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While it may appear that the Transport Agency is reviewing and approving the technical elements of the change itself, it’s actually that you have followed and applied good risk and change management process to the activity and to update/variation to your organisation’s safety case that is being assessed.

Section 33 (3) of the Railways Act(external link) states:

‘The proposed variation must be considered by the Agency as if the licence holder were proposing a new safety case, and section 31 applies as if it were a fresh application for approval.’

Can changes be tested before a safety case variation is approved?

In some change processes there is a period where rail activities are changed, but in a limited way – such as testing new rail vehicles before you start running regular operations. An approach we encourage in these types of scenarios is to split the variations into phases.

By requesting an initial safety case variation (eg to test a new rail vehicle in a controlled environment), you can perform your risk assessment and management processes without having to factor in the entirety of the change. This allows us to approve the variation and for you to commence the testing.

When the testing is complete you can then perform your risk assessment and management processes for bringing the rail vehicles into service – and submit another application for a safety case variation that covers this aspect.

What if a change is large and/or time consuming?

Engaging with the Transport Agency as early as possible regarding change is beneficial for all involved. This can be as simple as talking it through with your licence manager. Addressing risks at the design stage rather than at implementation is crucial for effective risk management.

When progressing with your change process, we can work with you to ensure you’re managing the change and assessing the risks in a robust manner. By doing this before any actual railway activity is affected, it will make the subsequent application for a safety case variation a much smoother and faster process.

The key elements of managing change

When submitting an application for a safety case variation, it’s important that you show you’re adequately managing the change and its effect on your organisation’s risks. This is why the additional documentation is required.

Some of the elements that may help manage your change process are outlined below.

The key elements of managing change

A plan of what is required

A people plan. Who is reponsible for what?

A quality assurance plan. How to confrm things are being done correctly

Consultation and communication

Suitable and sufficient risk assessment

Issues log of concerns and issues

Documentation of decision

A training plan

Training and competency needs identified and met

Checking deliver of planned package
Monitor the effects of change
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