0. HM Deputy Chief Inspector (Operations) Office of Rail Regulation
International Railway Safety Conference A regulator’s challenge – inspecting the right things
Allan Spence
HM Deputy Chief Inspector (Operations)
Office of Rail Regulation
Denver, October 2008

1. Office of Rail Regulation
Independent safety and economic regulator for Britain’s railways
Long-term vision for a safe, high-performing and efficient railway
HM Railway Inspectorate is the part of ORR that deals with health and safety
Inspectors gather intelligence that can inform economic regulation too
Economic efficiency and effective safety management are entirely complementary

2. ORR’s role in safety regulation
140 operational staff in 21 offices covering mainline, metros, tramways and heritage railways.
Authorising, inspecting, investigating, enforcing
Public and employee protection
HM Railway Inspectorate changed markedly in 10 years
Move away from prior approval to more structured inspection regime of management systems
Testing risk management not fragmented site-specific spot checks
External scrutiny?
Rail Accident Investigation Branch

3. Safe railway operators?
Authorising Safety Management Systems
Assess the written documents
Challenge
Clear process, trained inspectors, peer review
Proactive inspection to test compliance
Inspection occupies half of all our frontline activity:
50% to Network Rail
25% to (30+) train operators
25% to light rail, contractors, heritage

4. Why do we inspect? Test legal compliance
Validate the Safety Management System
Meet public expectations
Deterrence
Motivate improvement
Ensure equity between duty-holders
Identify and spread good/best practice
Inform and advise
Gather intelligence about:
current risk management
emerging risks
economic efficiency

5. Making inspection effective
Prioritise and structure inspection work
Inspecting practical safety and a slice through the management system
Want re-assurance about the management system:
standards, processes, organisation, resources, competence, supervision and monitoring
Reliably delivering effective risk control - not just when we look, but all the time?
National planning for consistency and effectiveness
Avoid simply reacting to the last accident

6. What to inspect? Risk profile topic strategies
Ensure correct priorities
Transparency on why we don’t do things too
Long term view from data and qualitative intelligence
Set the direction for 3 to 5 years
Used along with dutyholder-specific factors
Long list from safety risk model grouped into 14 topic areas

7. Risk Profile Topics Employee Safety
Health and Safety Management Systems and Risk Assessment
Human Factors
Level Crossings
Occupational Health
Power Supplies
Railway Operations
Rolling Stock
Route Crime
Vehicle and Animal Incursions
Signalling and Telecoms (Command, Control & Signalling)
Stations
Structures
Track

8. The top four Employee Safety Command Control Signalling (CoCoSig)
Level Crossings
Track (including switches and crossings)

9. Structured inspection assignments
Network-wide appraisal
Systemic or common weaknesses
Patterns in low-level non-compliance?
Deal with precursors before risks are realised
Track patrolling example:
S & C maintenance is a priority topic
Grayrigg derailment Feb 2007
Industry investigation concluded a local problem
Structured inspection across all area teams to check

10. Track patrolling example
Numerous but small deficiencies in all areas
Each on its own ‘insignificant’
only a small increased risk that patrolling would fail to identify a critical track defect
No one area had major failings
insufficient to warrant us taking more formal action locally
But national inspection program gave a strategic view
If a number of deficiencies occurred in the same place, at the same time, the increased risk would be significant
So, no evidence of systematic failure in any one location but consequence of them aligning in one place again created a significant risk
Enforcement notice for national improvement

11. Conclusion Significant aid to strategic planning
The right things to inspect
Structured inspections to provide best picture
Better placed for overall appraisal of risk control
Better placed to take regulatory action

12. Allan Spence HM Deputy Chief Inspector (Operations)
Thank you
Allan Spence
HM Deputy Chief Inspector (Operations)