The RMT response to Section 15 Possessions has been straightforward and forthright. We DO NOT intend to let a cost cutting agenda affect our safety at work. LUL and Tubelines have been notified of our concerns and urgent talks are being arranged for Thursday to address our concerns.
What is a Section 15 Possession?
LUL have always used to possessions to do work on the Railway. They are clearly defined and have rules regarding how they are used and access. In an attempt to cut costs, Section 15 of the Rule Book was changed to dumb down possessions instead of booking track access with the TAC. This is compounded by allowing all work to be undertaken with little training and a lack of control. It is clear that possessions are currently potentially unsafe and there is company wide confusion by the introduction of Section 15 Possessions.
So what is it that RMT members are so worried about?
There was a recent incident on the Piccadilly Line and LUL have investigated this and concluded this was NOT a section 15 issue? Below are the LUL bulletin and report.
Why are we NOT happy?
HSE Bulletin 1 in 2016 – attachment
The truth is simple
WOULD THIS HAVE OCCURRED IF THE MEMBERS OF STAFF HAD BOOKED OUT WITH A TRACK ACCESS CONTROLLER (TAC)? THE ANSWER IS NO. At most, the PWT-EH would have been barred.
In a rush to cut, cut and cut, LUL are risking our lives with a flawed process to replace booking out with the TAC. The risks are to us; to my life and to yours. We are balloting because we are truly worried that someone may well die.
Our union will do anything for its members and our members will not stand by and risk being sent home in a body bag
Below is what our reps felt was wrong with the incident at Hounslow and with Section 15 Possessions in General:
- There’s an inadequate number of protection staff
- They’re run by protection staff who do not know their job or are not aware of possession (section 15) procedures.
- Evidence that possession staff who do not follow the rule book and regularly carrying out tasks that are not permitted
- Possession Planners write plans that contradict the rule book
- Management are not reviewing possessions as the failings highlighted have been occurring for some time.
- Staff wanting access are not aware of section 15 procedures
- The is no training, limited briefs and limited access to information.
- Work sites are not defined as per rule book or possession plans/work guides, staff probably don’t know they’re actually accessing anything other than a routine possession.
Our H&S Rep’s Recommendations
Training and planning
- The company’s accept that staff are not adequately trained in Section 15 processes, they therefore should be halted immediately and all possessions should revert to pre-Section 15.
- LUL should return to the table and start meaningful discussions with all concerned.
- The TAC’s are tried and tested and need to be retained in its current format
- All staff to be fully trained in ALL Possession Procedures and are added to all PWT training and not just limited to POM courses.
- Selected Managers/ Reps from departments involved (those who will be briefing staff, not as a cascade format) will be invited and required to attend a briefing held by “safety training team” on Section 15 Processes. These briefings are not to be instead of formal training.
- Stop blanket booking areas as a “section 15” to skirt around the rule book.
- Keep it as a normal Possession for single large works or book out with the TAC.
- All briefings on section 15 nightly access in be a face to face format, (not via phone or email publication)
- Review of all current possessions and planning processes, including TBTC, rule book, specified areas, EVs etc.
- Service control cannot be responsible for all staff track access. All protection should be carried out via TAC as stated previously.
- Inadequate risk assessments and case for safety.
- Those authorising must sign (not electronically) the associated paperwork and not just because signature box ‘A is complete. This makes us concerned on who many purely are relying on others, of those who sign and do not actually read the plans.
- Possession staff to have certificates confirming what sections they are authorised to protect.
- Review of how less experienced staff are exposed to new areas.
Section 15, Possessions and work sites
- No blanket booking areas as a “section 15” to skirt around the rule book.
- As per rule book, only published works (or emergency works) can take place. Therefore NO opportunistic works. Only published works .
- All emergency work must be briefed to those planned work groups to avoid conflicts and there must be no opportunistic work
- SACs should be located within its worksite, not within another work site.
- Review of PICAD wording and usage to include “do not access site until you have had an Work Site Site Person in Charge (SPC) briefing” and signature box alongside associated work group SPC signature.
- 22:00 safety briefings at Pelham St are to be monitored and enforced. All protection staff and staff associated to site safety are to attend.
- All staff associated to works within possessions to be given 24 hrs notice and access to Work Group and plans (Not just email link).
- POM safety briefing to adopt PWT style safety briefs.
- All work departments accessing possession to attend. (Time or even day to be discussed)
- Too often POM staff turn up at 01:30 disregarding safety and staff requesting information.
- POM to be on site at all times and in a location described in the plan. (Not just an auto number). Clearly defined at possession access point.
- All site paper work to be official with those monitoring to sign and submit.
- Possession SAP emergency stickers to be re-introduced or coloured hard hat stickers etc Clearly identifies those who attended briefings.
- Each worksite to be assigned a protection master who remains at SAC. Point of contact for POM. SPC and SAC liaise directly to PM.
- Each worksite to be clearly defined, with clear access to Work Guides, possession plans and map of work sites.
- Post possessions, all paper work to reviewed for safety and ensuring procedures are followed. Results to be distributed to all LUL departments and TUs.
- 1/4 audits of all possession plans and processes to ensure they are still fit for purpose.