Rail Industry Focus

Risk management for railway engineering

RTM talks to Ben Shirley, health and safety risk specialist at the ORR, about the importance of risk management on Great Britain’s railways.

Keeping risk ‘as low as reasonably practicable’ (ALARP) is an essential part of mechanical engineering across all major industries, the Institution of Mechanical Engineers (IMechE) stated at its recent conference on risk management. 

However, Ben Shirley, who gave a presentation at the event, was keen to stress that the ORR uses ‘so far as is reasonable practicable’ (SFAIRP) rather than ALARP principles because, ultimately, “that is what duty holders will be judged on, if ever a case does go to prosecution”. 

“From our point of view, we are quite keen on this. Health and Safety Executive (HSE) made the statement on their website that they consider SFAIRP and ALARP to be interchangeable; however, that is heavily caveated by the fact that they expect duty holders to use SFAIRP in any of their legal documents. 

“It is quite key to make that point. SFAIRP is what is required for the rail industry.” 

During his presentation, Shirley reiterated that the rail industry has a history of good safety performance, and, as has been well publicised, “we are perceived to be the safest railway in Europe”. 

Shirley added that it is important organisations realise that risk management is very important for the ORR: “Not only do we require duty holders to continuously improve, but against this backdrop of very good safety performance, we need to make sure that we are continually looking for any emerging risks or risks that we are currently managing in the industry that might change.” 

In a recent ORR document, ‘Assessing whether risks on Britain’s railways have been reduced SFAIRP’, the regulator stated that duty holders must make a suitable and sufficient assessment of risks and, where considering duties constrained by SFAIRP, must compare the cost of implementing risk control measures (in terms of money, time and effort) against the reduction in risk those measures might achieve, and whether there is a gross disproportion between them — such that the costs grossly outweigh the risk reduction. 

While not discussing gross disproportion in great detail, Shirley was keen to highlight to the IMechE audience that in terms of risk management the railways are in a “good position”. 

This, noted Shirley, is because “we have a wide range of intelligence, and we have the RSSB, as an industry body, who does a lot of good work in terms of risk management, guidance and principles. They also manage the Rule Book”. 

“Our duty holders do have a lot of information, guidance and intelligence that can help them make risk-based decisions,” he stated. “Likewise, HSE produces a lot of general guidance that can be used by the railway and then we supplement that from the ORR’s perspective and the RSSB. 

“We also have a whole suite of documents which are strategic risk chapters that are also published on our external site. That is a suite of chapters on not just principle risk areas, like level crossings and rolling stock, but we also look at enablers like safety management systems and organisational culture – these things that all have an impact on an organisation’s ability to manage railway risk. 

“We are constantly reviewing and revising them on a staggered basis, so no chapter remains out of date for too long.” 

Discussing the changing nature of the railway for duty holders, and the move to devolved routes, Shirley stated that the ORR will be looking into this issue. 

“Those sorts of activities need to be looked at on a case-by-case basis,” he said. “And likewise, the regulation required will have to follow a bespoke systems approach to determine the risks associated with that.”

For More Information

To learn more about risk management principles on Great Britain’s railways, Ben Shirley has recommended the following reading:

• Reducing Risks Protecting People (R2P2) – HSE
• Taking Safe Decisions (TSD) – RSSB
• HSE online CBA guidance – www.hse.gov.uk/risk/theory/alarpcheck.htm
• Engineering Safety Management (‘The Yellow Book’) – RSSB
• Risk Management Maturity Model (RM3) – ORR