assumption would be based on the fact that freight train drivers
might be expected to spend more time on the track, using signal post
telephones and inspecting their train than passenger train drivers. In fact, the
risk from HEM-14 represents 27% of the passenger train driver individual risk
profile and 30% of the freight train driver individual risk profile. Without
specific normalising information for the exposure of drivers to the trackside
environment this would suggest that passenger train drivers are more
exposed than they should be compared to freight train drivers. The
conclusion might be that more should be done to manage the risk to
passenger train drivers.
Variations will be seen between the actual accident statistics held by a
transport operator, the ASPR and the SRM. The SRM includes an estimate of
fatalities that have the potential to occur (in low frequency, high consequence
events) but which have not happened. The SRM therefore can present an
elevated individual risk when compared to the ASPR.
The ASPR uses a ten year rolling average in order to capture a statistically
valid sample of data. The figures therefore include five train driver fatalities
from 1996 on. The figures in the ASPR do not however include the two driver
fatalities at Ladbroke Grove in October 1999 as these were TPWS
preventable. The SRM considers all potential fatal scenarios for train drivers,
which is considered to be an indication of the average long term risk profile.
All scenarios with a similarly small sample size are subject to significant
change due to a small number of incidents. This effect needs to be
understood.
The figures for track workers need to be treated with similar care. The ASPR
figures are dominated by eight fatalities in 2004, six of which occurred in two
multi-fatality events. The SRM figures give a prediction of the average
number of track worker fatalities that can occur from all accident scenarios,
therefore giving an indication of the long term risk profile.
Shunters are a particular issue of concern currently. Shunter fatalities are
reported in the ASPR but as most duties are carried out in depots and sidings
they are out of scope of the SRM. All transport operators engaged in shunting
activities will need to specifically examine their statistics to assess their
exposure to risk in this area.
Again the importance of reading the Safety Risk Model v5 Templates User
Guide (see references) cannot be emphasised enough.




A guide to writing safety plans        20                             Spring 2008
Developing trajectories
Analysis of existing actions
At this point, the transport operator should have established its own priority
risk exposures which will include those in the top nine that are relevant.
Analysis and normalisation of these exposures will show where the priorities
are for that organisation to seek to reduce risk. Secondly, any areas where
the risk is greater than might be expected given the characteristics of the
operation will be examined to identify the reasons for the elevated exposure.
Third, areas of risk that appear to be tolerable should be evaluated to identify
where further reasonably practicable measures might be used to reduce the
risk. Finally, areas of risk that appear to be under control should be checked
to ensure that the necessary degree of confidence and assurance that they
will remain under control exists. This can be obtained through assurance
activities such as audit and inspection.
All transport operators will have various actions and initiatives already in
progress. If not already done, they should be matched with the risks from the
above analysis to evaluate the likely effect they will have. Where possible
some degree of quantification should be applied and the risk analysis
adjusted to take this into account.

Identification of new actions
On 22nd May 2007 Safety Policy Group approved a further document (Taking
safe decisions – how Britain’s railways take decisions that affect safety). This
document is available from the RSSB web-site and explains the principles that
are applied to decision taking in the UK railway industry. The document is to
be updated to include specific guidance on how to undertake cost benefit
analysis (CBA) in support of ALARP decisions. This updated guidance is due
to be published in summer 2008.
Consultation with staff representatives and unions is important when
developing solutions to risk issues both in terms of gathering front line
experiences and perceptions, and in ensuring ‘buy in’ to implementation.

A good idea is a good idea
Where an initiative has been successful in one area it makes sense to assess
whether it could be similarly successful elsewhere. The ASPR sets out a
large number of initiatives, both national and local, and is a worthwhile source
of reference for ideas.

Liaison between Network Rail and other transport operators
Aside from the specific legal requirement for transport operators to cooperate
in the interests of safety, it is good practice to ensure that where operations
meet or overlap that planning for safety is coordinated. This is particularly
important where several parties exercise controls which combine together to
control a common risk. On 27 February 2007, the industry’s Safety Policy
Group (SPG) agreed changes to the process for development of the SSP,



A guide to writing safety plans        21                             Spring 2008
including new arrangements for liaison between Network Rail and train
operators in the development of their respective safety plans.
SPG also endorsed the principle that such development should not see the
creation of a new liaison framework, but should be incorporated within the
existing liaison arrangements. It was therefore proposed that Network Rail
Route Directors use the most appropriate forum to establish appropriate
Safety Improvement Groups (SIG).
These Safety Improvement Groups will be the means by which Network Rail
and train operators can meet, at Route level, to share in the development of
each other’s safety plans, and to support their input to development of the
SSP. This will include the risk areas to be addressed, strategy and specific
objectives for further improvement and a quantification of the impact this will
have on each risk area.
This process will provide a shared understanding of both Network Rail and
train operator plans and present the opportunity for each operator to input to
the development of other operators’ plans.
Each SIG will present their minutes and findings to their sponsoring group.
The output of each SIG meeting will include:
•   Identification of any significant omissions within Network Rail or train
    operator plans.
•   Any specific risk/action which the Route recommends to be added to the
    Network Rail or train operating company safety plan (subject to safety
    justification and approval within the relevant company).
•   The likely impact of each group of actions on the risk profile within each
    route - this should be based on high level subjective analysis, informed by
    the Route output of the SRM, the HLOS safety trajectory and judgement
    on the variation within the route compared to the HLOS safety trajectory.

Safety decision making
Anyone engaging in more complex safety decision making should be familiar
with the documents listed in References and Further Reading at the back of
this document.




A guide to writing safety plans         22                              Spring 2008
Structuring the plan
Format
Since there is a requirement to plan for safety but no requirement to produce
a Safety Plan it is inappropriate to specify how such a document should be
laid out. However, in order for RSSB to evaluate the combined effect of
individual plans on the nine key (and other) risks there is merit in the content
being as consistent as the process, in whatever format it is presented. As a
minimum of course, to comply with ROGS, qualitative and quantitative targets
must be presented as part of the safety management system. It is
understandable that transport operators may wish to reserve the detailed
assessment work for internal consumption, particularly where this is
integrated with commercial or business planning. Provided that transport
operators are able to make the data available to RSSB to show projections of
risk reduction in each relevant area for aggregation into future versions of the
SSP then format is not material to the function of the plan. An example of the
type of information required for aggregation is set out in the table in figure 7:
                                                               Impact on risk
Action                    Risk segment            Affected     2008      2009        2010
                          affected                persons
Example - Improving       Passenger slips,        Passengers   -2%       -2%         -2%
stairs by marking the     trips and falls on      Workforce    0         0           0
nosing – high risk        stairs (currently 60    public       0         0           0
stations                  passenger
                          incidents per year
                          for TOC X)

          Fig. 5 – Example of safety plan information needed for aggregation
Note that the impact on risk can be provided in a number of different ways
depending on what is most relevant for the duty holder, as follows:
    •    Absolute risk reductions in terms of FWI per year.
    •    Percentage reductions, together with the number of incidents per year
         or total FWI within the duty holder’s scope.
    •    Change in number of incidents, together with total number of incidents
         per year within duty holder’s scope.
The ‘duty holder’ data sheet from the safety risk model template (see Annex
A) should also be supplied by each transport operator for normalisation
purposes.




A guide to writing safety plans                  23                             Spring 2008
Content
Good practice already exists in the industry and some transport operators
produce a plan that encompasses safety and environmental issues. Typical
content would include:
•   A statement up front from the managing director or equivalent commenting
    on performance and setting out the company’s commitments to its
    trajectories
•   A review of the previous year’s performance (set against the previous
    trajectories if applicable. Having set qualitative and quantitative targets
    ROGS also requires annual safety reports to include the results achieved
    through putting the transport operator’s safety plans…into effect.)
•   New or revised trajectories for the following year(s)
•   Arrangements for review of the achievement of the trajectories
•   More detailed targets or departmental objectives that will contribute to
    achievement of the trajectories above
•   Items on specific topics that will be a focus for the period of the plan.
Before embarking on writing a safety plan the transport operator should
decide who the document is for and what its purpose is. This will focus
thoughts on both format and content and avoid the document being filed in the
bottom draw until the following plan is due or the annual safety report has to
be produced.




A guide to writing safety plans         24                               Spring 2008
                         Glossary (with references)
Where appropriate and available, web references have been given where
additional information on a particular term can be accessed. Further
documentary references are given in the next section.

ALARP As Low As is Reasonably Practicable
           http://www.hse.gov.uk/risk/theory/alarpglance.htm

ASPR       Annual Safety Performance Report
           http://www.rssb.co.uk/pdf/reports/summary_of_safety_performance_2007.p
           df
           http://www.rssb.co.uk/pdf/reports/ASPR_2006.pdf

ASR        Annual Safety Report (as required by ROGS)
           http://www.rssb.co.uk/pdf/guidance_annual_safety_reporting_rogs.pdf

CBA        Cost Benefit Analysis
           http://www.hse.gov.uk/risk/theory/alarpcba.htm

DfT        Department for Transport
           http://www.dft.gov.uk/pgr/rail/

ERA        European Rail Agency
           http://www.era.eu.int/

FOC        Freight (train) operating company

FWI        Fatalities and weighted injuries
           The current weighting means that one fatality is equivalent to ten major
           injuries or 200 minor injuries. The combined measure is termed ‘fatalities
           and weighted injuries’ (FWI). Note: During 2008 a new weighting for ‘non-
           reportable minor injuries and Class 2 trauma events’ of 1:1000 will be
           introduced for the evaluation of risk.

HLOS       High level output specification
           http://www.dft.gov.uk/pgr/rail/strategyfinance/strategy/hlos/

HMRI       Her Majesty’s Railway Inspectorate
           http://www.rail-reg.gov.uk/server/show/ConWebDoc.7770

HSC        Health and Safety Commission
           http://www.hse.gov.uk/aboutus/hsc/index.htm

HSE        Health and Safety Executive
           http://www.hse.gov.uk/aboutus/hse/index.htm


A guide to writing safety plans          25                                Spring 2008
NR         Network Rail
           http://www.networkrail.co.uk/

ORR        Office of Rail Regulation
           http://www.rail-reg.gov.uk

OTM        On track machine (operating company)

PIM        Precursor Indicator Model
           RSSB’s Precursor Indicator Model (PIM) provides a measure of the
           underlying risk from train accidents by tracking changes in the occurrence
           of accident precursors. It was first developed in 1999, and has since been
           subject to a series of modeling improvements, including realignment with
           updated risk information from SRMv5.

R2P2       Reducing Risks, Protecting People
           http://www.hse.gov.uk/risk/theory/r2p2.htm

ROGS       Railways and Other Guided Transport Systems (Safety) Regulations 2006
           http://www.rail-reg.gov.uk/upload/pdf/283.pdf

RPB        Risk Profile Bulletin
           http://www.rssb.co.uk/pdf/reports/Risk_Profile_Bulletin_-
           _Overview_of_Issue_5.pdf

RSSB       Rail Safety & Standards Board
           http://www.rssb.co.uk/

SPG        Safety Policy Group

SRM        Safety Risk Model
           http://www.rssb.co.uk/safety/spr/srmodel.asp

SoFA       Statement of Funds Available
           http://www.dft.gov.uk/pgr/rail/strategyfinance/strategy/hlos/briefingnoteonth
           edevelopment3511?page=3#a1004

SSP        Railway Strategic Safety Plan
           http://www.rssb.co.uk/pdf/reports/strategic_safety_plan.pdf

TOC        Train operating company

ToR        Tolerability of Risk from Nuclear Power Stations
           http://www.hse.gov.uk/nuclear/tolerability.pdf




A guide to writing safety plans         26                             Spring 2008
 References and Further Reading
As well as providing reference material for this document, anyone developing
a safety plan for a transport operator should be familiar with the content of all
the following documents:


Railway Safety Statistical Report 2006
http://www.rail-reg.gov.uk/upload/pdf/rss_report_06.pdf

Constitution Agreement relating to Rail Safety and Standards Board Limited
http://www.rssb.co.uk/pdf/Constitution_Agreement.pdf

Guidance on the production of Annual Safety Reports under ROGS, RSSB,
2007
http://www.rssb.co.uk/pdf/guidance_annual_safety_reporting_rogs.pdf

Profile of safety risk on the GB mainline railway, Issue 5, RSSB, 2006,
mailto:george.bearfield@rssb.co.uk

Railway Group Guidance Note GE/GN8561, Guidance on the Preparation of
Risk Assessments within Railway Safety Cases, RSSB, 2002,
http://www.rgsonline.co.uk/docushare/dsweb/Get/Rail-41475/GEGN8561.pdf

Safety Risk Model v5 Templates – User Guide, RSSB 2007
mailto:george.bearfield@rssb.co.uk


Successful Health and Safety Management, HSG65, HSE ,1997/2003
ISBN 0717612767
www.hsebooks.co.uk

Taking safe decisions – how Britain’s railways take decisions that affect
safety, RSSB, 2007
http://www.rssb.co.uk/pdf/safety/taking_safe_decisions/part_one.pdf




A guide to writing safety plans        27                              Spring 2008
Annex A – Duty holder data input sheet from RPB v5
templates




A guide to writing safety plans   28                 Spring 2008
Annex B – ‘Control’ sheet from RPB v5 templates




A guide to writing safety plans   29              Spring 2008