Presented by Vaibhav Puri Head of Standards Policy Autonomous systems, railway regulation and standards – In the pursuit of good questions? Presented by Vaibhav Puri Head of Standards Policy Feb 2016

About RSSB RSSB is an expert body that delivers programmes of work on behalf of the rail industry across technical functions that cross rail interfaces in the areas of: Health and Safety Research Standards Sustainability Through research, the understanding of risk, and analysis, we provide an evidence base to support industry decisions and collaboration. RSSB’s membership includes infrastructure companies, train/freight operators, rolling stock owners and suppliers. It is non-profit-making and independent of any single interest.

Contents 1. The key principles of legal framework 2. The scope of legislation 3. The role of standards 4. Challenges for autonomous systems

Infrastructure Manager Regulatory complexity that confronts a railway company TSI ROGS 2006 RIR 2011 MHSWR 1998 CSM-RA HASAWA 1974 Infrastructure Manager Project Entity Proposer Transport Operator Railway Undertaking ASBO DEBO NOBO Change

Key fundamentals of the regulatory framework The law places obligations on legal entities responsible for performing a function in a certain context/scenario The obligations can be on parties responsible for Designing, manufacturing and selling assets Operating and maintaining the assets and performing related functions/activities For regulating, supervising, enforcing and authorisation/approvals to be able to perform the functions or sell the assets

Objectives of legislation governing the railways Facilitate cross-border train operations Market opening for rail products and services Harmonise Technical and Safety requirements Market opening for rail products and services. Harmonise approval process for authorisations and certifications + Harmonise Technical and Safety requirements – simply tools to achieve market opening Facilitate cross-border train operations, only of secondary concern to GB Harmonise approval process for authorisations and certifications

Obligations as a project Scope of legal responsibilities NOT railway specific Duty as Corporate entity Example: Occupiers’ Liabilities Acts ‘57 & ‘87 Corporate reputation Duty as Employer NOT railway specific Example: Health & Safety at Work etc Act 1974 Example: Railway Interoperability Regulations 2011 Duty as Transport Operator Railway specific Obligations as a project RGSs (National Rules) Welcome to the decision making universe. It is quite important that we understand where decisions are made in the industry and the different responsibilities that one company can have when considering change

Scope of the Legislation CHALLENGE NO. 1: Does the description and boundaries of subsystems in law hinder progress towards autonomous systems? Railway Safety Directive 2004/49/EC Railway Interoperability Directive 2008/57/EC Railway system Railway Undertakings part of the system Infrastructure Maintainers part of the system Combined Subsystems Management System, including SMS Vehicles Combined Subsystems Network Management System, including SMS Telematics applications Maintenance Operations & traffic mgt Subsystems Subsystems Rolling stock On-board CCS On-board energy Trackside Energy Trackside CCS Infrastructure Subsystems Operations & traffic mgt Maintenance Telematics applications Subsystems CCS: All equipment necessary to ensure safety and to command and control movements of trains authorised to travel on the network IC IC Functional areas Structural areas Functional areas

What is expected of the rail system? Railway Safety Directive 2004/49/EC Railway Interoperability Directive 2008/57/EC Article 4(1) of the Interoperability Directive states that: The rail system, subsystems and interoperability constituents shall meet the relevant essential requirements. ‘Essential requirements’ means all the conditions set out in Annex III which must be met by the rail system…….. Annex III sets out the Essential Requirements: CHALLENGE NO. 2: Do the essential requirements hinder an autonomous system performing a function? The electricity/thermal energy supply systems used must: Enable trains to achieve the specific performance levels, In the case of electricity energy supply, be compatible with the collection devices fitted to the trains Safety Technical Compatibility Reliability & Availability Health Env. Protection Accessibility

Beyond high level obligations – where do standards sit? The obligations are given greater granularity via European target system specifications (TSIs) and State imposed National Rules …but the above only address obligations to the extent necessary Additional measures are required to fully meet obligations: Robust Risk Assessment and Management Rule Based approaches via standards Other acceptance principles Parties have other commercial and business obligations and objectives CHALLENGE NO. 3: Do the various specifications hinder progress towards autonomous systems?

CHALLENGE NO. 4: Specify functions and not who/what does it ETCS transmits the information in the form of data but the train driver is still the one who controls the speed of the train based on the available information (albeit with ATP supervision) Currently, the information is codified in the form of signal lights. ATP removes the train driver but the train driving function is still the same How the trackside CCS system contributes to the information needed by the train to control its speed

The scope and force and standards EC Regulations inc. CSMs & TSIs Imposed by law UK Legislation – Acts and Regulations Imposed by licence and law Railway Group Standards (RGS) National Safety Rules National Technical Rules SMS or contract Rail Industry Standards (RIS) Company standards standards Project Legal force European standards (EN) non-harmonised European standards (EN) harmonised Grant ‘presumption of conformity’ Rail Industry Approved Code of Practice (RACOP) Voluntary observation British Standards (BS) Guidance Notes (GN) Guidance Project Company GB Network European Scope of Standards

The scope and force and standards

The scope and force and standards Essential Requirements in the Railway Interoperability Directive 2008 Mandatory Rules - TSIs and NTRs (RGS) Standards directly quoted in TSIs RIS RACOP Guidance Notes BS, EN Company/Project Mandatory Specified in TSIs / NTRs Voluntary Applicant chooses own specification CHALLENGE NO. 5: Standards can be developed which specify characteristics for autonomous to integrate or meet the essential requirements Company/ Project Standards Level of detail

Functional Operator/use Individual system Human operated Human assisted Human delegated Human Supervised Mixed initiative Fully autonomous Structural Manufacturer/design System for systems

Approvals/verification focus Coordination/ Integration/ Supervision Manufacturer/ design Operator/ use A system for systems 1 Designers may assume that humans should not be included in systems because they are unreliable and inefficient. But many operating problems come from designer errors. 2 Automated systems are implemented because they can perform better than the operator, yet the operator is expected to monitor their progress. 3 The operator is reduced mostly to monitoring, leading to fatigue and ineffectiveness. 4 In the long term, automation reduces physical and mental skills of workers, yet these skills are still required when automation fails. In fact, the skills may be in more demand than usual when automation fails, because there is likely to be something wrong, requiring, takeover, diagnosis and recovery. De-skilling also affects workers’ attitudes and health adversely.  So in summary when we are designing these new systems – these are the HF issues we need to grapple with and consider early – it isn’t as simple as saying no humans NO problem – we just move the potential for human error back into the design stage!….. Structural Coordination/ Integration/ Supervision Nature of the system Functional Individual system

Is there a shift/change in Obligations Functions Improved understanding of what introduction of an autonomous system does Is there a shift/change in Obligations Functions Impact in terms of scope or scale The boundary of the change may be wider than the component or the function CHALLENGE NO. 6: Understand the system wide impact of autonomous systems

Ability to monitor, supervise and intervene Is our operation sufficiently safe, or do we need to make a change? We have decided to change something affecting our operation; is the change sufficiently safe? CHALLENGE NO. 7: Can the party on which obligations are placed in the new railway system made up of autonomous parts, REASONABLY ANSWER THESE QUESTIONS?

The seven challenges Does the description and boundaries of subsystems in law hinder progress towards autonomous systems? Do the essential requirements hinder an autonomous system performing a function? Do the various specifications hinder progress towards autonomous systems? Do standards functions and not who/what does it? Are standards being developed which specify characteristics needed in autonomous systems to meet the essential requirements? Is there a full understanding the system wide impact of autonomous systems? Can parties reasonably fulfil their monitoring & risk assessment obligations?

Thank you