Bob Hammer gives his thoughts on the Office of the National Safety Regulator’s major projects guidelines released late last year.
I read with interest the guideline recently released by the Office of the National Rail Safety Regulator [note] Major projects guideline version 1.0, 14 November 2014. Office of the National Rail Safety Regulator, Adelaide.[/note] and thought that the advice provided in the document applies as much to small projects as to large ones.
In fact I suspect that sometimes the smaller projects may be more at risk than large ones because they do not generate the same level of scrutiny.
One of the reminders in the guideline is that designers, manufacturers, suppliers and constructors of railway assets (regardless of the size of the project) have significant legal responsibilities. Section 53 of the Rail Safety National Law requires that (in my words), subject to the ‘so far as is reasonably practicable’ test, these persons must ensure that whatever they are designing, supplying, manufacturing and/or building is safe, be able to demonstrate that it is safe and to provide the necessary information to enable the asset to be operated and maintained safely.
Although smaller rail projects are usually delivered under the management of and in compliance with the accredited rail transport operator’s safety management system the legal responsibility remains with the designer, manufacturer and/or supplier.
The guideline also states that “good practice dictates that effective risk-based system engineering and safety assurance processes should be implemented”.
Again, good advice for smaller projects provided that the processes are sized to match the level of risk within the project.
A question I like to pose is “How will I know that the asset delivered by this project will be safe to operate and maintain?”
From my experience, the sooner that question is asked and answered through the establishment of a safety assurance process the better the chance of delivering the project without major issues.
Another piece of good advice in the guideline is to consider the requirements of the operator and maintainer throughout the project lifecycle. I would go further and suggest that the operator and maintainer should be active stakeholders throughout the development, design and delivery process.
This helps to ensure that the asset can be safely operated and maintained after it is delivered.
I observed one major station upgrading project in Sydney that placed the platform lighting on a high canopy directly above the edge of the platform. The lighting outcomes were great, but in order to change a light fitting the maintainer now has to get a scissor lift onto the platform (no mean feat in itself), stop trains from running and turn off the traction power.
I suggest that the maintenance issues were not adequately considered during design!
I was fortunate to work on the design and delivery of the Airport Line in Sydney.
This was one of the first rail tunnels in NSW that did not include personnel refuges within the tunnel, meaning that maintenance workers were not permitted to enter the tunnel while trains were running (in itself a significant safety improvement).
The maintainer and the operator were very heavily involved in the design process and we were able to ensure that as much equipment as possible was placed in the stations where it could be maintained safely rather than in the tunnels.