Disabled people's protection policy (DPPP)
Train and station operators are required by their operating licences to establish and comply with a disabled people's protection policy (DPPP) which must be approved by us.
A DPPP sets out, amongst other things, the arrangements and assistance that an operator will provide to protect the interests of disabled people using its services and to facilitate such use.
The 2009 Guidance on how to write your DPPP forms the basis of ORR's review and approval of operators DPPP. Here we provide information aimed at train and station operators about complying with these requirements. Operators should also refer to our July 2014 regulatory statement.
Information for disabled and older passengers, on the types of services they can expect to receive when travelling by train is available on our website in our passengers with disabilities section.
The approval process
Approval of DPPPs for new franchises or new operators
Newly licensed operators or those with new franchise awards must establish and comply with a DPPP. The licence condition sets out the steps required.
In our Assisted Travel consultation from November 2017, we took the view that it is not proportionate to ask licence holders to submit their DPPP policies for annual review and approval where only routine changes have been made.
Licence holders are now only required to submit their DPPP for approval where a material change has been made. Changes are classed as material where they constitute a substantive change to the policy itself and impact on the assistance provided to passengers. Licence holders are still required to confirm to us that they have conducted an annual review, and that there has been no material change (if this is the case).
As per the licence condition, we can require licence holders to submit their DPPP for review where evidence emerges that they are not being implemented appropriately or where we consider a material change has been made without approval.
To allow us to monitor train and station operators’ compliance with the DPPP licence condition, we carried out a large-scale programme of consumer research looking in depth at accessibility and assistance. This gave us a clear picture of passengers with disabilities’ experiences of assisted travel. The research allowed us to build up a strong evidence base to help us prioritise and target regulatory interventions that may be necessary to improve the experience for passengers with disabilities.
Our research focused on the following areas:
- A survey of passengers who have booked assistance. The findings helped to provide insight into passengers’ experiences of the booking process, assistance provision, changing trains, and the knowledge and helpfulness of staff they interact with. It also provided a measure of satisfaction with the overall experience.
- A mystery shop of ‘turn up and go’ (unbooked assistance) checked compliance, at an industry level, with the obligation to assist passengers who travel without booking ahead.
- A survey to measure levels of passengers with disabilities’ awareness of the current Passenger Assist and turn-up-and-go services. This was also used to investigate any potential barriers to travel for passengers who do not use these services and investigate ways in which information about them could best be presented and disseminated.
- A review of train and station operators’ websites to assess the provision and promotion of online assistance information from an accessibility perspective. This provided us with a snapshot of how accessible these websites are to passengers with particular disabilities or impairments.
A mystery shop of turn-up-and-go services
Once we have given our approval to a DPPP, we will publish a decision letter. The letter will summarise any issues that were raised during the approval process, note areas of good practice or highlight areas where we feel a licence holder should particularly seek to improve its practices.
We are also responsible for monitoring licence holders’ compliance with their approved policies. In order to carry out this monitoring, we ask licence holders to submit data which we refer to as ‘core data indicators’. These core data indicators collect a wide range of information. Specifically linked to accessibility, we collect core data indicators regarding:
- The volume of complaints about accessibility received by licence holders;
- Data about the number of journeys for which a Disabled Persons Railcard was used;
- The volume of assisted journeys provided by licence holders; and
- Information about the disability awareness training provided to staff by licence holders.
We will also:
- hold regular meetings with Transport Focus and London TravelWatch to discuss their views and research;
- review additional market research relevant to ensuring disabled people can travel confidently on the railways; and
- on occasion we may require additional information from operators, where possible we intend to rely on the information operators' already produce to monitor and evaluate complaints and their procedures.
A newly licensed operator, or newly awarded franchise, may have limited experience or data on which to develop its DPPP. For this reason, we would expect an operators of a newly approved DPPP to review its effectiveness in providing assistance within a suitable period, to allow for changes in light of experience.
- Letter to Northern re DPPP compliance - 26 March 2019
- Letter to SWR re DPPP compliance - 21 March 2019
- Letter from Northern Rail in regards to compliance issues in a number of key areas affecting consumers - 5 October 2018
- Letter to Northern Rail in regards to compliance issues in a number of key areas affecting consumers - 14 September 2018
- Condition 5 of the Station and Passenger licence: Statement of National Regulatory Provisions (SNRP)
Letter in relation to Condition 5 of the Statement of National Regulatory Provisions for passenger and station licence holders, and the Code on Design Standards for Accessible Railway Stations – joint letter from ORR, Transport Scotland and the Department for Transport.
21 November 2017
- Condition 5 of the passenger and station licences - Disabled People’s Protection Policy (DPPP)
Letter to Govia Thameslink Railway Limited's (GTR) regarding compliance with condition 5 of its passenger and station licence -
10 November 2017
- Licensing general authority
- Rail Delivery Group - Eurostar SNRP modification notice - 6 February 2013
- Modifications to the ‘operators of last resort’ passenger train licences and SNRPS - 29 January 2013
- Notice of modification of Network Rail Infrastructure Limited's network licence - 29 January 2013
- Notice of modifications to passenger train licences and SNRPS - 29 January 2013
- Rail Delivery Group (RDG) statutory notice - 16 October 2012
- Exchange of letters with Abellio UK regarding compliance with Condition 5 of the Station and Passenger Licence: Statement of National Regulatory Provisions (SNRP).
- Information for disabled passengers
- Regulatory statement
- How to write your disabled people's protection policy: a guide for train and station operators
- Disabled Persons Protection Policies (DPPP) industry workshop note – Monday 9 March 2015
- Disabled People's Protection Policy compliance and approval process
18 December 2014
An open letter to all train operators setting out: changes to the Disabled People's Protections Policy approval process; and, areas where some operators may not be compliant with the requirements of Condition 5 of the Passenger and Station licences and the Statement of National Regulatory Provisions.
- Response to ORR's open letter of 18 December 2014, from the Association of Train Operating Companies (ATOC)
12 January 2015
- Summary of DPPP workshop
- Speech by Anna Walker from ORR's workshop on DPPP
- For further information or to speak to us, please email DPPP@orr.gsi.gov.uk.
In January 2014 we commissioned independent research to give us insight into disabled travellers' awareness of the assistance available when travelling by train to inform our work in this area. Links to a summary document, and the full report, can be found below:
- Disabled rail passengers' awareness of assistance from train operators
- Disabled travellers' awareness of rights - report by Accent