Q. What are the objectives of the New Approach?
A. There are a number of objectives of the New Approach, these are:
· To reduce the number of rules, leaving only those that are actually needed
· To make it easier to change operational practices in future
· To simplify working practices
· To make sure the remaining rules are clear, concise and precise
· To reduce the likelihood of rules-based errors and violations
· To support the transition from a compliance to a competence led culture
Q. How long will the programme last?
A. The transition to the new Rule Book will be fully implemented by December 2013. At the same time, the New Approach has created a new way of working which will continue beyond that date.
Q. How will you reduce the number of rules?
The number of rules will be reduced by removing those rules that:
· are required by law anyway
· have no national application
· are company specific
· belong in training manuals
· are duplicated
Q. Give me an example as to how you have simplified working practises?
A. It was pointed out to us that there were too many ways in the rules for blocking the line for engineering work outside of possessions. Through the New Approach the rules have been rationalised and led to the removal of the artificial distinctions between the former modules T2 and T12. This has already led to more opportunities for safe access to do engineering work which does not affect the safety of the line.
Q. What other areas have been improved by the New Approach?
A. A few examples include:
· The role of handsignallers at defective signals has been withdrawn because of the number of SPADs which resulted from miscommunications.
· We have introduced rules for the use of trolleys inside possessions. This will reduce the likelihood of incidents such as Larkhall (2005) happening again.
· We have clarified the rules to do with working on rail vehicles and emphasised the differences between line protection and vehicle protection as well as clarifying the roles of the Designated Person and the Person Working on Rail Vehicles.
Q. What’s wrong with the current Rule Book?
A. Frankly, it’s too big, has large amounts of material that are not really rules which makes it difficult to identify those rules that really matter. The current Rule Book does not take into account the different needs of the users of the rules. The same subject can be covered in a number of Rule Book modules which makes the rules both difficult to find and more complicated to change.
Q. Why didn’t the last Rule Book review sort this out?
A. The last Rule Book review focused on the format of the Rule Book rather than the content of the rules. The New Approach keeps the use of Plain English and the general format of the Rule Book Modules.
Q. How do you decide what should be in the Rule Book?
A. The industry has agreed an overall operational aim and a set of operational principles which acts as the scope of the Rule Book. If a statement in the current Rule Book isn’t needed to support the operational principles then it isn’t a rule!
Q. Where can I find this operational aim and the set of operational principles?
A. You can find them at the back of both Rule Book Module G1 and Rule Book Handbook 1.
Q. By reducing the size of the Rule Book won’t we lose some important knowledge about how the railway is operated?
A. No, the content that is being removed from the Rule Book usually exists elsewhere anyway, be it in legislation, in training manuals or in company instructions. Each statement in the Rule Book has been subject to a disposition process making it clear where each statement belongs.
Q. How was it decided to implement the New Approach?
A We decided to implement the New Approach in twelve parts or tranches. This has made it possible to group existing related Rule Book Modules together and take a really good look at what the content of the rules should be. By doing this over the twelve tranches it also allows us to control the flow of change making sure that we are not overburdening users of the Rule Book.
Q. What are the costs of the New Approach?
A. There are costs to do with the development, validation and production of new rules as well as the publishing and printing of the Rule Books that RSSB has to pick up. Railway Companies have to pay for the new Rule Book Modules and Handbooks. There are also costs for employers of users of the Rule Book in having to make changes to company documentation (such as the competence management system) and potentially training costs too.
Q. How big an issue will changes to training and competence management systems be for companies?
A. It will be necessary for companies to review their company management systems and training throughout the New Approach process to make sure that any material removed from the Rule Book is adequately covered if it is applicable to the organisation. We expect most of the material removed from the Rule Book will already be either in company instructions or in existing training material. Where there is a need for cooperation to make the railway operate safely this, by definition, will stay in the Rule Book.
Q. What are the business benefits associated with the New Approach?
A. The New Approach will provide some direct benefits such as more efficient training, greater assurance of safety benefit, withdrawal of the AM (amendments module), more efficient printing and publishing and fewer proposals for change.
More importantly it will also enable major business benefits by creating opportunities for the industry to improve the way it operates the railway, including:
· Enabling the rules changes to support the Network Availability Programme (originally known as the 7 day railway). Radical change of Network Rail practices for maintenance and renewal of its assets will provide greater access to the network to run revenue earning train services.
· Streamlining the process of setting up safe systems of work including engineering possessions, and provides for the use of On Track Machines outside of possessions. Supporting the work of the Network Rail Access Programme in their re-design of engineering processes leading to more useful work time and so to fewer possessions and less disruption to train services lowering costs for the industry as a whole. And by improving the access to the infrastructure, Network Rail will be able to introduce maintenance regimes that drive down the rate of asset failure leading to a more reliable network.
· The New Approach includes a systematic assessment technique which will help the industry to challenge the existing model for operating the railway, enabling innovation in operating practices. The industry has already identified a number of areas in which it wants to make this kind of challenge.
Q. How does the Business Case stack up?
A. In broad terms, direct benefits pay for the direct costs over something of the order of ten years, whilst the “big wins” are to be found in much better enabling of operational change starting now and continuing permanently.
Q. There was a big reduction in volume in the first 3 tranches of the new Rule Book, much of which is now in the form of Handbooks. Will it be the same for the remaining tranches?
A. No. We believe there will be significant differences for the remaining tranches with the main distinction being the two different reasons why rules exist:
· There are rules that are required to enforce safe systems of work to keep people safe when they are working on the railway; a lot needed to be taken out of these rules, and Handbooks are a good format for many of these rules.
· Then there are rules that are required to operate the railway. For drivers and signallers who operate the railway, it is more appropriate to retain the use of Rule Book Modules, and the reduction in volume will be less.
Q Are the Handbooks still part of the Rule Book?
A Yes, they are a vital element of the Rule Book. The handbooks are tasked based, pocket sized documents that set out clearly what the rules are for the task being carried out.
Q What about other Handbooks that RSSB produce, are they part of the Rule Book too?
A No, and we are reviewing what we should call these documents: most of which are training aids.
Q. What help is available for industry during the transition phase of the New Approach?
A. In two ways:
· Providing support to Railway Companies by providing disposition statements for all elements of the current Rule Book, and one-to-one briefing about the changes brought about for each Tranche for those companies that require it.
· We have created an Operational Concept that sets out the high level risk controls that can be mapped to each rule, which was approved by the RSSB Board and published in February 2012.