Taking Safe Decisions Worked Example Removal of fire extinguishers use by passengers on trains, previously mandated in Railway Group Standard GM/RT2177 issue 1. Therefore, in subsequent standards there is only the requirement for the provision of on-board emergency equipment which can be directly accessed by staff. Through monitoring of operations, a Railway Undertaking (RU) encounters a spate of incidents of criminal damage to fire extinguishers. Noting that there is no longer a requirement for direct passenger access to emergency equipment on trains, the RU decides to review whether to remove or retain fire extinguishers which can be accessed by passengers on their services. The RU understands that the industry is also experiencing a long-term reduction in the risk from a fire on board a train due to a range of factors such as introducing more flame retardant materials, more efficient removal of rubbish and the regulated public smoking ban. Summary: This worked example describes the removal of a risk control considered to be no longer providing an overall safety benefit. Key learning points: This worked example illustrates: • Removal of a risk control that is no longer providing an overall safety benefit. • Decision based on expert judgement and qualitative assessment. 2. Analysing and selecting options 1. Origin of review Following an impact assessment, a cross-industry Standards Committee decided to withdraw the requirement for the provision of on-board emergency equipment which could be directly accessed for Factors to consider The RU conducts an initial qualitative risk assessment to assess and compare the options of either removing or retaining fire extinguishers directly accessible to passengers, considering the safety hazards of a fire on board a train and other related issues. Data indicates that when fire extinguishers on trains are directly accessible to passengers they Nature of the decision Risk owner Owned by one organisation Shared by many organisations Worst credible case consequences Insignificant Multiple fatalities Operational experience Extensive None Technology Mature Novel Complexity Very simple Highly complex Ability to monitor and act post change Can identify problems and resolve quickly Difficult to monitor and/or intervene More likely to be catergorised as significant Approach for making the decision More senior level decision taking More consultation More extensive and detailed analysis More time to agree and implement the decision Figure 2: Scoping the removal of fire extinguishers www.rssb.co.uk 1 are often vandalised or misused, thus becoming a potential source of hazard rather than a safety device: • There is potential for increase in injury should a passenger or a train crew member go to a location expecting to find a fire extinguisher, but finds that it is missing or vandalised. • Experience shows that fire extinguishers can be used as offensive weapons on traincrew members and passengers, or to vandalise the railway vehicle. • The cost of replacing emergency equipment when it has been vandalised is high. On the basis of this evidence the RU judges that the disadvantages of retaining the fire extinguishers would outweigh the benefits. The experience of other railways operating under similar conditions is used as a sense check. In one reference case, a subsurface railway previously had a requirement for fire extinguishers in each carriage. However, they then decided that they would only provide one fire extinguisher per train cab on the basis of similar arguments to those above. In particular, their analysis had found that passengers were reluctant to use such emergency equipment even when it was available and in good working order. The RU also determines that removal of fire extinguishers accessible for use by passengers is in line with current fire safety good practice. The advice from the Fire Brigade is that members of the public should evacuate an area where there is a significant fire and should not attempt to fight the fire themselves. The conclusions of the different analyses are consistent with each other, increasing the level of confidence in the case for removal of fire extinguishers which are directly accessible to the public, with associated safety benefits and cost savings. On this basis, and in view of the potential for vandalism and misuse of emergency equipment, together with the decreased risk from a fire on board a train, the RU decides that removal of these types of fire extinguishers should be implemented. In this case, there is considerable operational experience of the issues involved and the risk is completely owned by the RU. The decision can therefore be taken by the RU senior management with only a small amount of local stakeholder consultation; and the change implemented through instructions issued to staff. 3. Making a change Following the decision to remove fire extinguishers accessible to passengers, the RU identifies the steps required to safely make the change as well as any long term additional safety requirements. The proposed system, post change, is therefore defined, and then assessed using the risk acceptance principles of qualitative risk assessment and comparison with a similar reference system, building on the options analysis. The change is not considered significant under the Common Safety Method on Risk Evaluation and Assessment (CSM RA) so does not need to be independently assessed. 2 www.rssb.co.uk The RU identifies some additional safety measures that they should take to manage the change from this assessment process. In summary: • A schedule is drawn up, to remove the old fire extinguishers and fit the new ones along with the appropriate signage, which minimises both the disruption to services and the changeover period. • The RU replaces their existing fire extinguisher signage to communicate the new arrangements to passengers. • The RU holds initial briefing sessions for all train staff prior to the removal of the fire extinguishers. 4. Monitoring safety The RU undertakes a review six months after the change is implemented to evaluate feedback and data on the change. Reports show that there have been fewer incident of vandalism since the fire extinguishers were removed and industry data continues to support the premise of decreasing risk from fire on board a train (given the low number of fires on board trains, the RU’s own data alone on this change of risk over the six months is inconclusive). Based on these conclusions, the RU decides to retain the change and to continue to monitor both vandalism and on-board fires, both on their trains as well as in national data. • All train staff have refresher training on how to respond in the event of a fire on board the train which covers both the use of the new fire extinguishers and passenger management. Selection of Risk Acceptance Principle CODES OF PRACTICE SIMILAR REFERENCE SYSTEM EXPLICIT RISK ESTIMATION Application of Codes of Practice Similarity Analysis with Reference System(s) Identification of Scenarios & associated Safety Measures Safety Criteria Qualitative Quantitative Figure 3: Risk acceptance principles selected www.rssb.co.uk 3