We could argue long and hard about the legacy of New Labour. It invested huge (probably ‘unsustainable’) amounts of money in our public services, driving an economic boom…followed by a cataclysmic bust. The divide between society’s richest and poorest grew; to address this, ordinary folk hung the millstone of credit around their necks but then sunk when the bankers’ recklessness took us to the brink. And of course there was Iraq. Whatever your conclusion, one thing is undeniable - the period since 1997 has seen the rise of a truly malevolent force. No, not the spin doctor. We now have a knife held to our throats by bureaucracy and its associated drizzle of middle management. Nothing can move unless first cocooned in paperwork, and then only backwards.
RAIB loves this stuff. It commanded the industry to develop a written definition for the term ‘approaching train’ - a ludicrous edict that changed precisely nothing - and has, on occasions, expressed indignation at those who reach decisions without generating an audit trail. The temerity of it! What’s worse though is the railway’s feeble response to this babble. It just tugs its forelock, rolls over and churns out more garbage. And it’s for this reason that every IWA and COSS now has another form to fill in before they can set foot through the access gate. And so does their planner.
It was much more straightforward in 1998 when I joined the ranks of COSSs. If a T2 was needed, I would speak to the signaller and talk it through with him. Safe systems were devised following site visits and insights gleaned from the Sectional Appendix and Hazard Directory. Around 20,000 other COSSs took a similar approach and got it right almost every time. But momentous exceptions drove the imposition of Rimini - taking safe systems out of practitioners’ hands and placing them into those of former Tesco shelf-stackers. Ownership was lost; responsibilities were blurred. The only safety net came in paper form - the Rimini Pack.
We’ve all seen them - they’re hard to miss after all. They tell you the Compliance Manager’s office number (very helpful in the early hours), the type of asbestos once found in a disused signal box seven miles from site, and the contractor’s policy on recycling and waste management. Unfortunately, they don’t always include the right linespeed or the worksite mileages, but you can’t have everything.
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Unfortunately, they don’t always include the right linespeed or the worksite mileages, but you can’t have everything. |
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So what’s the best way to drive improvements? That’s right - bring the COSS in the day before to check that the planner has done his job properly, then compel them to append their signature to a piece of paper, thus taking responsibility for any blunders. That’s fair and reasonable, isn’t it? Anyone who thinks it would be more effective and less time-consuming just to let COSSs plan their own safe systems has never occupied a management position. Far too sensible.
Yes, Issue 8 of Network Rail Standard NR/L2/OHS/019 - the safety of people working on or near the line - goes live on 4th December. A major briefing programme has been ongoing for the past three months - those IWAs and COSSs who have not successfully passed the assessment will have their qualification suspended until they do.
Implementation brings with it a number of changes, their objective being to improve the accuracy and suitability of planned safe systems as well as ensuring that the IWA/COSS has sufficient time to consider them before the job starts. All that is to be commended. Less helpful are the mechanisms prescribed to deliver these advances. They are protracted, probably impractical in many cases, and will succumb to the tick-box culture - the documentation will be accepted without being checked simply to save time and effort.
This is what’s meant to happen under the new regime. At least one shift before the work starts, each nominated IWA/COSS will have to confirm that the planner’s proposed safe system is appropriate and can be implemented safely. This involves them checking the contents of the Rimini Pack. If it’s OK, they accept it and sign it off; if it’s not, they reject it and return it to the planner with comments. In the event of unforeseen sickness or other unavoidable absence, the pack can be verified on the same shift as the work. After the job, the IWA/COSS must return the pack to the planner, pointing out any errors found or changes that had to be made. This feedback is used to benefit future planning.
One significant step forward is that the scope of the pack is now defined. It will include -
- a partly completed IWA/COSS Form (RT9909)
- a partly completed Line Blockage Form (RT3181) if the safe system involves a T12 or T2
- a copy of the Sectional Appendix covering the access point, site of work and the section of line between them
- relevant extracts from the Hazard Directory
- a copy of the PICOP Pack, if relevant
- additional signal or track diagrams, if needed
- other diagrams needed by those who are placing protection, if relevant.
This, as you can see, is a considerable stack of paperwork but at least there is now a prescribed list of what should NOT be included -
- information about background factors used to determine the choice of safe system
- Work Package Plans
- Task Risk Control Sheets
- risk assessments
- local hospital details.
This last item is a tad surprising. The name and phone number of the nearest A&E are not going to be the straw that broke the COSS’s back and could prove to be of value, so why preclude it?
In selecting the safe system, the planner already has a two-page form to complete, justifying their decision-making. Now they have a second one - the Planning Check Sheet. This features 16 items, each with individual ‘yes/no’ tick boxes, designed to ensure that only finalised packs go forward for end-user verification.
More onerous though is the workload brought by the SSOW Pack Verification Form, to be filled-in by the IWA/COSS. This only has 15 entries and associated tick boxes but, to confirm that all is as it should be, the IWA/COSS has to go through the extensive source material (see list above) to prove that it covers all relevant areas and that any information extracted from it for the forms is accurate.
We all know what’s going to happen in practice and what the consequences of that will be. Errors and omissions will still filter through but at fault for any resulting incidents will now be the Conveniently Overburdened Safety Scapegoat who signed to endorse his pack. As ever, the development of these changes has been masterminded by self-serving desk-jockeys who are only comfortable with ‘process’. Beyond their comprehension are the practical implications. Those at the front line must hope that some benefits are found amongst the wreckage.
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