‘Minding the Gaps’ in safety procedures

My point exactly! There is only one very simple warning, and everyone knows it: “Mind the Gap”. The expression is so effective, it’s entered the wider general vocabulary - journalists, for example, often tell Government to “Mind the Credibility Gap”. 

So, “mind the gap” is incredibly simple. It does what it says on the tin. It’s embedded in everyone’s psyche. You say “mind the gap” and everyone knows exactly what you mean and where. 

“So we’re in agreement!” says Prosser. “We’re coming back to my golden rule - proportionate, accurate, simple. On my LU platform at King’s Cross, every day is well managed and well controlled by one individual, and there are hundreds and hundreds of people that use that platform. It’s common sense, most of this. 

“It’s about not making it too complicated, not over-burdening people. Simple messages. ‘Stand back as the train comes in’ - that’s all they say. Sometimes, we have to work hard to keep it simple, because as human beings we tend to over-complicate things.”

Aha! NOW we’re in agreement, I tell him! My sense is that he does really ‘get’ this point… in which case, I wish him well in going out to bat for ‘proportionate, accurate, simple’. 

Apply that rule to rollerblading at King’s Cross, and the only thing that applies is the simplicity of the warning. Apply it to the ‘slippy platforms in inclement weather’ and it fails entirely on ‘simple’ - the railway is the only place anywhere these days (I think) that even uses the word ‘inclement’!

So are passenger safety trends generally heading in the right direction? Some stats seem to be heading the wrong way?

“Passenger risk does appear to have gone up slightly, but that is because the numbers have gone up,” Prosser replies. “But when you normalise the stats, risk is slightly down. Something is working, and that’s because Network Rail - in some areas - has made some really quite key improvements.  

“Level crossing risk has improved, for instance. But there are problems elsewhere - we need to maintain momentum on renewals, in particular, and maintenance. NR is starting to make headway on earthworks after we had to enforce on drainage last year. They are making progress with drainage.”

Isn’t the problem there because of decades when drainage has been neglected? Civil engineers privately say that it’s the easiest thing to cut out of the budget when you need to save, because nobody notices… at least at first!

“Absolutely - and the key words there are ‘at first’,” Prosser replies with great firmness. “It’s like vegetation, where we have also seen NR make a push. These are the sort of Cinderella assets we must not forget about, because they will come back to bite us. Poor drainage has a major impact on track geometry and embankment stability - and the safety risks there are very obvious.”

Good point, and a worrying one. We have seen the landslip at Harbury this year (RAIL 768). There was the West Highland landslip in June 2012, when a Class 66 freight train careered down a hillside and very nearly ended up in Loch Treig (RAIL 700, 701). That could have been the Caledonian Sleeper train. And there was an embankment collapse at Loughborough, under a freight train that divided and rolled down the bank - that could easily have been an East Midlands Train passenger train. In an era of climate change and much more severe weather, are we heading for a fall here? 

Prosser does not disagree. “We have had some incidents, and this was why we enforced on drainage, and why we’ve enforced on Network Rail in previous years on civil structures and earthworks. And it has since made some really important progress. 

“Network Rail MUST continue to better understand its embankments. It has a much better understanding of embankments now, but it needs to follow through with work on civil structures. NR believed it had a good central plan for drainage, but when we went out to the roots we found weaknesses. The plan wasn’t being implemented well - so we took enforcement action. 

“That’s why we at ORR have to be on the ball, because if we think NR is not where it should be, we have to act quickly. That’s why it’s important, as a regulator, that we should not be afraid of using our enforcement tools.”

When Tom Winsor was Rail Regulator, his complaints about asset knowledge were a common refrain of his time in office. Are we finally making progress at a rate you’re happy with?

“I think NR is going in the right direction, but we’d always like it to go faster. That’s why we demanded in the Periodic Review that the regulatory outputs around asset management capability should be prioritised. This was the first time the regulator had done that, and it was because we are now a joined-up regulator and we did not make NR’s progress to be entirely output-based. 

“At the same time, we do need to be careful that we don’t overload NR in terms of initiatives. We have to make sure NR is prioritised on the right things.”

You mentioned level crossings?

“It’s an improving picture in terms of understanding the risks at level crossings. Managers that NR put in place, after some enforcement from us, have been a very positive development. 

“It’s about ownership of the problem, rather than it being shared by signalling, maintenance, ops and so on. What you have now is ownership, and so people will get a much better understanding of the way in which these crossings are used and the associated risks. 

“One area for the industry to worry about is the passive crossings, which have no warnings at all beyond the old ‘stop, look and listen’ signs, because this is where we’re seeing most of the tragic fatalities. It’s an area where some simple technology - active warnings - would help.”

Personally, I think there’s a discussion to be had here, around our previous chat about a proliferation of warnings. After all, “stop, look and listen” is as simple as “mind the gap”.

I would apply Prosser’s own thinking here: one size does not fit all. If a passive crossing has long, highly visible approaches for trains, surely ‘stop, look and listen’ should suffice? We’re expected to look out for cars and lorries before stepping into the road. Why not apply the same thinking?

Maybe there are exceptions, where there are curved approaches to crossings. But blanket application of pee wee-style audible warnings to all passive crossings does not seem right to me.

I tell Prosser about the current farcical NR management of the passive foot crossing at Gainsborough Central, where there are only three trains a week, Saturdays only. NR is planning to replace the footbridge (which probably only needs shot blasting and painting anyway), but is not adding ramps. It is also planning to remove the passive foot crossing (RAIL 777, 779).