Consultation on revision of ORR guidance on application of the Railway Safety Regulations 1999 to Mark 1 type and hinged door rolling stock

Consultation status
Reviewing responses
Date of publication
Closing date

We are seeking views on our proposed revision of ORR guidance on application of the Railway Safety Regulations 1999 (RSR 99) to Mark 1 type and hinged door rolling stock when operated on railway infrastructure where line speed exceeds 40kph.

We welcome views on our proposals as outlined below and other aspects of our revised guidance.

Hinged door rolling stock
Collapse accordion Open accordion

At the time of introduction of RSR 99 where line speed exceeded 40kph it was recognised that for hinged door rolling stock it was impossible for the range of heritage stock primarily operating on the mainline railway to immediately comply with the requirements of the regulations, most notably for central door locking (CDL). In this case RSR 99 permitted the use of exemptions until rolling stock was progressively retro-fitted with CLD or equally effective systems. 

We are now 21 years on from the introduction of the regulations and we have the view that this is sufficient time for relevant stock to be fitted with CDL. 

The withdrawal from service and dismantling of more modern mainline hinged door carriages fitted with CDL means that serviceable second-hand components for CDL are available which can be retro-fitted to hinged door stock at reasonable cost. 

We believe there is no practical basis for justifying continuing non-compliance with the requirement to fit CDL and for further generic exemptions to be issued for hinged door rolling stock operating on infrastructure where line speed exceeds 40kph.

Other than the person responsible for activating the central door locking system, we can see no justification for reliance of a manual process for locking and unlocking the doors of hinged door stock. 

The basis for this proposal is that:

  • The relevant RSR 99 regulations are not qualified by ‘reasonably practicable’, therefore CDL must be fitted.
  • CDL technology and components are now readily available.
  • There has been considerable time for industry to achieve the fitment of CDL on stock intended to run on infrastructure where line speed exceeds 40kph.
  • We recognise that alternative, equally effective technical solutions comparable in effect to CDL may be possible, and consequently the provision for the potential issue of exemptions from the absolute requirement to have CDL remains in place. However, we have amended the criteria to reflect the changed circumstances and that:
    • an engineering means of door locking that does not rely on more than 1 person is proposed
    • the engineering-based approach is supported by quantified risk assessment, and 
    • the application of the hierarchy of controls as per the Management of Health and Safety at Work Regulations 1999 has been undertaken.

Mark 1 type rolling stock
Collapse accordion Open accordion

With regard to Mark 1 type rolling stock exemptions, we propose the following future requirements:

  • where Mark 1 type carriages are used, there is a clear inspection and maintenance regime with appropriate accompanying records, to demonstrate that structural crash pillars are maintained to an acceptable standard, and 
  • that the remainder of the vehicle underframe and body shell are also maintained in a state of good repair.

Where such evidence as indicated above is available, we would normally expect to continue to issue exemptions against RSR 99 Regulation 4 (Prohibition of Mark 1 rolling stock).

We consider that the draft revised guidance that we are consulting on sets out the above position clearly, whilst remaining consistent with the unchanged legal wording of the regulations. 

Responding to this consultation

All responses on this consultation should be addressed to Julie Holt before the close of the consultation period. If you have a technical query on this consultation and would like more information, please contact Ian Raxton.

Publishing your response
Collapse accordion Open accordion

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 General Data Protection Regulation (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 General Data Protection Regulation 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.