JARGON BUSTER: SMS
A Safety Management System is a formal arrangement for managing a safe working environment. It defines roles and responsibilities, sets arrangements for safety mechanisms, involves workers in the process and ensures continuous improvement. All operators and duty-holders are required to have in place arrangements for managing safety risks and monitoring the performance of their safety system.
SR: You’ve raised a number of issues there. Among the first of those was the notion of railways assuming greater responsibility for their own actions. Can you explain what you mean by that in practical terms?
IS: We’ve had ROGS [Railways and Other Guided Transport Systems (Safety) Regulations] since 2006. The ORR and HRA have continued to provide advice and guidance to the individual railways and how they discharge their duties, but, fundamentally, the legal requirements and duties haven’t changed.
There’s a requirement to have an SMS and, within that, describe what the leadership and governance arrangements are.
I think some of the charges are getting more difficult as the infrastructure gets older and as the profile of volunteers changes, but I want the sector to become more mature in how they achieve what they achieve and move away from being reliant upon the inspectors saying ‘this is what you have to do’. That is not our role. We’re here to provide advice and guidance, and the task
I put to Steve [Oates] and Chris is to take on more of that responsibility to help the sector develop its own solutions. A solution coming from Chris and Steve should be more effective than if it came out of my office because I don’t run railway businesses.
CP: One of the areas I’m concerned about, leading on from what Ian has just said, is that, actually, it’s not just about competence on the ground; it’s not just about whether your fitter can weld up a brake pull rod or whether your guard can despatch a train correctly and so on, it’s also about competence at governance level. I’m not afraid to say this – there are railways tearing themselves to pieces and I know that one of the ORR inspectors has rung one of them up recently, they’re so concerned.
We’ve also got to make sure that, with RM3 [Risk Management Maturity Model] we start at the top, and I think that there is a reluctance within railway governance to look at the top and work its way down. It concentrates over and over again on whether the guard is competent, is the driver competent, is the fireman competent – but, ultimately, are we competent?
And, more to the point, does some of our political wrangling and selfish attitudes towards what we think our railway should be doing destabilise governance to the point where we’re destabilising the competence to actually run the railway in the first place?
Safety is becoming increasingly important, so if governance is going to start affecting it then that’s a problem.
IS: Absolutely. We’ve put governance and leadership at the centre of our engagement with the railways. Chris mentioned a number of political battles going on at a variety of railways. I don’t want to get drawn into that, as that’s not my role as a safety regulator, but I need to make sure that the outcome of
those various battles does not impact upon safety. So, regarding the railways that we are aware of which are having some internal debate as to their future, we have increased our level of oversight as to how they’re managing safety. We won’t get involved in it, but we will monitor the impact and outcome of it, and if a railway is having poor governance and risk is not being controlled, we will take action.
SR: If you were to take one of those railways as an example, what would your fear be if they were to run a train tomorrow?
IS: In terms of governance and leadership, the volunteers who do much of the day-to-day work will take their prompts on what is acceptable behaviour from the people above them, so if they see their board directing their energies at ripping each other apart, then they might view that some of the safety requirements with which they have to comply are less important. So it’s all about the shadow the board casts. What does that tell the volunteers?
We see a lot of chitchat going on where volunteers start arguing as to whether chairman X or chairman Y is the right person to be following. It becomes selfdestructive and you take your eye off the ball of the safe day-to-day running of a railway. So, how does the behaviour of senior leaders affect the people doing daily activity?
SR: If you’re looking for a good railway manager, you’re looking for someone who is genuinely a leader, aren’t you? You’re looking for someone who’s going to put themselves above such in-fighting.
CP: To a certain extent, yes. If you’ve got people at a governance level tearing themselves to pieces, how much attention is being drawn to the state of their SMS, the state of their internal regime of auditing, their competence management? My concern is that those areas are being dropped down the list of importance while we’re fighting with ourselves over the control over our favourite bit of the railway.
IS: And that then allows the volunteers and staff to also reflect on the importance being put on safety versus other matters, and that could lead to certain decisions being made that aren’t necessarily correct.
Steve Oates: The directors and the trustees should not be ripping each other apart, but asking the questions and proactively saying, ‘so, if I’m sat at board/trustee level, can I see how that volunteer – who is way, way down the management chain – has a direct line back to me?’, and ‘can I be assured that there is a clear governance line at a safety level between the two?’. And that’s a proactive issue as well as a leadership issue, and what has fascinated me about governance leadership is that, on the financial and heritage level, it is much more second nature than it is on the safety level.
A lot of us came into this because of heritage and the fun of saving something and keeping these things going and so on, and we’re all very exercised about heritage and the governance in terms of how a locomotive should look or whether a carriage should have that type of chair or this type of chair, and the same goes for finance. It’s taken a lot of organisations, whether it’s heritage
I’m not afraid to say this – there are railways tearing themselves to pieces
CHRIS PRICE
railways or other voluntary or cultural organisations, much effort to sort out financial governance, but it should be the same with the safety area of leadership and governance; it’s got to be second nature, and that second nature has to start at the top.
CP: The two most ‘boring’ aspects of running a heritage railway are safety and finance. Isn’t it very telling that our sector at the moment has safety and financial crises? Are we, as a sector, incredibly distracted by shiny pretty things?
We’re not sitting here saying the heritage movement is full of cowboys
SR: It is a matter of public record that, Ian, you went down to the West Somerset Railway two years ago and they took the decision to cease their own operations. The thing that came out of that was very much what had been overlooked for several years – the governance, the track, the bridges and the infrastructure.
How emblematic, if that’s the right word, do you think that this sort of situation is for the entire railway preservation movement?
IS: My concern is that there is more than one railway in those circumstances.
SR: How many are we talking about? How big is this issue?
IS: I’m not going to go into specifics, but I would suggest to you that the railways we all love were all railways that were shut down for good reason, and often the infrastructure was not necessarily in good condition when those railways ceased to exist. That infrastructure hasn’t gone away; it has to be maintained.
Most railways have at least one form of significant structure on them that requires significant input to keep them in a safe condition. These assets are nearly 200 years old in some cases; they require major intervention just to understand the condition of them. How many of the railways that I regulate have the capability to do that when it is required to be done?
SO: If you’ve got a bridge which is Victorian and it’s starting to exhibit signs of heave or cracking or whatever, some places would say, ‘Oh, Bob knows about bridges, he’ll take a look,’ as opposed to the board saying ‘Actually, is that good enough?’. It’s a case of questioning the competence of Bob and realising we are going to have to budget for an external bridge engineer and that we’re going to have to get this done properly.
And then you come to this issue of ‘Oh, we were going to spent the finance on one of those shiny steamy things’ or whatever it may be, and then you start thinking ‘well, maybe we can hang on for a couple more years because Bob’s alright, isn’t he?’.
That’s a governance issue in terms of what is actually more important, because it is a Victorian structure which is now
CHRIS PRICE
exhibiting signs of cracking or heave, and because nobody knows whether or not Bob is competent. Is Bob the right person?
That’s the sort of issue that has to be addressed by the board; they have to make that decision and stand by it, and hopefully they’ll make the professional decision.
CP: We as a movement had got away with infrastructure issues for nearly 50 years as all these railways had been professionally maintained.
You’ve got to remember, BR’s Modernisation Plan was pretty much a switch – BR was still maintaining the ‘Moors’ three weeks before they ripped it up for instance, so the movement took over professionally maintained railways in the ’50s, ’60s and ’70s and then spent 40 years getting away with it. And that is now not the case.
We could get away with having one of Her Majesty’s railway inspectors turning up, having a jolly ride on the train and giving us the thumbs up at the end of the visit and disappearing – that world has gone.
The ORR has already professionalised beyond what they were, and I’m saying some quite negative things about some heroic figures from Her Majesty’s Railway Inspectorate of the past, but the whole industry has moved on. We’ve got to be more professional.
IS: I can’t give you a number of railways but what I can say is that I am having three live conversations with three different railways of varying sizes regarding the adequacy of their infrastructure, and whether their structures can support the rolling stock they want to run across them. And it’s ‘no’ at the moment, because they can’t demonstrate it.
SR: That’s the nub of our follow-up to that. There are more than 500 [preserved] track miles in the UK – the reality is that if we are talking about really upping our game collectively, if we were to just look at infrastructure, then that is unsustainable, surely?
IS: No, it’s not, because the first thing is to understand the condition of your infrastructure. And if every railway fully understands the condition of its infrastructure, then they have a better understanding of how scary that is. Now, I’m not suggesting they don’t understand the condition of their infrastructure, but that is the first stage.
CP: It is sustainable because then you have to mobilise your governance. The North Yorkshire Moors Railway did not have enough money in the bank to change £2.4 million worth of bridge. The first part was going to find the money to change the bridge, and you only know you’ve got to find the money when you know the condition of your bridge.
If you’ve got your fingers crossed and then someone comes in and says, ‘have you seen the cracks that have appeared on that bridge?’, that’s not good business sense. What Ian is telling railways is: know the size of your problem and manage it, because if you don’t manage it then it’s a business risk. It’s not just a safety risk, it’s a massive business risk as well. You shouldn’t be afraid to know the size of the apple you’ve got to eat.
SO: And taking that back to board leadership and governance, has the board of every heritage railway got someone on the board with the requisite civil engineering knowledge to recognise the issues that need to be on the boards’ and management teams’ agendas, so that these items can be checked and inspected and known about?
If a board doesn’t have any engineers on it and it’s all people who love steamy things and for whom it’s all about the livery, do these significant issues get addressed? Again, it all comes back to starting from the top. Does the board have the requisite skills, expertise and knowledge on it, of active people who have been there and done it and can provide some insight?
IS: We shouldn’t be entirely negative because there are many railways that I visit that do have the requisite knowledge and their infrastructure is capable of carrying what they run. As a regulator, we will often focus on the negative because that’s what we’re there to do, to prevent the bad event, but there are many railways out there that do understand the condition of their assets and are managing that appropriately.
I can think of many railways that have proactively shut themselves temporarily to replace a bridge or repair the waybeams or whatever, so there is a lot of good stuff going on out there – but there are also areas that can be improved.
CP: I think Ian is absolutely right to put a sense of proportion on it. We’re not sitting here saying the heritage movement is full of cowboys. There are some great examples of professionalism out there that make me proud to be vicechairman of the HRA, but it only takes one bad apple – and that’s the point.
What we should be looking at is the lowest common denominator, not the highest, and there is a danger that the lowest could have an effect on the industry. We have a collective responsibility to highlight that there are areas of concern, and if that prompts even one railway to say, ‘we saw an article in Steam Railway. Do you think we should look at this RM3 model and apply that to ourselves?’, then this conversation is worthwhile.
IS: I think we should also remember that the heritage sector has the same
environmental challenges as the main line sector. We have viaducts and bridges that cross watercourses, piers sitting in the water that are subject to scouring and so on; we have railways going through steep-sided embankments and high cuttings, and they’re also being impacted by the changes in weather we are seeing, so are the heritage railways also thinking about that?
It’s not just about your structural capability today, it’s about your structural capability in one, five, ten years’ time, and if you have an effective SMS with properly qualified directors on the board, you can start asking those questions so we do these things proactively and not reactively, because, reactively, the heritage sector will struggle. They need to get ahead of the game here.
SR: Across the industry, there are those railways who are taking this on proactively very well, but you might say that they are in the minority; many railways are still relying on inherited material.
IS: And that might be the right thing to do, but it’s making sure they realise they are coming to a crossroads and they have to make some decisions. They might not need to take action today, but they have to be aware that they are coming to a point where they might have to decide to take action.
SR: But the expertise, arguably, is spread quite thinly across preservation.
CP: I would like to clarify the point Steve made and say that I don’t think a board has to have a civil engineer on it to be competent – it’s got to be able to demonstrate it can get that competence, and that’s the point.
It’s not just about saying, ‘here’s my civil engineer, here’s my mechanical engineer’, it’s more holistic than that. It’s about a board being able to look at itself and say, ‘have we got the competence available to us to manage safety correctly, manage infrastructure, manage rolling stock – even manage tearooms – correctly?’.
It doesn’t have to be that you have those various competencies sitting on your board, but they have to have access to it and demonstrate they can get access to it when they need it.
SO: I agree. It’s not saying you’ve got to have that competence on the board, you’ve got to have the thinking process, almost as second nature, to ask the questions about the infrastructure in the same way as they might do, and I say this slightly tongue-in-cheek, about the livery of their locomotives.
That might be someone who has got a civil engineering background, if not they’ve got to have access to those competencies.
There has to be the thought process that every area of the railway’s operation is thought about at board level, because that’s where it starts.
IS: It’s being able to recognise when an important issue is crossing your desk and you have to stop and ask the question, and then you get the expertise to help you form the questions you need to be asking. There are some boards who don’t have sufficient people who question; they come too quickly to a judgment and then move on.
CP: I’ll say it and I’ll say it again, it’s when the balance between enthusiasm and business gets tipped too far in one direction. It has got to be a balance; you’ve got to be a railway enthusiast to keep the level of interest alive, but you’ve got to be a businessman to know what the important, boring stuff is you’ve got to deal with.
I’ve said it before in Steam Railway and I stand by it, and we are seeing it at certain levels being played out, whereby shiny things are distracting people away from the nuts and bolts, but it’s the nuts and bolts that are going to hurt them, not the shiny things.
SR IN PART TWO: We discuss the HRA’s planned Heritage Railway Safety Standards Board and what it means for the steam movement.