New Approach to the Rule Book

Introduction

Under the leadership of RSSB the industry is embarking on an ambitious project to transform the content and presentation of the rules currently published in the Rule Book (GE/RT8000). The project is entitled the “New Approach” and the programme to systematically review and revise all modules that make up the current version of the Rule Book is scheduled to take four years.

Background

Rules have been used to help control operational risk on the railway for over 170 years. During this time the rules have evolved gradually as we have learned lessons from accidents and our understanding of risk has developed. The “New Approach” represents the next major evolution in the history of the Rule Book and is the biggest comprehensive review of the rules since the current Modular Rule Book was introduced in 2003.

The Current Rule Book

The current Modular Rule Book was the culmination of a six year project to make the Rule Book easier to navigate and the rules more accessible. This involved a complete rewrite of the 13 Personalised Rule Books and significant changes to structure, format and language as follows:

• The rules are now written in the 2nd rather than 3rd person form
• Use of responsibility indicators to clearly identify which roles are responsible for carrying out which rules.
• Use of  less colour to improve the effectiveness of colour as a means of highlighting key points
• Greater use of diagrams to illustrate how certain rules are applied
• Use of a language style that meets Plain English campaign requirements
• Use of human factors experts from the Occupational Psychology Centre to trial the changes.

Why Change?

Although the current Modular Rule Book improved upon its predecessor our experience of using it has highlighted opportunities for improving the document and a need for our rules to align more closely with the many technological and organisational changes the industry has experienced since its introduction.  

The “New Approach” has been established to tackle these issues which are reflected in the following comments expressed by a range of people in the industry:

• “the rules no longer let you think”
• “the rules are too complicated”
• “the rules are not suitable for today’s railway”
• “the volume of instructions issued exceeds what the
   average person can mentally retain”
• “the rules are becoming encrusted with bullet points”
• “the rules do not clearly explain the inter-relationship between the arrangements and roles defined in the different modules”
• “there are now too many rules”………….

Aims

The primary purpose of the New Approach is to review and revise the current Modular Rule Book with the aim of significantly rationalising its content and restructuring the document so that it is more accurately targeted at the skill sets of end users and clearly aligned with operational principles.

The objectives of rationalisation and restructuring are to:

• reduce rules based errors, violations and misapplication;

• enable end users to exercise greater judgement and discretion in resolving operational issues

• reduce the need for and the costs of future rules changes; and

• support industry goals for competence management and performance improvement.

End User Engagement

The project is also taking a “New Approach” to the way in which it engages stakeholders to participate in the development of rules. In a significant departure from previous major Rule Book change projects it is intended that end users of the rules should have an opportunity to contribute to the creation of revised rules and rules based processes before final drafts are circulated for general stakeholder consultation.

This engagement process will primarily take the form of a series of end user workshops arranged at various locations around the country where sample groups of end users will get the chance to see rules at an early stage in their development. At these workshops end users will be invited to express their views about which features of the “New Approach” they find helpful, which elements are difficult to understand or unhelpful, and which aspects of the current Modular Rule Book they would wish to see discarded or perpetuated. 

The primary purpose behind engaging end users in this way, and at a much earlier stage than would normally be the case, is to validate whether the first products of the “New Approach” are consistent with its stated principles from an end user perspective. It is also recognised that traditional stakeholder consultation methods do not always reliably engage end users due to constraints of time and limitations in the consultation cascade within duty holder organisations.

What’s New?

The New Approach will provide:

• Targeted publications related to skill sets.
  • Recognising that there are different audiences for the rules.
  • Rules contained in a mix of modules, handbooks and procedures to make the Rule Book more portable for those working in an outdoor environment.

• Rationalisation
  • A significant reduction in the quantity of rules by removing those rules that are legislative requirements, have no national application, are company specific, are training/guidance material, or are unnecessarily duplicated.
  • Remaining rules to be clear, concise and precise
  • Future rules will address key interfaces between end users and will be contained in fewer separate publications to make the rules for a particular role easier to navigate, learn, remember and refer to when undertaking operational safety tasks.

• A clear link between rules and principles.
  • A proposed rule is only included if it is needed to deliver the operational principles.
  • A future rule will need to be agreed as essential to system safety.

Programme Content

All modules of the current Rule Book have been divided into 12 tranches:

• Tranche 1 Basic competencies for going on the railway (G1, G2, T5, T6, T8)
• Tranche 2 Setting up safe systems of work (T2, T7, T10, T12)
• Tranche 3 Possessions and control of rail movements (T3, T4, T9, T11, OTP, OTM)
• Tranche 4 People who work or go on electrified lines (AC, DC)
• Tranche 5 Level crossings - signallers, train drivers and crossing attendants (TS9, TW8)
• Tranche 6 Signallers, train crew and others involved in emergency train working (P1, P2, TW7, M1, M2, M4, M5)
• Tranche 7 General signalling, track circuit block and absolute block regulations (TS1, TS2, TS3)
• Tranche 8 Working single lines (TS4, TS5, TS7, TS8)
• Tranche 9 Train working (TW1, TW2, TW3, TW6)
• Tranche 10 Defective trains, shunting and station duties (SS1, SS2, TW5)
• Tranche 11 Signals and indicators (S1, S2, S4, S5, SP)
• Tranche 12 Signalling failures (S3, T1A, T1B)

Link to Tranche disposition statements
Link to Rule Book Briefing Leaflets (RBBLs)

Traffic Operation and Management Standards Committee (TOM SC) have approved work to be undertaken on all 12 Tranches.

Implementation Dates

In response to feedback from the industry when the Modular Rule Book was introduced, with all modules implemented on the same date, we will be adopting a phased introduction of “New Approach” changes as follows:

Tranche	Published	In-force
Tranche 1	April 2010	June 2010
Tranche 2	September 2010	December 2010
Tranche 3	March 2011	June 2011
Tranche 4 & 5	September 2011	December 2011
Tranche 6	March 2012	June 2012
Tranche 7 & 8	September 2012	December 2012
Tranche 9 & 10	March 2013	June 2013
Tranche 11 & 12	September 2013	December 2013

On-site briefings

RSSB, on the acceptance and approval of each tranche by the Traffic, Operations and Management Standards Committee, are offering Heads of Training, Training Managers and Operational personnel responsible for training in all TOCs, FOCs and IMCs the option of an individual on-site briefing. The briefings are specifically to explain the impact that the changes may have on current training programmes and help identify gaps that may be required to be addressed as a result of change.

If you consider that you would benefit from these briefings please contact Roger Luckins, Senior Operations Specialist (Workforce Development) who will contact you and arrange a convenient date.

Project Organisation

Strategic governance of the programme which includes funding authorisation comes under the RSSB Board where industry interests are represented at Chief Executive level from the duty holder organisations who make up the membership of RSSB.

Tactical level governance has been delegated by the RSSB Board to the Traffic Operation and Management (TOM) Standards Committee where industry interests are represented by experienced and senior operational specialists from RSSB member companies. The Board has also created an Industry Leaders Group, with representatives at director level from across the industry, to help make sure that maximum benefit is obtained from the New Approach by providing guidance and constructive challenge to RSSB and TOM SC.

The drafting input & technical expertise is delivered by RSSBs Operations team, with the day to day project management undertaken by the RSSBs Project Delivery department.

The programme is funded from the RSSB budget which is financed by its members in accordance with the RSSB constitution agreement through an annual levy on each member.

To support the programme the project team also includes employees seconded from RSSB member companies to assist RSSB with project development, facilitation, engagement and communication activities.

Post Tranche 1 of the New Approach. Information relating to the Safety Benefit

A review of hazardous events in the RSSB Safety Risk Model (SRM) was undertaken. For each hazardous event, precursors that were controlled all or in part by the Rule Book were identified. For example, fewer rules through targeted handbooks and more competent staff will lead to a reduction in risk. This is also dealt with at ground level industry consultation. Professional judgement was then used to identify how much the New Approach to the Rule Book could affect these precursors. Additional mitigations of consequences, due to Rule Book controls after a hazardous event has occurred, were not estimated. A conservative bias was used in performing the expert judgement for the following reasons:

• There is no basis or precedent upon which to judge how far ‘deficient or sub-optimal presentation of rules’ will affect their correct application, nevertheless, it is intuitive that rules that are clearer, less cluttered and more easily comprehended are more likely to be applied correctly; the question is one of degree.
• Improvements in competence management and the standard of competence provide the more direct value in risk reduction.

All safety impacts were considered, ie a reduction in risk, as a result of clearer rules engendering improved safety performance. It is assumed that where elements of the Rule Book have been removed, because they are either duplicated in legislation, or should be part of company training material or instruction, then these are picked up by companies as appropriate, and there is no decrease in safety performance.

For future tranches work is currently being undertaken to review data to analyse safety and performance evaluation. The work being undertaken as part of the New Approach in order to capture information regarding number of incidents that relate to the following examples:

• Failure to follow rules.
• Failure to follow instructions.
• Ignorance of rules.
• Ignorance of instructions.

The output from the New Approach is assumed to have a safety benefit of 0.245 fatalities and weighted injuries per year (FWI/year), which is broken down as follows:
 

Hazardous event type	Risk benefit (FWI/year)
Train collisions	0.009
Collision with object on line (no derailment)	0.0002
Train collision with road vehicles	0.006
Train derailments	0.056
Workforce struck by train	0.134
Workforce electric shock	0.037
Workforce injury whilst coupling/uncoupling	0.003
Total	0.245

Work on the first tranche of rules has emphasised simplification in order to improve the safety of track workers. In addition, opportunities have been identified that have the potential to facilitate efficiencies and remove barriers to achieving performance benefits. For example, Tranche 1 has resulted in a proposal to reduce the number of situations in which a handsignaller is appointed from four to two.

New Approach project Frequently Asked Questions (FAQ)

RSSB have been developed some project FAQs and these can be viewed on the New Approach to the Rule Book (FAQs) page of the website.

RSSB undertakes industry consultation via the Consultation and Stakeholder Register. Details of consultation for the New Approach (tranche specific) can be found at the following web address: http://www.consultation.rssb.co.uk/. 

Questions about the 'New Approach' to the Rule Book

If you have a question related to the New Approach to the Rule Book, you should contact the RSSB enquiry desk who will deal with your enquiry in liaison with Operations Specialists within the Traffic Operation and Management Delivery Unit. The RSSB enquiry desk can be contacted on 020 3142 5400 or enquirydesk@rssb.co.uk.