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Safety controls are the systems and processes that mitigate the risks involved with your rail activity, and your safety case has to show that the ones you have in place meet the requirements for railway participants in Section 7 of the Railways Act 2005(external link).

Choosing safety controls  [s30(1)(d)]

Your approach for choosing the right safety controls should encourage exploring many options with a fair consideration of how they may or may not work, rather than simply opting for the most familiar option. Your safety case needs to describe your selection method and show that consideration was given to:

  • all of the possible options
  • what is considered best practice or consistent with respected standards
  • whether you’re making a safe place or solely relying on safe people, and
  • whether you’re managing the risk so far as is reasonably practicable.

Note: Refer to Section 5 of the Railways Act 2005(external link) for the meaning of reasonably practicable.

Your safety case should also show that these decisions are being made by those who have the authority to make them happen. Some decisions can be made at lower levels, but the board should be considering things that require buy-in from across the organisation or significant budget.

Critical safety controls

There are some safety controls that are required by all rail operations, so you must have them as part of your safety system and demonstrate in your safety case that that you can operate them well. These controls are listed below.

When describing these controls in your safety case, focus less on how you carry them out and more on the type of risks they will address and how well they will address them. Doing it this way helps your front-line team understand the importance of the controls and how they directly contribute to safety.

Team member fitness for duty  [s30(1)(k)]

For those of your team with safety critical roles you need to show how you can be certain they are not impaired in any way - particularly by fatigue, illegal drugs, prescription drugs or alcohol.

Interoperability  [s30(1)(f)], [s30(1)(j)]

If your rail activity interacts with other rail participants, especially on-track, managing safety in this area is known as ‘interoperability’. Where this exists, your safety case should show that all parties agree on the system of controls and there are no gaps in practice, which includes showing:

  • there is open and constructive talking between the organisations on how to stay safe
  • concerns and problems are rapidly identified and addressed
  • you are clear where your activities overlap and where they don’t, and
  • you are clear what risks are affected by each other’s activities  and how ownership will be shared.

If you operate on the National Rail System (NRS), you must demonstrate how participation in the committees and following the NRS standards will help you achieve your safety goals.

Asset management  [s30(1)(g)]

The condition of your rail assets is critical to maintaining safety. When they don’t operate as intended, it can result in a person getting seriously hurt. Your safety case should show how you’re aware of the condition of your assets and their operational needs.

Emergency management  [s30(1)(l)]

Despite your best plans, things may go wrong at some point. Emergency management makes sure a bad situation doesn’t get worse. The three objectives of emergency management are to:

  • recognise quickly that things are going wrong (or are likely to)
  • understand the emergency well enough to react, and
  • react accordingly to prevent further harm.

You should describe how you will develop and maintain emergency plans that are effective and are understood by the people who may need to use them.

Document control  [s30(1)(g)]

Keeping your documentation (including practices and procedures) well managed and maintained is a big part of ensuring safety in the workplace. As well as staff knowing they can easily access it and are looking at the most up to date version of what they need to know, it also helps those in governance positions know they are meeting their legal obligations.

Your safety case should demonstrate that:

  • you know the important information you hold and who’s responsible for it
  • you can protect that information from being damaged, lost or corrupted
  • people are able to access the right documents for their needs, and
  • you know when documentation changes, who has changed it and why.

Change management  [s30(1)(l)]

When something changes in your organisation it must be managed well, as unexpected risks may arise and people could be exposed to harm. A strong and integrated change management process is a must-have for any rail operation and your safety case should show:

  • how well the process is/will be integrated into the business
  • the value to risk management it provides, and
  • that it adjusts to the scale and importance of a change.

Documents that may help you develop this section

  • Your safety control selection method
  • Examples of how you have applied the method to mitigate risks
  • Your policies and procedures for the critical safety controls
  • Joint operating procedures with those you interact with
  • Approval from the NRS access provider if you are choosing to operate on the National Rail System
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