Taking Safe Decisions Worked Example Provision of Signal Post Telephones when adopting GSM-R Summary: This worked example describes the removal of a risk control which is no longer providing a significant safety benefit, and where several iterations of the risk assessment and monitoring processes may be required to reach a decision. It also illustrates the complexities of decisions involving multiple organisations. with operations becoming significantly less reliant on these where GSM-R is installed and is fully operational. Such telephones may however provide a useful back-up to GSM-R in the event of GSM-R failure, but their upkeep and maintenance also incurs significant on-going costs for the industry. An Infrastructure Manager (IM) undertakes a resignalling project in an area covered by GSM-R and wishes to assess whether they should continue to provide SPTs in the area from a safety point of view. Key learning points This worked example illustrates that: • Framing can influence the decision: it is often more constructive to frame the decision as whether a control needs to be provided rather than whether it can be removed to avoid loss aversion. • It is important to seek stakeholder consultation, involvement and agreement in the early stages of scoping and assessing the change. • Assumptions underpinning the risk assessment need to be verified. • Previous work can be reused and built upon to prevent unnecessary re-working. 1. Origin of review GSM-R voice and data radio has been fitted across the UK railway network, meeting the requirement of the Railway Interoperability Regulations. The initiative raises a number of strategic questions for continued use of existing train control equipment, including Signal Post Telephones (SPTs). The main purpose of voice radio systems between train drivers and signallers is to provide an effective means of communication to support the safe and efficient movement of trains and the general operation of the railway. Where fitted, GSM-R forms the primary means of supporting such communication. Although no longer mandatory, SPTs continue to exist across the railway network, www.rssb.co.uk 1 2. Analysing and selecting options The IM accesses previous RSSB research as a starting point to analyse available options. Prior to the introduction of GSM-R, RSSB had commissioned consultants to advise on the optimisation of communications following the introduction of GSM-R, and the role of SPTs. The RSSB analysis was initially undertaken to determine whether, from a safety perspective, it is necessary to provide SPTs, given installation and operation of GSM-R. The aim was also to provide IMs with a basis for decision making on future projects regarding whether to continue to provide SPTs. The quantified risk assessment within this RSSB analysis indicated that not providing SPTs created some additional risk to train drivers and passengers associated with the potential for loss of communications in safety critical situations. However, for some locations this additional risk was offset by a reduction in the risk associated with train drivers alighting from the train to the trackside to use the SPTs less frequently. Overall, the RSSB analysis had concluded that providing SPTs would result in a net safety benefit for train drivers of approximately 0.18 FWI/year nationwide but would incur significant maintenance Factors to consider costs. The cost-benefit ratio of around 28 supported the case for not providing the SPTs, overall. It was however recognised that the costs and benefits of SPTs vary from one location to another and that therefore there may be some SPTs where the benefits exceed the maintenance costs and, from a cost-benefit perspective, it would be reasonably practicable to provide SPTs in these circumstances. On the basis of this analysis the IM decides that the selective provision of the SPTs should be assessed on a location by location basis for the project with explicit risk estimation, using the RSSB assessment tool – the Fixed Lineside Telephony Assessment Tool (FLAT) - together with industry guidance. Site-specific data is entered into FLAT to determine whether there is a safety benefit and/or financial saving from the provision of each particular SPT. This analysis concludes that the majority of the SPTs are not required to make the system acceptably safe when operating under GSM-R, assuming that drivers can resort to the use of company mobile phones for back-up. On the basis of the analysis therefore, the IM concludes that it is reasonably practicable to provide SPTs protecting signals and junctions, but not in other locations. 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 provision of all SPTs when adopting GSM-R for a re-signalling project 2 www.rssb.co.uk The IM then consults with the Railway Undertakings (RUs) operating over each line of route covered by the re-signalling project, as well as the maintainers of the SPTs. Although the RUs and maintainers agree that the proposal is sensible, one of the RUs is keen for the IM to continue to provide the majority of the SPTs at this time as their drivers do not have company mobiles. They are concerned that there would not therefore be a backup for secure communication to the signaller in the event of a GSM-R failure as the GSM-R system has not yet been proven as reliable in service. They are also reluctant to take on the additional cost of providing mobile phones when the reduced provision of SPT does not provide them with cost savings (as the IM current covers the associated maintenance costs). The IM finally decides to continue to provide SPTs at locations where they offer a safety benefit until the GSM-R system is more mature. However, those SPTs which demonstrate explicitly obvious safety related concerns will no longer be provided, namely: mid-platform SPTs; SPTs with limited clearance to an adjacent line; and a few others with very difficult access. 3. Making a change For those SPTs that will no longer be provided, the IM expands the explicit risk estimation to identify any further risk mitigations required for safe implementation. This includes the FLAT assessment for each SPT, as well a HAZID for the relevant SPTs to identify the hazards, the mitigation measures already in place and any additional controls that will be required. Given the agreed scope of the change is that only a limited number of SPTs will no longer be provided, and that not providing these SPTs is in line with the applicable standards, the change is not considered significant. 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 The actions required for safe implementation of the change include a briefing for all affected drivers on the new communication system, the recovery of redundant lineside SPTs by the IM, and making public mobile phone coverage available in areas where there are issues with GSM-R coverage. For specific SPTs which cannot be completely removed prior to the change in operations, it is deemed sufficient to disconnect them and clearly label the handset as no longer in service. 4. Monitoring safety RU support is identified by the IM as the main issue in reducing the provision of SPTs. Therefore the IM decides to focus on addressing the issues that the RUs raised before conducting further similar assessments. At the time of the project, GSM-R is not demonstrating as high a level of reliability as had initially been hoped in the original risk assessment, highlighting the importance of reviewing the underlying assumptions. A large proportion of failures are due to the on board train equipment, so new software is trialled to address this problem and the stability of the cab radio is monitored following its introduction. Further issues are also identified around incorrect operation of the new system but this is expected to improve over time as understanding of the system increases. In this case, although initial analysis supports not providing SPTs, the IM retains most SPTs for the time being due to lack of stakeholder support for the proposal. This highlights both the importance of stakeholder consultation, involvement and agreement in the early stages of scoping and assessing the change when there is a larger degree of design flexibility, and problem framing to avoid cognitive biases such as loss aversion and narrow framing. Future risk assessment results will be framed “if SPTs were not present would there be a case for installing them?” rather than assessing the case of removing SPTs, and will also consider whether the savings from not maintaining SPTs can be more effectively spent on other risk controls. As the IM would however still like to reduce the levels of SPT provision where the safety benefit outweighs the impact of non-availability of GSM-R, demonstrating the availability of voice communications via GSM-R is identified by the IM as the key issue for future review of SPT provision. Having multiple stakeholders involved in the change creates challenges. Although the removal of SPTs is judged to provide benefits to the system as a whole, the various costs and benefits are split between different organisations. The savings from eliminating the costs of maintaining the SPTs accrue to the IM, but the RUs incur costs if they need to issue company mobile phones to their drivers as a backup system. 4 www.rssb.co.uk