ORR consults on Mk 1 central door locking

THE CONTINUED future of Mk 1 stock on the main line has long been in question, especially with regards to controlled toilet emissions and the safety of slam doors. Now the Office of Rail and Road is consulting on its proposed revision of the Railway Safety Regulations 1999 (RSR 99) to Mk 1-type and hinged door rolling stock when used on railway infrastructure where line speed exceeds 25mph.

At the time of the introduction of RSR 99 it was recognised that for hinged door rolling stock it was impossible for the range of heritage stock primarily used on the main line to immediately comply with the requirements of the regulations, most notably for central door locking (CDL). In that case, RSR 99 permitted the use of exemptions until rolling stock was progressively retrofitted with CLD or equally effective systems.

That was 21 years ago and the ORR has the view that that has been sufficient time for relevant stock to be fitted with CDL. The withdrawal from service and dismantling of more modern main line hinged door carriages fitted with CDL means that serviceable second-hand CDL components are available that can be retrofitted to hinged door stock at reasonable cost. Consequently, the ORR feels there is no practical basis for justifying continued noncompliance with the requirement to fit CDL, or for further generic exemptions to be issued for hinged door rolling stock running on infrastructure where line speed exceeds 25mph. Other than the person responsible for activating the central door locking system, the ORR can’t see any justification for reliance on 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’, and 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 25mph.

The ORR recognises 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, it has amended the criteria to reflect the changed circumstances and the fact that an engineering means of door locking that does not rely on more than one person is proposed, also that the engineering-based approach is supported by a 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.

With regard to Mk 1 rolling stock exemptions, the ORR proposes the following future requirements:

Where Mk 1-type carriages are used there should be a clear inspection and maintenance regime with appropriate accompanying records, to demonstrate that structural crash pillars are maintained to an acceptable standard and 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, the ORR would normally expect to continue to issue exemptions against RSR 99 Regulation 4 (Prohibition of Mk 1 rolling stock).