Goal Setting Principles for Railway Health and Safety: Draft Appendix for operation of passenger trains in Unattended Train Operation configuration

This document, reissued by ORR in 2017, sets out fundamental principles to be considered when setting up, operating or changing a railway.
 
The introduction of increasing levels of automation into railway operations has brought into focus the need to make clear the considerations to be made when introducing automated trains and railway operations.

Although GOA4 UTO (Grade of Automation 4 - Unattended Train Operation) currently has limited application in the UK, primarily the airport people movers at Heathrow, Gatwick and Stanstead, We have developed factors for consideration on the basis of GOA4, as it focuses on the key safety aspects that must be addressed. 

Dutyholders introducing GOA2 and GOA3 levels of automation will have clear indications of the factors to be considered for these grades of automation in light of the factors necessary for GOA4 - the most complex level.

The starting point used to develop the factors for consideration is that a GOA4 UTO train must at minimum be capable of providing the same level of safety as a train operated by a human train driver, notably in relation to safe stopping at and departure from a platform (for example platform-train interface safety) and safety from collisions with obstructions in the guideway.

In line with the GSPRHS the draft appendix expressly does not seek to set out solutions to be adopted. For example, reference is made to Platform Edge Doors (PEDS) but ORR has sought to make clear that this also means any equivalent means of protecting the platform-train interface (PTI) from obstruction. 

We consider it is best left to dutyholders to identify and develop solutions for achieving a safe PTI in line with the hierarchy of controls specified in the Management of Health and Safety at Work regulations 1999.

We are seeking consultees views on the Factors for Consideration and in particular on the following. 

1. We have focused the supplement on the issues identified in BS EN 62267:2009 “Railway applications. Automated urban guided transport (AUGT). Safety requirements.”
   1. Do you agree with this approach?
   2. If you disagree please provide your reasons.
2. Do you agree with our intention to publish such Factors for Consideration dealing with automated systems operating to the GOA4 principles as a supplement to the existing Goal Setting Principles for Railway Health and Safety?
   1. If you disagree please provide your reasons.
3. If you agree with our approach to publish a supplement, do you believe the factors for consideration developed in the supplement suitably and sufficiently address the operational safety issues associated with safe operation of a train in UTO (unattended train operation) mode.
4. Do you consider there are issues that are not included in our draft supplement that you believe should be included. 
   1. If you believe there are such issues please identify them and set out your reasoning in each case.
5. Do you consider there are issues that are included in our draft supplement that you believe should be excluded. 
   1. If you believe there are such issues please identify them and set out your reasoning in each case.
6. Are you aware of any ongoing research, trials, or other innovation work that might change expectations on the reasonable practicability of delivering safety systems to support GOA4 UTO operations? Particularly if the outcome of that work might require modification of our draft factors for consideration. 
   1. Please provide details where further information on such work can be obtained.

We do not believe that the matters being consulted make fundamental change to the existing position in terms of equality obligations. Nonetheless we will carry out an Equality Impact Assessment upon closure of the consultation and receipt of comments. 

We plan to publish all responses to this consultation on our website.

Should you wish for any information that you provide to be treated as confidential, please be aware that this may be subject to publication, or release to other parties or to disclosure, in accordance with the access to information regimes. These regimes are primarily the Freedom of Information Act 2000 (FOIA), the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA) and the Environmental Information Regulations 2004.

Under the FOIA, there is a statutory code of practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence. In view of this, if you are seeking confidentiality for information you are providing, please explain why. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on ORR.

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