Few things have done more to compromise frontline rules knowledge than RSSB’s imposition of the Amendments Module in 2005. The overall integrity of the Rule Book and its elevated status as the railway’s safety-critical bible has since been undermined, resulting in its relevance diminishing as a sizeable proportion of live modules promote out-of-date instructions. That’s an indefensible state of affairs for a document that most would instinctively regard as definitive; indeed compliance with it is endorsed on that basis. It’s a fiasco that speaks volumes about the priorities of the Board and its inability to fulfil core responsibilities to an appropriate standard. Yet it falls over itself to commit time, money and manpower to internal corporate navel gazing as it strives to secure unwarranted extensions to its empire.
So anyone browsing the preview of next December’s Module AM - available on the Railway Group Standards website - would have felt a small earth tremor as they opened the PDF. Confronting them was the following message: “This will be the last issue of this module. In future, rules changes will be dealt with by the reissue of the module or by exception, will be published in the Periodical Operating Notice until the reissue of the module.”
Quite an unlikely turn of events. It seems that RSSB is now going to do what it promised back in 2003 when the Janet and John Rule Book was first inflicted on us. Well, better ten years late than never I suppose. Of course, whilst this has to be welcomed, it will do nothing to rectify the reputational damage sustained by the Rule Book during that decade, nor the recent scattering to the winds of many essential instructions under the guise of the New Approach project. For many activities, procedural insight is now lost down the back of the settee - banished into local instructions or flimsy (in every sense) keypoint booklets.
The cause of this sudden shift is not clear; nothing ever is with RSSB. But perhaps pressure from the many industry voices who have expressed concern at the amendments omnishambles has eventually broken the Board’s resistance to doing things properly. Passing interest from the regulator might also have had an influence. Whatever the driver, I now have one less thing to moan about; we can though spend a little time celebrating an unexpected victory over the scourge of ignorant and self-serving officialdom.
Back in the real world, Sentinel entered a new era on 25th September with closure of the NCCA-run system that has served us for the past 14 years. The launch of its replacement coincides with extensive changes to the rules surrounding the role of sponsors, the idea being to share the associated costs and responsibilities more evenly across the supply chain.
When New Sentinel is fully rolled out, anyone working on Network Rail infrastructure must have a primary sponsor, a role which involves the provision of relevant PPE, training, mentoring and procedural information, as well as the monitoring and recording of working hours, investigating breaches of the Sentinel scheme rules and agreeing arrangements for any work carried out for sub-sponsors, of which only two per person are permitted. All this has to be set out contractually between the parties.
The issue of sponsorship is a vexed one. Network Rail cannot legally restrict an individual’s right to make a living but it is keen to set out a proper framework that allows their activities to be managed and controlled. That’s not unreasonable. Currently, 5% of Sentinel card holders have more than three sponsors; at least one has 27! But which of their sponsors is meant to be providing him/her with briefings or arranging competence assessments? The introduction of a primary sponsor will resolve that…at a cost. An annual subscription will be levied against each company reflecting the number of people for whom it fulfils that role.
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| 5% of Sentinel card holders have more than three sponsors; at least one has 27! |
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It’s an evolution that reflects how both the industry and technology have moved on since the late Nineties. From 6th January next year, those attending site must have a smartcard on which competence information will be stored and updated electronically, rather than being printed on the front as now. Everyone in the group will present theirs to the COSS or SAC for authentication and recording using a scanner, usually in the form of a smartphone with an installed Sentinel app. It’s a quantum leap from the supposed 10% verification via the slow phone service that formed part of the old system.
The next phase, to be delivered later in 2014, will cover site access control and harness opportunities around ‘fatigue risk management’: basically recording working hours and imposing restrictions based on the individual’s shift pattern.
Don’t just look upon all this as securing jobs for managerial data crunchers and paper shufflers; there’s also stuff here that benefits real folk. Most notable is the Lone Worker Protection Service which again uses a smartphone app to keep a remote digital eye on IWAs. Once activated, the individual is sent a text message (christened a “Heartbeat”, no doubt by the marketing department) at regular intervals to check they’re OK. As long as this is answered within a defined time limit, the system records the IWA’s location via GPS and then resets itself until the next response is due. If no reply is received, the service transmits repeated messages for three minutes before carrying out an agreed escalation procedure. Quite what happens if, between messages, the IWA moves to a location that’s out of range of the mobile network is not stated. Allied to this app is a ‘Push for Help’ module which triggers either an amber or red alert if the individual finds themself in an emergency situation and presses one of two big coloured buttons on their phone. It’s a simple idea and one that should be commended.
It will no doubt take time for all the new arrangements to become embedded in the industry’s consciousness - we’re not good at change - and obstacles are bound to be encountered on the road to full implementation. But New Sentinel seems to be driven by a genuine desire to improve safety management. Let’s welcome that, even if it impacts on a few people who currently choose to work all the hours God sends for anyone who’ll pay them.
Its 2012 Annual Report rates highly on the RAIB distortionometer.
Finally, RAIB published its Annual Report last month for the year ending December 2012. It includes some fabulous hypocrisy from the Branch’s Chief Inspector Carolyn Griffiths. She declares that “last year I commented that the RAIB investigated a number of accidents where it emerged that those accidents may not have occurred had earlier RAIB recommendations been completed in a timely manner. During 2012 we have seen this again. We have completed five such investigations; two where the subsequent accidents probably would have been avoided had our recommendations been fully implemented and three where there was less certainty but where the subsequent accidents possibly would have been avoided.”
Castigating the industry for not acting with sufficient haste is rich coming from her. It might also be fair to assert that those accidents would not have happened had RAIB published the relevant inquiry reports within the deadline demanded by the regulations that govern its operations, namely 12 months. With astonishing arrogance, the Branch refers to that deadline as an “aim”.
Four of the five inquiries alluded to above exceeded that time limit whilst the fifth crawled under it by just nine days. If you want to know why the industry doesn’t always learn lessons speedily from serious events, you should look at your own organisation’s relentless failings Ms Griffiths. Of the 15 ‘heavy rail’ inquiries published so far in 2013, nine are non-compliant with the regulations. One of them almost took two years. It’s contemptible that these overpaid and seemingly unaccountable civil servants are allowed to disregard their own obligations whilst passing judgement on the rule compliance of hard-pressed frontliners. And whilst RAIB’s 12-month publication deadline is generous (most of the industry’s middle and high level managers believe reports should be ready within six months), trackworkers have to contend with a rat’s nest of complex instructions for which there is currently no definitive reference resource. I feel another indignant missive to the Secretary of State coming on.
Story added 1st October 2013
