Health and safety management

Strategic risk chapter

5. Appendix

Industry performance

Network Rail

Network Rail operated broadly at the Standardised level across most SMS components, with Scotland consistently outperforming other regions and reaching Predictable maturity in leadership, governance, and proactive monitoring. Improvements were noted in assurance activities and dashboard-based performance tracking, particularly in Scotland and Wales & Western. However, weaknesses persist in contractor control, incident investigation, and competence management, compounded by staff shortages and retention challenges. Fatigue risk management remains underdeveloped, and uneven application of standards continues to affect consistency.

Chart showing Network Rail’s Health and Safety Management System maturity against RM3 criteria. Overall maturity is Standardised, with Predictable performance evident in leadership, board governance, and proactive monitoring, particularly in Scotland and Wales & Western regions. The chart highlights improvements in assurance and performance tracking, alongside weaker performance in contractor control, incident investigation, competence management and fatigue risk management. The data indicates uneven application of standards and ongoing challenges linked to workforce resource pressures.​

Mainline Operators

Mainline operators demonstrate Standardised maturity overall, with Predictable performance in leadership, board governance, and incident investigation. Worker involvement and change management scored well during major fleet introductions. However, variability across duty holders remained significant, particularly in contractor control, safe systems of work for high-risk tasks, and proactive supplier monitoring. Several risk assessments were found outdated, and communication gaps persist, limiting the reach of safety briefs and route risk information.

Chart illustrating RM3 maturity levels for mainline passenger and freight operators. Overall maturity is Standardised, with Predictable performance in leadership, board governance and incident investigation. Stronger performance is shown in worker involvement and change management, particularly during major fleet introductions. The chart also shows variability between operators, with persistent weaknesses in contractor and supplier control, safe systems of work for higher‑risk activities, proactive assurance, and the currency of risk assessments.​ ​

Non-Mainline Operators

Non-mainline operators generally operated at Standardised maturity, with strong performance in communication, worker involvement, and record keeping. Contractor control and change management also scored highly, supported by structured processes. However, risk assessment and audit processes remained inconsistent, asset management is uneven, and competence arrangements for agency staff require improvement. Emergency planning is supported by joint exercises but lacks systematic integration of lessons learned.

Chart presenting RM3 maturity across non‑mainline rail operators, showing overall Standardised maturity. Stronger performance is evident in communication, worker involvement, record keeping, contractor control and structured change management. The chart also highlights inconsistent maturity in risk assessment, audit, asset management and competence arrangements, particularly for agency staff. Emergency planning is present but shows limited systematic learning from exercises.​ ​

Heritage Railways

There are over 200 Heritage and Minor railways in Great Britain, varying significantly in their scale and operations. ORR expects individual railways to develop a SMS proportionate to the level of risk associated with their operations. To support improvement, ORR has published SMS guidance tailored for heritage railways and developed a dedicated RM3 topic set specifically for this sector Our inspections in 2024/25 identified that the sector is typically at a Managed level of SMS maturity. Weaker areas tend to be found around audit and change management.

Chart showing RM3 maturity for heritage and minor railways, indicating that the sector typically operates at a Managed level of maturity. Stronger arrangements are evident where systems are proportionate to risk. The chart highlights weaker maturity in audit, change management and formal assurance processes. The data reflects the wide variation in scale and complexity across the sector and the need for proportionate but structured Safety Management Systems.​ ​