Consultation on draft train protection systems guidance

Consultation status
Conclusions published
Date of publication

Sought feedback on new train protection systems guidance. Guidance aims to clarify legal obligations of dutyholders in relation to modern train protection systems.

Consultation outcome

In May 2024 we published guidance which explains the application of The Railway Safety Regulations 1999 (RSR99) to train protection systems.

The guidance provides clarity on the interpretation of RSR99 in relation to train protection systems, including how we expect duty holders to manage the migration towards automatic train protection systems.

The guidance also explains other legal requirements relevant to train protection systems, such as The Railways and Other Guided Transport Systems (Safety) Regulations 2006 (ROGS).

January 2024 consultation

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We are asking for views on our new draft guidance on train protection systems. The guidance is intended to help interpret the Railway Safety Regulations 1999 and other legal requirements relevant to train protection systems. It aims to reflect the current technology and safety expectations around modern technologies that underpin train protection on Great Britain's railways and metro systems. The guidance provides a resource for anyone involved in the design, management and operation of train protection systems, including train operators and infrastructure managers.

The guidance follows a principles approach which ORR uses for other similar publications on railway health and safety. It does not place additional obligations on dutyholders, but supports the design, management and operation of train protection systems on mainline and non-mainline railways.

We welcome feedback on the content of the guidance and views on how helpful it will be as an aid to manage the migration to modern signalling systems.

If there are any matters that you consider we should clarify further then please let us know. In particular, please let us know if it is clear how the Railway Safety Regulations 1999 and other legal requirements relevant to train protection systems affect you and what you need to do during the migration to modern signalling systems. Please also let us know whether you require additional guidance from ORR to support the migration at this time.  

Publishing your response

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We plan to publish all responses to this consultation on our website.

Should you wish for any information that you provide to be treated as confidential, please be aware that this may be subject to publication, or release to other parties or to disclosure, in accordance with the access to information regimes. These regimes are primarily the Freedom of Information Act 2000 (FOIA), the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA) and the Environmental Information Regulations 2004.

Under the FOIA, there is a statutory code of practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence. In view of this, if you are seeking confidentiality for information you are providing, please explain why. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on ORR.

If you are seeking to make a response in confidence, we would also be grateful if you would annex any confidential information, or provide a non-confidential summary, so that we can publish the non-confidential aspects of your response.

Any personal data you provide to us will be used for the purposes of this consultation and will be handled in accordance with our privacy notice which sets out how we comply with the UK GDPR and Data Protection Act 2018.


In responding to this consultation you consent to us:

  • handling your personal data for the purposes of this consultation;
  • publishing your response on our website (unless you have indicated to us that you wish for your response to be treated as confidential as set out above.)

Your consent to either of the above can be withdrawn at any time. Further information about how we handle your personal data and your rights is set out in our privacy notice.

Format of responses

So that we are able to apply web standards to content on our website, we would prefer that you email us your response either in Microsoft Word format or OpenDocument Text (.odt) format. ODT files have a fully open format and do not rely on any specific piece of software.

If you send us a PDF document, please:

  • create it directly from an electronic word-processed file using PDF creation software (rather than as a scanned image of a printout); and
  • ensure that the PDF's security method is set to no security in the document properties.