Consultation comments received on Rule Book module
GE/RT8000/TW1
Preparation and movement of trains - general
Closing date 26 January 2007
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Summary of Responses from Railway Organisations
Consulted:
Number consulted
183
Number ticking "yes"
16
Number ticking "yes with
7
amendments"
Number ticking "no"
2
Number ticking "nil return"
8
Total returned
33
Date responses returned to
15/02/07
organisations
Mr H Bridges Head of Safety, London Lines for, c2c Rail and Silverlink Train Services
Mr B Cook, Head of Operational Standards, South West Trains
Mr Keith Norman, General Secretary, ASLEF
Mr M Drew, Central Safety Assurance, Alstom Transport UK
Mr N Green. Professional Head of Engineering, Works Infrastructure Ltd
Mr J Chilton, Head of UK Operations, Eurostar UK Limited
Mr P Charlton, Operations Standards & Development, Jarvis Rail
Mr J Samways, Operations Standards Development Specialist, Network Rail
Mr Simon Groves, Safety Assurance Manager, Arriva Trains Wales
Classification Code: (CC)
DC Document changed
NC No change
Consultation
No Page Section
General
1
Revised
Page Section
CONSULTATION RESPONSES REVISED 10 MAY 2005
Comment
By
Following further consideration of the industry proposals arising 1
from the studies undertaken by the Train Horns Steering
Group, London Lines (representing c2c and Silverlink) would
like to support the recommendations included within the recent
RSSB led consultation on this subject.
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CC Response
NC
Thank You
Consultation
No Page Section
Briefing
2
Revised
Page Section
Comment
By
CC Response
Briefing notes are intended to give adequate information about
changes and the reasoning behind them, but I feel that this one
is over-long in terms of background. The end user is less likely
to read the key points of a long note and, whilst the whole
process for change is factually depicted, it could be
summarised in far shorter space thus giving the note more
impact.
There is a statement in this clause which is incorrect and
should be amended. Not all trains have Day/Night headlights.
Clarification required: the comment regarding a night time ban
– is this aimed at road users, train use or horn use?
“You may disregard a blue and white chequered flag” – this
implies a decision is to be made, Should this state “You should
disregard…” where it does not apply to you?
8
NC
The purpose of this briefing note was to provide
background (including to readers who do not work
in the rail industry) for a significant change in
industry practice. It will not be the document which
will be made available to support briefing of railway
staff, which will be shorter and simpler.
7
DC
7
NC
Agreed, thank you. Change made to Impact
Assessment (‘many’ trains)
Horn use – see proposed wording of the rule.
4
NC
8
42, 43 10.2b), c) Three different words are used for occasions when there is a
human presence on or near the line (“people”, “personnel” and
“anyone”). For consistency and to clarify that in all cases the
requirement to act applies to any number (including one), I
suggest standardisation to “anyone”.
Thus in the table in b) “people” would become “anyone who is”,
in the heading to c) “Personnel” would become “When anyone
is”, and in c) Whistle boards “personnel are” would become
“anyone is”.
DC
Note
3
4
5
6
4
IA
5
IA
42
42,
43
5.3.9
5.5.2
10.1
10.2b), c)
4
IA
5.3.9
This clause is outside the scope of this consultation
and is not affected by the proposed change. A
blue and white chequered flag, used by a lookout,
will never apply to a train driver, only to track
workers.
Agreed, thank you. Changes have been made
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Consultation
No Page Section
42,
10.2b), c)
7
Revised
Page Section
43
8
42,43 10.2b), c)
9
43
10.2c)
43
10.2c)
Comment
By
CC Response
We believe that the night-time quiet period should end at 06.00
not 07.00. It is our view that the majority of people are either
already up at this time of morning or at least awake.
We disagree with the use only the low tone at whistle boards.
The use of a two- tone horn allows for people with “tone
deafness” to still be warned of an approaching train.
9
NC
Support general principle of a night time ban. Would like to
ask two questions. Why move start time from 23.30 to
23.00? This is a period when clients of public houses are
likely to leave, and then take short cuts across footpath
crossings.
Secondly, the use of the low tone may not be possible. This is
because the fitment can vary from cab to cab. Would need to
have every cab horn control clearly labelled. When a lower
standard comes in, and assuming train operators lower the
noise levels on existing units, will become less of a problem.
3
NC
Whistles Boards
Change the last line of paragraph from “When personnel are on or near the line” to read “When anyone is on or near the line”. This keeps wording
standard with other sections of the same rule and could in its
current wording be mistaken as only applying to railway
employees.
2
DC
The timing of the quiet period was considered
carefully, including in the assessment carried out
for the Industry Steering Group by AD Little. To
shorten the period in the way suggested would
erode a disproportionate amount of the benefits
(from reduced sleep deprivation). The finishing
time corresponds with existing rules for whistle
boards at automatic and open level crossings, and
for road users generally, set out in the Highway
Code.
The single low tone is perceived as less aurally
intrusive than the high tone. People with tone
deafness cannot identify different musical notes
accurately, not that they cannot hear the horn. The
level of sound provided will never be heard by all of
the population and has to be set at a level that is
reasonable, given the circumstances
Thank you for the support. The timing of the quiet
period was considered carefully, including in the
assessment carried out for the Industry Steering
Group by AD Little. To change the start time in the
way suggested would erode a disproportionate
amount of the benefits (from reduced sleep
deprivation). In recognition of the point you make
about usage of footpath crossings, Network Rail
will be conducting a prioritised risk based review of
the need for alternative controls
It is accepted that not all trains have the facility for
separate sounding of high and low tones, hence
the caveat in the proposed rule.
Agreed, thank you. Changes have been made.
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Consultation
No Page Section
10.2c)
10 43
11
43
10.2c)
12
43
10.2c)
13
43
10.2c)
14
43
10.2c)
15
43
10.2c)
Revised
Page Section
43
43
10.2c)
10.2c)
Comment
By
CC Response
“Whistle Boards”
5
It is suggested that the restriction on the use of the horn at
Whistle Boards between 2300 and 0700 is added to the table
on page 42.
“Train Movements”
5
It is suggested that the tone and setting should be added to the
table on page 42.
DC
Agreed, thank you. Changes have been made but
the rewording will be ‘when passing a whistle
board between 07.00 and 23.00’.
NC
“Tunnels”
It is assumed that the tone and setting is the same as for
“people on or near a running line”. It is suggested that this is
clarified and added to the table on page 42.
“Other Purpose”
It is suggested that the tone and setting should be specified
and added to the table on page 42. Unless this is “local or
special code” – if it is, is not clear.
I do not believe changing the time to 07.00 has been fully
justified. I believe it is too late, there are numerous locations
where crossings will be used prior to this time and I do not
believe that the risks and potential consequences of this
change have been adequately addressed.
5
NC
5
NC
6
NC
Outside the scope of this consultation: a separate
change proposal has been made to review all
remaining rules requiring train horns to be used.
Any revisions will be consulted on when drafted.
Outside the scope of this consultation. Rules
relating to use of the train horn near tunnels were
changed in 2004 and there has been no request
for a further change.
Outside the scope of this consultation: a separate
change proposal has been made to review all
remaining rules requiring train horns to be used.
Any revisions will be consulted on when drafted.
As set out in other answers, The timing of the quiet
period was considered carefully, including in the
assessment carried out for the Industry Steering
Group by AD Little. To change the start time to an
earlier hour would erode a disproportionate amount
of the benefits (from reduced sleep deprivation).
The risks have been considered and also set
against the potential and actual health disbenefits
for railway neighbours from the existing
arrangements. In recognition of the point you
make about usage of footpath crossings, Network
Rail will be conducting a prioritised risk based
review of the need for alternative controls
Section heading “personnel on or near the line”
This heading suggests the instruction is aimed at Railway
Group/Staff Members, but the first line states “anyone on or
near the line”.
I would suggest the title be amended to read “Persons on or
about etc”.
7
DC
Agreed, thank you. Changes have been made.
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