Health and safety by design aims to eliminate or reduce risks through identifying potential risks at the design stage and taking steps to reduce or eliminate them.
Principles of Health and Safety by Design
Health and safety by design should begin at the earliest stages of a project and continue as design choices are made. It requires proactively incorporating health and safety considerations and the impact of the changes at the design stage to minimize risk on the whole railway system throughout the lifecycle of the change, including construction, installation and commissioning, operation, maintenance, de-commissioning and dismantling or demolition.
Good health and safety by design means ensuring that people with the relevant expertise and experience are involved in the design phase of projects, to identify risks and impacts, so that they can be designed out where possible. Where this is not reasonably practicable, the project should ensure that the residual risks are capable of effective control. Effective control requires competent people with the relevant health and safety knowledge to engage with stakeholders and those who will be responsible for managing the risks in future to ensure they understand those risks and have the appropriate expertise and experience to be able to effectively control those risks.
The end-user should be involved in decisions where possible. Projects which leave identification and control of risk to designers alone or project teams with no one responsible for assessing, evaluating and controlling the risk long-term, put in jeopardy the effectiveness of their control measures and are unable to demonstrate health and safety by design good practice.
The challenges
Too often, the planning of new works or changes to existing works fail to take simple steps that would avoid future hazards to the health and safety of workers or passengers. Consideration of how the station roof can be designed to reduce the need for future repair and maintenance work to be carried out at height, or how entrances to stations can be set out to reduce the need for passengers to cross vehicular traffic could reduce the risk of future incidents.
Anyone who is planning new work, or making changes to existing infrastructure and systems, should be considering - through good design - how they can make their systems safer for the public, passengers and employees, and with less risk to health.
Better planning, compliance with standards and application of good practices, and incorporating lessons learned and advice from other operators and projects all at an early stage would help to reduce the need for late, often expensive changes in projects to deal with emerging issues. Crucially, it can lead to continuous improvement and drive down the levels of incidents and accidents in the long term.
- We want to see companies monitoring safety trends and feeding back lessons learned from incidents and accidents into updating of standards and guidance.
- We want duty holders to take a holistic view of the railway as a system and understand how their projects and works can impact others – and seek to minimise that impact.
- We want to see the proper application of risk assessment methods early on in schemes.
- We want credible use of cost-benefit analysis and optioneering, not using these processes to justify decisions that have already been made.
- We want consideration of the whole lifecycle to ensure that works are optimised for maintenance and use and not just construction.
Health and Safety by Design applies across the entire railway system, including rolling stock, signalling and telecommunications, electrification, level crossings, infrastructure, stations and the equipment and systems that are part of all these areas of the railway.
Safety considerations
The Railways (Interoperability) Regulations 2011 require any new, upgraded or renewed infrastructure or rolling stock being put into use on the GB mainline network to be authorised by ORR before it can be used. The Regulations support the railway to function as one modern integrated system, providing more reliable, efficient and accessible services for the rail customer, increasing the choice of potential rolling stock and routes for operators, and reducing production, delivery and maintenance costs for the wider industry Interoperability.
The Railways (Interoperability) Regulations set out the requirements that must be met before an authorisation can be granted by ORR. These requirements are separate to any safety certificate or authorisation that may be issued under ROGS.
Authorisation under the Railways (Interoperability) Regulations requires the infrastructure or rolling stock to meet common baseline requirements. These baseline requirements cover technical compatibility, reliability and availability, accessibility, environmental protection, health, and safety. These are referred to as essential requirements for interoperability. However, meeting these essential requirements alone does not mean that a railway subsystem is safe. Health and safety law, which focuses on controlling risk ‘as low as reasonably practicable’ (ALARP) to assure, requires entities making significant changes to the railway to apply the Common Safety Method for Risk Evaluation and Assessment (CSM REA) in determining risk controls, and in all cases to assess risks and apply appropriate mitigations for the circumstance. This may identify that additional or alternative measures to the standardised safety ‘Essential Requirements’ under the Railways (Interoperability) Regulations are needed to ensure the safety of the subsystem.
Anyone seeking an authorisation from the ORR should incorporate health and safety by design principles at the earliest stages of their projects.
Additional benefits of safety by design
Early design considerations for simpler, easier to use and safer systems is not just a benefit in health and safety terms but can also give long term financial benefits through reduced construction and maintenance costs and prevent need for costly modifications.
It can also reduce the impact of incidents and accidents in lost time and compensation costs. If opportunities are missed to address health and safety requirements at the design stage of projects, this can lead to increased costs later on to resolve the issues or put in place additional measures to mitigate the risk.
Risk controls that were reasonably practicable to incorporate into the initial design become significantly more expensive when required to be implemented later.