Research Brief High level safety management system guidance and good practice T847 - September 2011 Background The Railways and Other Guided Transport (Safety) Regulations (ROGS) 2006 have led to a greater emphasis on the need for safety management systems (SMS) of GB rail organisations to at least maintain current levels of safety, albeit with less prescriptive requirements. To embrace fully the potential of this change, and to inform thinking about SMS at a European level, the GB rail industry Safety Policy Group (SPG) requested this project to support efforts to further develop the SMSs of GB rail organisations. At a simple level an SMS can be considered to be the totality of an organisation's arrangements for managing, assuring, and improving safety. As ROGS guidance puts it: 'the safety management system is the basis for making sure a transport system runs safely and in line with ROGS'. However, major accidents in many different industries and various parts of the world have occurred where an SMS was present but apparently ineffective. Understanding the underlying factors that contribute to an effective SMS is therefore regarded as a key contribution to the continuous improvement of SMSs in the GB rail industry. Furthermore, it is considered that infrastructure maintainers and transport undertakings elsewhere in Europe, that have not had an SMS previously, may find it useful to see the benefits of a nonprescriptive SMS clearly set out, which this research aims to do. Aims The objectives of the study were to: • Support the continuous improvement of SMS development in the GB rail industry through the development of informed, high level, non-prescriptive guidance and good practice. • Inform and influence European SMS developments. RSSB R&D Programme Block 2 Angel Square 1 Torrens Street London EC1V 1NY enquirydesk@rssb.co.uk www.rssb.co.uk/research/pages/ default.aspx 1 High level safety management system guidance and good practice T847 - September 2011 Findings In summary, the findings from the study demonstrated that: • GB rail organisations are comfortable with their interpretation of the legal requirements associated with an SMS. • Information is available to improve understanding about the development and application of an SMS. • There is good information available to improve the effectiveness of the SMS in practice. The study visits presented a picture of rail organisations that are becoming familiar with dealing with the concept and application of an SMS, albeit to differing degrees of depth. Aside from organisational and personal experience, the main area of SMS knowledge came from the use of documents such as Health and Safety Guidance 65 'Successful health and safety management' (HSG65) and British Standard 'Occupational Health and Safety Management Standard' OHSAS 18001. Organisational standards and procedures were seen as playing a large role within the rail SMS. It was not known from the study visits whether these internal company standards and procedures changed post ROGS or whether they have remained for the most part the same as they were in the earlier safety case regime. Certainly some respondents regarded the SMS as having evolved from the safety case with little change. SMS structures as well as standards and procedures appeared to provide a rigidity to rail SMSs that may have accounted for the continued good performance of safety within the rail industry to date but perhaps also accounted for a desire not to move beyond generalised SMS guidance documents. From the visits to other industries the various uses of SMSs presented no clear, single best practice way to manage the SMS, although there were many good practices within each of the industries studied. This is thought to be because safety has been aligned to management practices and that there is no one successful way to manage an organisation. Generally other industries were seen as attempting to progress SMSs in similar ways to the rail industry, such as in better understanding of safety culture. It was also identified that they were experiencing similar issues with getting the organisation to 'live' the SMS instead of just complying with safety requirements on paper. Major findings from the in-depth review and comparison of key SMS texts identified that: 2 RSSB • Good information is spread across a number of documents and could usefully be drawn together into one resource. • Key information is missing from some of the texts or is replaced by bullet points. • There were some gaps in the SMS components covered within the guidance information. As a body of information, the various guidance documents were seen to bring together areas of good and advanced safety advice. Whilst the various guidance documents contained some useful information, there was not one consistent message that all adhered to but rather a number of individual messages that could be useful if taken into consideration when working on a particular component of the SMS. The documents reviewed often offered generic checklist guidance which could assist with achieving legal compliance or gaining certified accreditation but provided little supporting information to develop or embed leadership and a positive culture, or to facilitate continuous improvement. Many guidance documents contained little information to help readers understand the reasons why particular good practice should be followed. Each of the guidance documents reviewed contained a set of definitions. Very few of them agreed completely about the definitions and some of the documents actually disagreed as to meanings. Therefore there is currently little clarity as to how a set of definitions regarding SMSs should be developed. As greater responsibility has been placed on the organisational SMS following the implementation of ROGS, it could be viewed that within the internal organisation, and during external cooperation, the need for assurance in the understanding of SMS definitions had increased. The review of accident investigation reports highlighted common SMS faults and potential gaps or weaknesses in current SMS guidance. From the 22 SMS-related topics identified through the accident reviews, seven of them were common to five or more of the accident investigations, and were therefore highlighted to be of particular interest. These were: safety assurance, learning lessons from operational experience, training and competence, safety culture, skill and staff shortages, change management, and risk management. The findings suggested that there is a strong culture of compliance within the rail industry regarding an SMS but that there are still difficulties in making the SMS dynamic and relevant RSSB 3 High level safety management system guidance and good practice T847 - September 2011 to everybody within an organisation. The findings highlighted that a more effective SMS may be delivered by developing a better understanding of management systems. This would lead to refinement of the SMS purpose, the methods of effective management systems and the SMS structure. Deliverables Deliverables from this research include: • A research report (and associated appendices) that clearly sets out the study undertaken and demonstrates the basis for decisions taken to produce the guidance document. • An SMS guidance document to help railway organisations further develop their SMS and increase its effectiveness in practice. The guidance is set out in four sections. The deliverables are available via the RSSB website and enquiry desk at enquirydesk@rssb.co.uk Method The method for carrying out this research consisted of a literature review, study visits, workshops, and stakeholder visits assisted by input from an industry steering group. The review of SMS related literature identified 135 SMS and SMS related documents through internet and journal searches, advice from professionals, and references within other documents. For the major SMS guidance documents identified, a question set was developed to evaluate the strengths and weaknesses of each document and to assist comparisons made between them. The SMSs were also analysed to identify frameworks and models, thus enabling a comparison to be made of the types of models used. Analysis of the literature associated with a number of serious accidents identified major organisational safety failings. Emerging themes from the review of SMS texts focused further literature searches and reviews on particular SMS components. For the study visits, industry perspectives were obtained from safety professionals across the breadth of RSSB membership. To elicit information, an extensive open-ended questionnaire was developed. The planned study visits were initially piloted with two steering group partners and then meetings were set up with a range of partners, totalling 18 rail industry organisations. The questionnaires were completed on a one-to-one basis and responses were written by the interviewers and then repeated back to the respondent. External professional opinion was also sought by identifying industries with comparable safety risks to the rail industry, such as nuclear, aviation, chemical and shipping. 4 RSSB Eight organisations were engaged to develop an external perception of SMS use. The questionnaire developed for the internal study visits was used as part of a semi-structured interview. Following the development of an interim report based on the research findings and acceptance of this report by the steering group, a number of options for developing guidance for the rail industry were put forward. The development of guidance focused on the creation of a skeleton document, setting out the main sections and SMS themes to be included, which was agreed by the steering group and safety professionals within the rail industry at regional workshops. Next Steps SPG encourages duty holders to review this research and consider whether they need to take action to improve and develop their SMS and/or its application. They suggest that this research is read alongside The application of leading and lagging indicators to the rail industry (T852) and the guidance document Measuring safety performance. Furthermore, SPG and the project steering group have asked that the SMS guidance be placed on the RSSB website alongside other SMS material. Contact For more information please contact: Michael Woods Head of Operations and Management Research R&D Programme RSSB enquirydesk@rssb.co.uk RSSB 5 High level safety management system guidance and good practice T847 - September 2011 6 RSSB