Phil Hibberd, a committee member of the Institution of Occupational Safety and Health’s Railway Group and Engagement Manager at the Rail Safety and Standards Board, explores how safety is managed…
‘Freight operators are competing to provide a seven-day accessible freight network, and striving towards the achievement of 24-hour operation, against a backdrop of network capability constraints. All of this has implications for risk, a risk tackled by the National Freight Safety Group.’
This recognition of rail freight and its risks was included in the Annual Health and Safety Report 2018-19, produced by the Rail Safety and Standards Board. So, what do the figures show us? In 2018-19, there was one fatality to a member of the public involving a freight train. Forty-two per cent of all ‘potentially higher risk train accidents’ involved freight trains, most low-speed derailments. There has been a decline in the number of freight trains passing signals at danger. Most freight train derailments are not RIDDOR-reportable and occur in yards, depots and sidings.
National Freight Safety Group
How is safety managed? Many within the rail industry people believe the National Freight Safety Group (NFSG) was established before any other cross-industry freight group. However, this is incorrect, as the rail freight sector is sufficiently compact and, following privatisation, the Professional Heads of Operations from each of the freight companies continued to engage and share best practice through the Rail Freight Operators Group (RFOG). And that’s probably down to them all having once worked together under the banner of British Rail.
RFOG was properly established around 2006, when the operators identified the need to formalise their regular ‘catch-ups’. Following the serious near miss at Carstairs in December 2009, where a freight train travelling south on the West Coast Main Line in freezing temperatures and snowy conditions, passed two red signals in succession. RAIB’s report into the incident identified that poor train braking performance, caused by the freezing conditions, impacted on the braking equipment (in fact the train’s disc brakes were effectively aquaplaning on the wheels).
Shortly after, in January 2010, in similarly freezing temperatures and snowy conditions, the front portion of a freight train travelling from Inverness towards Perth on the Highland Main Line came off at Carrbridge station. The derailed portion of the train came to rest on an embankment, close to some houses. The driver and technician on board suffered minor injuries. Damage was caused to private property, to the derailed train and the rail infrastructure. RAIB’s investigation identified a combination of factors that led to the derailment. These included:
• snow and ice ingress reducing the effectiveness of the train’s brakes
• the way the driver of the train applied the rules for operating trains in snowy conditions on steep climbing gradients
• the train ploughing into and/or disturbing lying snow during the journey from Inverness to Carrbridge
• the presence of deep lying snow close to the line.
Code of practice
It was these incidents which led to RFOG developing and implementing its first freight approved code of practice (ACOP) to address the risks associated with operating freight trains during severe winter working. The collaboration with RFOG members was noted by industry leaders. Other industry groups were also undertaking similar work, the Infrastructure Safety Leadership Group (ISLG) being one of those.
As a result, heads of safety started to engage and share best practice. A great of example of this collaboration was demonstrated at Network Rail’s Westwood site when all freight operators made the collaborative decision that, in order to reduce and mitigate the risk of collisions within engineering worksites and possessions, they should amend their own supplementary operating instructions to mandate maximum speeds of 5mph in a worksite and 15mph in the possessions. This led to Network Rail making some significant adjustments in its planning processes. This freight safety mitigation, introduced during 2016, has seen that no further collisions have occurred.
At this point, the RSSB Board commissioned a project to review and improve arrangements for industry cooperation under the Modernisation of Safety Cooperation (MOSC) project. The purpose was to modernise the industry approach to safety cooperation with the objective of making it ‘fit for purpose’ to meet the current and future needs of all industry stakeholders. The MOSC framework gave the rail industry the ability to demonstrate collaborative working, which supported its duty to cooperate under ROGS Regulation 22. The rationalisation of the plethora of meetings at the time, allowed for a more structured approached to be taken in managing cross-industry risk, through the creation of System Safety Risk Group (SSRG) and its expert subordinate groups, providing ‘line of sight’ from national to local level.
Soon after, the Head of Safety of the then EWS Railways (now DB Cargo UK) got together with the Chair of ISLG to discuss how the freight sector could establish a new group, focusing not only on rail operations, but also more generic health and safety matters. A working group was formed by all the freight operating companies and with the support of the RSSB, the National Freight Safety Group (NFSG) was formed.
The NFSG was established as a national level operator group, to enable the FOCs to identify and implement arrangements to address their ‘duties of cooperation’ across both the mainline and non-mainline rail networks and use this as a framework to reduce operational risk in the freight sector. The Chair of NFSG reports into the SSRG to provide and maintain an interface and to ensure that the contribution of freight operating risk towards overall system safety is being suitably addressed.
In line with the industry strategy, Leading Health and Safety on Britain’s Railways, the NFSG developed an ‘Integrated Plan for Freight Safety’ with the involvement of all its members, and assisted by RSSB, to:
• identify and maintain a ‘common to all’ top ten risk profile associated with freight operations and their interfaces with infrastructure managers and other transport operators
• develop suitable practical risk control measures to address identified risks in a consistent way, leading to continuous improvement of safety performance and management arrangements
• develop a suite of performance indicators to allow continued measurement of positive/adverse trends in safety performance
• develop a precursor indicator model specific to freight operations
• establish arrangements for learning from operational events across the UK, European and worldwide rail industries.
The original ‘Integrated Plan for Freight Safety’ was published in 2016 and had 16 key actions for the group to focus on, however it didn’t take long for the group to realise that whilst trying to collaborate and work on 16 projects, they also had to provide support and guidance to their businesses. As a result, a number of projects started to slip. A major challenge came from a lack of visibility, understanding and support from senior leaders within the FOCs, as there was no clear governance structure to the RDG Freight Board, with each MD/CEO having their own views of what health and safety excellence looked like. They didn’t always align.
A change at the board
In 2017, the decision was reached to review the integrated plan and reduce the number of projects to a more realistic level. At the same time, the RSSB Board appointed Geoff Spencer as its Non-Executive Director for Freight and Dougie Hill of Direct Rail Services was appointed the new Chair of the NFSG. These two gentlemen demonstrated a real energy, enthusiasm and belief that the NFSG can truly deliver a safer better railway and the freight journey began.
Within a matter of months, the NFSG had established a Steering Group, chaired by Geoff, who created a clear governance link to the RDG Freight Board. The MDs and CEOs were at last collectively discussing the challenges around freight safety, allowing a charter to be established and signed by all board members.
The objective of the charter was to demonstrate their joint commitment to improving health and safety in line with the national strategy, whilst agreeing not to use safety as a ‘bargaining chip’ when tendering for business, all agreed that best practice must be shared and that only with a true collaborative approach can the industry drive continuous improvement in health and safety. Adopting such an approach is aimed at promoting the movement of freight from road to rail with a firm basis in safety, performance and sustainability.
Version two the current ‘Integrated Plan for Freight Safety’ now focuses on five key areas of risk:
• freight derailments
• road risk
• site security
• common safe systems of work.
Each risk project has an appointed Sponsor and Project Manager and a standardised framework of reporting has been developed with the support of Network Rail’s Operations and Safety Manager for Freight and National Passenger Operators, Pete Williams, another driving force at the NFSG.
With a new governance structure in place RFOG has now become a ‘doing’ group for the NFSG and recent work has seen the publication of ‘Bulk Loading ACOP’ created with the support of the construction industry. Work is now underway to reintroduce Working Manual For Rail Staff (old Green Pages) to bring Loading Standards consistency into the sector and under the banner of NFSG.
A clear collaboration framework has been established which can be seen in the diagram below. This interface established risk groups facilitated by the RSSB, with sub-working groups of the NFSG. This framework and commitment of all involved has seen a significant step change in the pace at which the NFSG now works.
The future of rail freight safety continues to be monitored by the NFSG in a mature and collaborative manner with a willingness from all freight operators to share best practice and learning from operational experience, however continuous improvement identifies the need for greater speed in delivery and greater capacity if we are to truly fulfil our potential.
Phil Hibberd is a committee member of the Institution of Occupational Safety and Health’s Railway Group and Engagement Manager at the Rail Safety and Standards Board