As someone who has long advocated (that’s a posh way of saying “made a bloody song and dance about”) the wholesale rewriting and simplification of the Rule Book, you might expect me to be a happy man this month; at least as close to ‘happy’ as a Yorkshireman ever gets. June marks the abandonment of several workforce safety-related modules - G2 and T6 amongst them - with new pocket-sized handbooks taking their place, targeting specific duties.
This ‘New Approach’ is RSSB’s latest effort to deliver instructions in a fit-for-purpose form to those who are compelled to apply them. You wouldn’t have thought it was that difficult. However its last costly attempt hugely underwhelmed despite a rumination and paper-shuffling period (they call it ‘consultation’ and ‘development’) measured in years. The deckchairs’ moth-eaten upholstery was refreshed somewhat but, otherwise, the project only succeeded in shuffling them.
Handbooks, you will recall, were vehicles promoted by the TSSG’s Rules Simplification Subgroup during the Middle Ages. Back then, RSSB’s resistance movement vigorously opposed them. But as the Board gets to grips with the challenges of the 20th century - no, that’s not a typing error - it seems that its conversion to them is finally complete.
If you’ve not heard of the ‘New Approach’, you’re not alone. Presumably in an attempt to keep a lid on expectations, RSSB has said precious little about it. Missing have been the high-profile conferences, briefing packs and videos that accompanied the Rule Book’s last overhaul. And yet this one promises real instructional surgery, not just a makeover. The real world must be brought up to speed.
The project does though boast its own section on RSSB’s website, including one absurd page of self-aggrandisement which concludes that “The output from the ‘New Approach’ is assumed to have a safety benefit of 0.245 fatalities and weighted injuries per year.” Bollocks in its purest form, taking in Safety Risk Models, optimism bias, benefit-to-cost ratios and RPI forecasts. Click here to have a laugh at it. If Dave and Nick are still on the look out for cuts to make, here’s a whole department that nobody would miss.
On the agenda is a significant rationalisation of the Rule Book’s content and structure “so that it is more accurately targeted at the skill sets of end users and clearly aligned with operational principles.” Requirements are being simplified by only including “true rules”. That development will worry the country’s treacle producers. The principle of, wherever possible, funnelling all an individual’s procedural knowledge into one document does of course tick the right boxes. That’s why we have had COSS and Track Safety Handbooks for several years.
So what’s the verdict? Let’s consider the inspirationally-entitled ‘Handbook 1’ covering “general duties and track safety for track workers”, as opposed to “general duties and track safety for drug takers” which deals with completely different issues. At first glance, it looks very much like a familiar Rule Book module but, at A6, it’s half the size. The smooth and thick material - I’m talking about the paper, not the content - suggests it will stand up reasonably well to abuse from filthy fingers. At 23, the page count is encouraging but not stupendous. Previously G2 and T6 totalled 74 pages despite adopting a smaller font - the rule writers’ juices must really have been flowing when those two modules were authored.
Although the text is clear, there’s nothing engaging about the Handbook’s presentation. I’m sure Jungle Ron would tell us that a picture paints a thousand words as far as the on-track community is concerned. But here, burgeoning verbiage has taken hold. A solitary diagram explains the meaning of ‘on or near the line’ whilst eight tiny illustrations offer clues about lineside signage. RSSB has clearly not yet invested in a digital camera.
Fundamentally, the only rule a PTS holder needs to understand is “do what the COSS tells you”. However, given that they are bizarrely permitted to head off on solitary yomps down the four-foot to a place of work, a fair amount of additional knowledge has to be heaped on top. Even so, a pragmatist could make a reasonable case for 80% of Handbook 1’s contents to be jettisoned. (RSSB staff can click here for a definition of the word ‘pragmatist’.) Much of it does not feature “true rules”, as advertised. And out of the blue, there is a double-page spread at the back featuring ‘Core Operational Aims’ which stands out like a virgin in a brothel and is as compliant with Plain English principles as John Prescott.
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Fundamentally, the only rule a PTS holder needs to understand is “do what the COSS tells you”. |
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The other point worth making is that many of the lost instructions haven’t actually disappeared. They have simply been booted into other documents - company policies, training plans, local instructions and the like. They’re still expected to be lodged in your brain. So, rather than all the rules being in a single not-so-handy tome, they have been deliberately scattered to the four corners of our safety management system. In an effort to score a commendable goal, RSSB has lofted the ball into Row Z, doing something of a disservice to those struggling to comprehend what precisely is demanded of them.
And there’s more to come. December will see the introduction of handbooks relating to safe systems of work. These have already been out for consultation and, if accepted, will cause some consternation within the fraternity of safety professionals. They don’t like change much, particularly if it involves a loosening of the procedural noose. A sense of déjà-vous will overcome members of the aforementioned TSSG subgroup whose proposals - including a merger of T12/T2 and the despatch of red/green zones - these largely are. A collection of review materials is available here. RSSB's response to any comments received is awaited.
As a footnote, I’ll leave you with a classic passage from Handbook 1. Included is a new rule explaining what to do if there isn’t a rule. “If there is no rule that allows or prevents you doing something you believe must be done, you must do it in the safest way you know, taking into account your training and experience.” It would seem that the Head of Risk Aversion hasn’t yet become a victim of the country’s budget deficit! Let’s hope it’s just a matter of time.
Story added 1st June 2010
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