Are rules a good way to save lives?

Posted in Off The Rails's blog on Mon, 25/05/2020 - 18:30,
Safety First sign

Network Rail has ten lifesaving rules. These are supposed to be rules for all staff to follow to keep them safe. They are the focus of Network Rail’s staff safety strategy:

1. Always be sure the required plans and permits are in place before you start a job or go on or near the line.
2. Always use the equipment that is fit for its intended purpose.
3. Never undertake any job unless you have been trained and assessed as competent.
4. Never work or drive while under the influence of drugs or alcohol.
5. Always test before applying earths or straps.
6. Never assume equipment is isolated – always test before touch.
7. Never use a hand-held or hands-free phone, or programme any other mobile device, while driving.
8. Always obey the speed limit and wear a seatbelt.
9. Always use a safety harness when working from height, unless other protection is in place.
10. Never enter the agreed exclusion zone of machinery unless directed to by the person in charge.

These rules are, quite obviously, all reasonable enough. But the whole approach ensures the focus of NRs safety strategy is on the individual. This is despite time and again reports and investigations highlighting systemic management failure to put in place safe working procedures.

Agreed railway industry practices for risk assessment and reduction are based on a hierarchy of strategies for mitigating risk. The first level is to engineer risk out of the equation. For example, it is always safest to work on the tracks when all train movements have stopped. The second level is technological solutions, like automatic warning systems to alert track workers to approaching trains. The third and final level is human based solutions – rules, training, assessment, and judgement.

Where the first level of risk mitigation can be practicably adopted it should be used. If it isn’t practicable then we progress to the second level. Where that isn’t practical, we resort to the third level. Reliance on training people to follow a set of guidelines should be, on paper, the last resort for managing the risk to staff. People are human and make mistakes. It is not reasonable to expect people to work continuously in an environment where a mistake can have such horrible consequences. Over time mistakes will always happen.

The focus on the lifesaving rules gives managers who should be responsible for ensuring work is done safely an obvious way out of having to do so. Time and again investigations highlight problems with NRs processes for ensuring workers are protected when on the tracks, but if we assume no one will break a lifesaving rule then what does it matter? Anything unsafe would be challenged under rule 1 so why fix the planning procedure, thinks the manager. And if anyone does end up getting hurt then they obviously broke rule 1, so really it was their fault and what more could be done…

Clear, easy to understand, guidelines for how to stay safe are obviously very important. However they are only a small part of keeping staff safe. Exhortations to follow the rules are particularly galling after each investigation into safety incidents shows basic standards for planning of work not being adhered to. It transfers the onus to challenge unsafe behaviour from those with the most power and influence in the organization to those with the least.

Trade Unions

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