Background

Different parts of the Business have been told different stories regarding the benefits and purpose of Section 15.  DRACT submission advocates Section 15 as a single rule set, necessary to replace existing Possession procedures, including end on for Night Time running.  The Access Transformation Project promises increased time on tools, 30–60 minutes more working time, again necessary to deliver Night Tube.  When challenged about how unrealistic this was, Management informed staff that it wasn’t about working time, but better planning and control.  An attempt perhaps to regain control that was lost when CPD made most SABRE bookings “generic” in nature, to cut jobs in the planning department, which made it possible for staff to attempt to book into Specified Areas/Possessions.  A new process to allow last minute/poor planning to go unseen, hidden within Possessions.  He told Kebba Jobe (RMT Service Control) that Section 15 Would be used to permit things such as re-lamping, running new cable for upgrades, minor work to maintain line side equipment … it would be extremely unlikely that Section 15 would be used for larger works.”  This is the polar opposite of what Management told TAC’s; it wouldn’t be used for routine maintenance and most worrying that they had no cause to be concerned for their survival.  Perhaps the most useful insight into the rational behind Section 15 can be found in the ATP Transitional Safety Risk Assessment, compiled by Management.  This concentrates on the perceived benefits of Permissioning.  Last train issues (caused by CPD’s inability to publish this information correctly), and the can be eliminated by Permissioning.  Taken from the RA, concerning the perceived potential for signallers to misroute trains in complex areas; By September 2015 London Underground will be in a position to always “permission contractors onto the track” through a possession master, rather than LC/LS procedures (Section 15 possession). 

3 months into the trial, Section 15 has predominantly been used for mini BTR’s and other significant pieces of work such as the RAM’s project.  But it has also been published to facilitate routine maintenance.  SUP have been told to base their contracts for resignalling the sub-surface on all work being carried out in Section 15 Possessions, Management confirmed this at a presentation to TAC.  Experience of resignalling on Northern / Jubilee line demonstrates this will be a huge undertaking, probably the biggest ever LU signal project, requiring several Section 15 Possessions each night. In addition CPD have embarked on a trial with the intention of converting all Specified Areas into Possessions.

LUL Track Access Controllers, through its Power Control colleagues, have firsthand knowledge of when traction current is actually switched off and when Service Control authorises switch on.  They are also aware of the call back times given within these Possessions, from staff who book on with TAC across the boundaries.  There is no evidence that working time has increased, on the contrary in some locations it has been reduced.  Any claims of increased productivity can only be due to using more staff and equipment, or being better prepared to work in the short time available.

In order to address a problem of its own making, CPD are implementing a procedure introducing many other risks instead.  Line Clear / Line Safe protection has an exceptional safety record, which could be compromised by the proliferation of Section 15 Possessions across the Network.  Attempts by staff  to raise concerns through all usual channels have for the most part been ignored. These concerns have only recently been taken seriously by the Engineering Branch of the RMT, whose members are most at risk of having their safety compromised as a result of these changes.

Safety concerns fall into 2 main categories; work site controls and impact on existing process.

Work Site Controls

Until recently there would have been about 12 Specified Areas around the Network on weeknights; each confined to a small exclusive area, where no-one else could gain access except in an emergency.  Each Specified Area will now become a much larger S15 Possession; e.g. train originally booked 08/06/15 to work between Moorgate and Angel, became a Possession; Euston (City) sub-gaps to Kennington sub-gaps, All.  Under S15 principles whole Traction Current Sections must be taken; thus affecting much greater areas with much greater impact on other work.  To avoid taking weekend Closures, which will impact on Night Tube, more work will be carried out on weeknights.  Including mini BTR’s which use numerous trains and mechanised vehicles in hazardous worksites.  Larger Possession areas allows flexibility to move trains / vehicles around without the detailed planning involved in Specified Areas; staff have no visibility of where these are actually working, which could change at short notice anyway.  Staff less able to plan work to avoid sites where trains/vehicles are working, will be increasingly forced to working within Possessions with these hazards present.

Previously other staff would have been kept away from such work, not permitted access within a Specified Area or Possession. The purpose of a worksite for Engineers Trains / Mechanised Vehicles was to exclude access to anyone other than those undertaking hazardous work. But such is the pressure to squeeze 7 nights work (plus weekend shutdowns) into 5 to enable the Night Tube; previous controls have been covertly changed without following due process. Evidence suggested other work was being allowed to take place in the same worksites as hazardous work was taking place.  Patrols and routine maintenance have continued in the BTR worksite on the Heathrow branch, which has been running nearly every night for 3 months.  Ultrasonic defects have been found and fixed, around train movements.  Safe segregation of staff and machines has not been documented in Possession Works Guides, to rail industry standards.  This has been confirmed in a “clarification” to the OSP on 25/06/15 which now says; Provided all work has been planned to safely co-exist, whether or not the worksite involves train(s) or rail mounted mechanised vehicle(s), separate work groups are permitted to share one worksite.  This is the polar opposite of what Management told staff that when this concern was raised at a team talk he attended. The long standing purpose of having separate worksites within a Possession is totally lost if any work can take place within them. The safety of staff carrying out maintenance and unrelated work within the same worksite as Engineers Trains / Mechanised Vehicles is now reliant on ad-hoc controls being imposed by staff on the ground, instead of being locked into separate documented worksites.  Increased risk of staff being struck by engineers trains / mechanised vehicles.

Another significant change, made by means of a “clarification” to the OSP on 25/06/15, is to allow Sections within a Possession to be switched of progressively instead of taking current off from the whole area simultaneously.  After the passage of the last train, this can either be consecutively requested for each traction current section, or all sections can be requested simultaneously, as determined when planned.  Service Control are now required to progressively protect areas as they are being switched off, with trains still running, as opposed to simply protecting the whole published Possession area when all train movements have ceased.  It also has an impact on Possession Master who, based on hand written records, can permission staff onto the track within a Possession where traction current may still be alive in part of it, with trains running.  This process is outside of any existing Rule Book Possession procedures, or existing training standards, raising new concerns.  Both have safety implications above and beyond the scope of the original OSP.  Risk of staff being inadequately protected within partly taken Possessions.

Section 15 is driven by the Contractors desire to control access, in the manner they wish, forcing everyone else work around them.  It is incestuous that the Rule Book team now resides in the same part of the organisation responsible for delivering projects, making it possible for this to happen, without following due process and proper consultation.  A building site type culture is being introduced to replace the existing controlled Engineering Hours environment, increased risk to staff accessing the track.

Impact on existing process

Service Control POM/SPC’s do not have the tools to manage bookings in the same manner that the present Track Access Controller do using CTAC, increasing the risk of clerical error associated with booking staff onto wrong sections, missing call back times and managing overruns.  The transformation of Specified Areas into much larger Section 15 Possession areas, plus other major works undertaken in this manner including sub-surface resignalling, will result in increased numbers of staff being forced to work within Section 15 Possessions instead of booking on with the TAC. At present the TAC manages access for up to 900 groups of staff at night using a bespoke computer system designed to a Safety Integrity Level.  Any transfer of workload from the computer system to paper increases the risk of clerical error.  Risk increases proportionally to the number of Section 15 Possessions taken each night.  Section 15 introduces an increased risk of clerical error, with potential to place staff in danger of electrocution/being struck by train.

Service Control/POM/SPC’s do not have tools to check the validity of licenses of the staff they are protecting (staff uses computer to interrogate SCL database; statistics show these checks are worthwhile).  Creating risk of staff being allowed to undertake roles they are not licensed to do, or for which they have been barred.  An allegation strongly refuted by Management at a JNP H&S forum, but subsequently corroborated by evidence from Service Control and Protection staff.  Section15 will result in a reduction in existing safety controls.

The concept of staff working in a Possession simply booking on with POM, as shown in Management’s risk assessment, is in truth more complicated because responsibility for access within each worksite rests with individual SPC’s.  As a result staff working over a large area (patrolmen, litter pickers, etc…), can find themselves coming under the protection of the POM, one or more SPC’s, in addition to TAC for areas outside the Possession.  These complex arrangements increase the risk of staff becoming confused and making errors taking/clearing protection.  Already there is evidence it will be more difficult to safely manage existing Line Clear/Line Safe procedures in areas surrounding Section 15 Possessions. EIRF 60817 raised by staff on 01/07/15 involved staff working in these challenging circumstances, which caused problems to TAC process. On that occasion a group of staff were not even given a call back time to work within the Section 15 Possession.  Another EIRF (60798) was raised on 30/06/15 when a member of staff working in a Section 15 Possession tried to clear his protection with the existing TAC’s.  Section 15 process creates increased risk of staff being inadequately protected, situation compounded by Engineering Hours procedures applying in surrounding areas.

Where Section 15 is used at night, with no trains running, no Banners are placed at the Possession limits.  Gives rise to the possibility of staff accidentally walking into the Possession from adjoining areas under Line Clear/Line Safe protection (TAC records demonstrate staff are often denied access through unfamiliarity with sub-gaps at complex locations, such as Northfields).  While this is also a feature of Section 13 protection, the banners are only missing for a short time, at weekends when there are few staff working in surrounding areas.  Since Section 13 was created, the NEPA was introduced, which has caused problems with staff failing to highlight Possession limits.  As a result TAC insisted markers were placed for the Section 14 trial.   Lack of Possession limit markers creates risk of staff accessing the Possession area in error.

Since the introduction of the NEPA there has been an increase in the prevalence of staff trying to book into Possessions.  Until recently the exact areas affected by Possessions were not shown in the NEPA.  Evidence is now emerging (from denied bookings in CTAC), that staff are confused about the extent of Section 15 Possessions with impact on TAC delivery.  They find it difficult to assimilate whether the station they wish to work at lies within the Possession area, which runs from sub-gap to sub-gap.  This is likely to increase as more Specified areas, which are usually from station to station, are converted into Section 15 Possessions.  These same people will now need to arrange protection in more complex situations involving POM/SPC/TAC.  Previously most staff were trained to avoid Possessions, in future they have to work in them.  No training/familiarisation has been given in what is a fundamental change to protection principles.  Section 15 process creates increased risk of staff being inadequately protected, situation compounded by new procedure being poorly delivered.

OSP does not take into account access for LU Operational Landlord responsibilities presently undertaken using Engineering Hours Track Access.  Rule Book 22, Section 3.3 specifically prohibits access within a Possession.  The Heathrow Possession has been running nearly every night for 3 months, making it almost impossible to safely fulfil Landlord responsibilities within existing rules.  Operational staff will be forced to work in Possession worksites, in close proximity to hazards that existing rules are designed to protect them from.  Section 15 introduces risk of Operational staff being struck by engineers trains/mechanised vehicles.

Records held on paper scattered around the railway with POM’s and EIC’s will increase the time to manage incidents.  The safety and operational benefits of centralised Command and Control in LUCC will be lost, particularly for incidents which extend over large areas or involve more than one line.  Section15 will result in a reduction in existing safety controls.

Traction current switching arrangements in Section 15 Possessions are fundamentally different to Engineering Hours (TAC involved in some areas and the Controller in others).  Running both processes side by side introduces risk of human/communication errors.  Section 15 Possessions can now randomly appear anywhere on the Network taking the place of Specified Areas, changing on a nightly basis.  Power Control staff have expressed concerns about making switching errors, the consequences of which are unimaginable.  Risk increases proportionally to the number of Section 15 Possessions taken each night.  There have already been two instances where Power Control staff thought messages to switch on at SOT would come from TAC when it should have been the Controller, as a result of not being briefed as prescribed in the OSP and inadequate publications. TAC EIRF’s 60459 (08/06/15) and 60795 (30/06/15) refer.  Section 15 has introduced more complex switching arrangements, therefore increased risk of error, with potentially serious consequences.

Concerns raised by Power Control about Controllers handing over Sections within Section 15 Possessions in bulk (when Possession clears), as opposed to TAC passing messages individually 5 minutes before switch on time, have not been addressed.  In the event of access being needed in an emergency in the intervening time, or Sections needing to be held to protect overrunning work outside the Possession area, the Controller needs to retract messages previously given.  Otherwise traction current will be switched on at the published time regardless.  Section 15 process is not as robust as Engineering Hours rules, does not fail safe under these conditions.  Risk increases proportionally to the number of Section 15 Possessions taken each night.  Section 15 increases risk of human/communication errors in managing switching arrangements.

Managing switching arrangements for  unpublished events/incidents also becomes more complex; Premature discharge, Track Alive, sleet train running, early switch on, holds for overruns/implementing Buffer Sections….  With the exception of emergency switch on, these events are not covered by the OSP.  Lack of process, compounded by the complexity of running both procedures simultaneously in a random manner across the Network, will lead to human/communication errors.  Risk increases proportionally to the number of Section 15 Possessions taken each night.  Incident management becomes more complex with the introduction of Section 15, therefore increased risk of error, with potentially serious consequences.

At present staff are able to manage incidents such as Track Alive using CTAC and team working, allowing several TAC’s to be used simultaneously to contact protection staff in an emergency, thus reducing the time staff are exposed to whatever risk is present.  Section 15 POM does not have the facilities to do this.  Furthermore the chain of command under Section 15 is increased as a result of staff within each worksite coming under the control of individual SPC’s.  Section 15 will increase response times during incident management, with increased risk to staff on the track.

Another significant change, made by means of a “clarification” to the OSP on 25/06/15, is the introduction of a process to allow traction current to be switched on in an emergency inside the published Section 15 Possession area.  Previously OSP was “clarified” to prevent current being switched on before the published time, as that affected the integrity of Engineering Hours protection outside the Possession.  Poorly worded it assumes current will also need to be switched on outside the Possession area, which won’t always be the case.  Process should mandate the Controller to consult with TAC, to request Special messages if required, or obtain assurances that staff working outside the Possession will not be put at risk if traction current is switched on unexpectedly within the Possession.  TAC may also need assurance that mitigation has been put in place to prevent any train leaving the published Possession area, to protect staff on abutting Sections.  In order to prevent any misunderstanding TAC have obtained assurances from Service Manger that this process will not be carried out without first discussing with TAC; EIRF’s 60718 (24/06/15) 60793/4 (30/06/15) refer.  Clarification to Section 15 OSP creates risk to staff outside Possession area from traction current being switched on in an emergency.

The Risk Assessment that presently underpins the trial is based on the premise that it is not possible to address last train publication issues.  It goes into detail on the perceived benefits of “Permissioning”, but does not properly identify or evaluate the risks arising from introducing Section 15 (other than a few Power Control issues).  It has not been carried out to Company standards.  It contains no “access subject expert” / formal HSE input; as a result its conclusions are not sound or objective.  Union reps from Engineering Departments have been excluded, despite the fact it is their staff whose safety is most at risk from such significant changes to access procedures.  Section 15 risk assessment does not address the relevant safety issues arising from the introduction of Section 15.

Finally, there is no confidence that CPD will deliver Section 15 safely.  Given their poor track record with the NEPA, quality of publications, planning failures, other access “improvements” in recent years….