Article
citation information:
Helak, M., Smoczyński, P.,
Kadziński, A. Implementation of the common safety method in the European Union railway
transportation. Scientific Journal of
Silesian University of Technology. Series Transport. 2019, 102, 65-72. ISSN: 0209-3324. DOI: https://doi.org/10.20858/sjsutst.2019.102.5.
Magdalena HELAK[1], Piotr
SMOCZYŃSKI[2], Adam KADZIŃSKI[3]
IMPLEMENTATION OF THE COMMON SAFETY METHOD IN THE EUROPEAN UNION RAILWAY TRANSPORTATION
Summary. Change management is considered to be
an important element of safety management systems, lack of which can lead to
industrial accidents and disasters. Therefore, risk management related to
changes introduced to the railway system has become one of the processes
covered by regulations aimed at harmonising the rules of railway transport in
the whole European Union (EU). This article presents the results of a
comparative analysis of available source materials in terms of determining the
manner and level of implementation of EU-wide rules for risk management related
to introduced changes. The analysis was based on data from five selected EU
Member States. A common issue raised in practically all of the reports analysed
is the lack of detailed definitions of terms such as significant change, insignificant
change, the impact of change on the safety of the railway system. Attempts to
solve this situation have been specified by us and evaluated from the viewpoint
of safety engineering.
Keywords: change management,
safety management system, railway undertaking, railways
1. INTRODUCTION
The main document regulating the
railway system safety at the level of the entire European Union (EU) is the
Railway Safety Directive 2016/798 (RSD). It states that ‘safety should be
generally maintained and, when practicable, continuously improved, taking into
account technical and scientific progress, and the development of Union and
international law’, which is to be achieved using common targets,
indicators and methods of safety in rail transport. The RSD clearly indicates
that the responsibility for the safety level of the railway system rests with
infrastructure managers and railway undertakings (carriers), without excluding
entities cooperating with them, such as producers, maintenance entities,
disposers, service providers and sub-suppliers. To analyse the data collected
and evaluate the progress achieved, in 2004, the European Railway Agency was
established, which in 2016 was replaced by the European Union Agency for
Railways.
Common Safety Targets (CST) set the
limit values of certain indicators defining the level of safety, both of the
railway system as a whole and of individual aspects of its functioning.
Achievements of specific EU Member States in the implementation of CST are
indicated by the EU Railway Agency, based on the so-called National Reference
Values (NRV) for each Member State. Each EU Member State is obliged to
constantly monitor the safety level of its part of the EU rail system, both in
achieving CST and calculating values of Common Safety Indicators (CSIs). These
indicators form a set of data describing the safety level of the railway system
in a given EU Member State, and also provides information about this system and
its economic conditions, for example, about the costs of delays.
Common Safety Methods (CSMs) are
defined as methods that should be developed to describe ways of assessing the
level of safety and meeting the requirements in this regard. It could be
achieved by developing and defining guidelines for:
-
risk assessment methods.
-
methods for assessing compliance with requirements in safety
certificates and safety authorisations.
-
methods of monitoring the level of achieving the assumed level of
safety.
One of the areas that was decided
to unify within the entire EU was the process of introducing changes to the
railway system, and in particular – the process of managing the risk of
hazards related to changes. Change management is considered to be an important
element of safety management systems and the lack of which, according to Takeda
et al. [12], is one of the main causes of
accidents. This opinion is also shared by Gerbec [6] who believes that changes in safety management systems carried
out in an uncontrolled manner have caused many industrial accidents and
disasters. He also indicates along with Levovnik [11] that problems related to correct change management in safety
management systems are hidden, and change management itself is more important
for safety than is considered in the industry and scientific literature. At the
same time, safety management systems must be adapted to the dynamics of
continuous changes, the intensity of which has never been as great as it is
today.
Change management in the railway
system is a topic much researched by many authors. However, these are rather works
focusing on presenting the binding formal and legal requirements [1, 8] or the role of assessment bodies [9], less frequently concern the application of
change management in practice [2, 7, 13].
The purpose of this article is to
analyse available materials in terms of determining the manner and the level of
implementation of EU-wide rules for managing the risk of hazards related to
introduced changes. Section 2 describes the relevant regulation and the source
materials used. Section 3 presents the information obtained in the course of
analysis with reference to several selected EU Member States. The comparison of
this information, their discussion and the conclusions from it are described in
Section 4.
2. MATERIALS AND METHODS
2.1. Common Safety Method for risk
assessment and evaluation in rail transport
One of the documents
belonging to a set of Common Safety Methods is a regulation commonly referred
to as ‘CSM RA’ (Risk Assessment). It was adopted at the European
level in the form of Regulation 352/2009 and then replaced with a new version
via Regulation 402/2013, that has been partly changed and completed two years
later. In these documents, the term ‘safety’ is understood as
‘freedom from unacceptable risk of harm’.
The aim of the CSM RA is
to harmonise the activities of entities operating on the railway market in the
following areas [2]:
-
risk management processes, including obtaining risk-related evidence.
-
exchange of safety-related information between various railway
undertakings.
In the CSM RA for the
first time, the concepts of significant change, technical change, operational
change, and organisational change, but their detailed definitions were not
given. The use of the CSM RA is mandatory for railway undertakings,
infrastructure managers and entities in charge of maintenance. Other entities
may use the CSM RA as part of good practices. The following stages of risk
management according to the CSM RA can be listed:
-
analysis of the significance of change.
-
risk management process.
-
independent assessment.
-
risk supervision and audits.
-
monitoring and feedback.
Changes of operational,
technical and organisational nature (if they have an impact on safety) are
assessed according to the criteria specified in the CSM RA. It is recommended
to start activities related to risk management at the earlier stage of
developing the change. At the beginning of the process, it should be assessed
whether the change has an impact on safety. If there is no such impact, no
detailed assessment according to the CSM RA is needed and the change can be
implemented into the railway system.
If the change is
considered to have an impact on safety, it should be determined whether it is
significant or insignificant. The CSM RA provides for the possibility of
applying national provisions that determine the significance of a change. If no
national rules have been established, the criteria listed in the CSM RA are
used to indicate the significance of the proposed change in the system:
-
consequences of system failures: a credible worst-case scenario in the
event of failure of the system under evaluation, taking into account the
existence of safety barriers outside the assessed system.
-
innovation used in the implementation of the change: both for the entire
railway sector and for the entity introducing the change.
-
the complexity of change.
-
monitoring: inability to monitor the change introduced during the entire
system life cycle and to perform appropriate interventions.
-
reversibility of change: inability to return to the system before the
change.
-
additionality: assessment of the significance of the change, taking into
account all recent changes in the system under consideration, which were
related to safety and were not considered as significant.
If the change is
considered significant, the next step is to assess the risk of hazards related
to the introduction of changes in the railway system and then to determine how
to respond to the risk, including its monitoring.
If the change is
considered significant, the assessment of the adequacy of the risk management
process carried out with the requirements of CSM RA is performed by independent
Assessment Bodies (AsBo). It is worth adding that AsBo should not assess the
substantive scope of the change (for example, its justification), but focus
only on the assessment of compliance of the carried out and documented risk
management process with the requirements of the CSM RA.
2.2. ERADIS database
The EU Railway Agency
publishes data on the railway safety and interoperability in a specially
prepared on-line database ERADIS (European Railway Agency Database of
Interoperability and Safety) [4]. In the
ERADIS database there is, for example, information about the national safety
authorities, competent in matters of railway transport in a given Member State,
or about safety certificates issued to railway undertakings. The database also
publishes annual reports on railway transport which every EU Member State is
obliged to send to the EU Railway Agency every autumn. An obligatory part of
the report is information on the use of CSM RA in two areas:
-
experience of national safety authorities.
-
feedback from railway entities.
As part of the research
works described here, an analysis of the content of the 2016 reports published
in the ERADIS database by five EU Member States: Belgium, Czech Republic,
Germany, Italy and Poland, was carried out. Data on the length of railway lines
and transport performance in the analysed Member States were presented on the
basis of Common Safety Indicators provided by these States, available in the
database [5, 10].
3. RESULTS
3.1 Belgium
In 2016, about 97.1
million train-kilometres was performed in the Belgian railway system, of which
over 80% was for passenger transport. The Belgian Safety Authority issued 21
safety certificates. The function of Entities in Charge of Maintenance was
performed by 5 organisations [4].
The length of railway lines is 97,105 km. Two organisations perform the
functions of AsBo – Belgorail SA and Viattech Q&S.
The Belgian Safety
Authority emphasises that the change proposers do not pay sufficient attention
to the analysis of interfaces with other actors of the railway system. The
second aspect to which attention is drawn is the weak argumentation of the
proposers regarding the significance of the changes they evaluate. The idea of
developing a list of generic changes that should be treated as significant in
the three railway subsystems (rolling stock, infrastructure and railway
undertakings) is now under consideration.
3.2 Czech Republic
In the Czech Republic,
117 safety certificates for railway undertakings were issued and 34 entities
acted as certified Entities in Charge of Maintenance of freight wagons. In
addition, 7 organisations are entitled to act as AsBo. The length of Czech
railways, one of the densest in Europe, is 162,000 km.
The Czech Safety
Authority requires applicants to attach safety assessment reports to changes
affecting safety and to be assessed in accordance with the CSM RA. In this way,
the supervision over the quality and level of correctness of results generated
by the AsBos is carried out.
In the Czech Republic in
2016, a total of 104 changes was reported. As in Belgium, the National Safety
Authority had doubts about the correctness of the results of the change
assessment. Proposers were requested to state whether the implemented changes
were safe. Based on the statements sent, the changes were divided into the
following groups:
-
organisational changes that do not affect the operation and maintenance
procedures changes to the railway system that do not affect safety.
-
changes to the railway system that affect safety, but are insignificant.
-
railway system changes, which are significant (in this case the
application should have been accompanied by a safety assessment report).
There are independent
safety assessors in the Czech Republic who evaluate safety assessment reports.
They are appointed by the National Safety Authority.
3.3 Germany
Railway transport in
Germany is second in terms of transported goods, just after road transport.
According to data from 2016, the length of German railway lines is about
1,066,477 km. There are 10 independent AsBos in this country. Altogether 99
safety certificates were issued, and 82 entities act as Entities in Charge of
Maintenance.
In Germany, it is noted
that there are no exact definitions of the terms; change and significant
change. The safety impact criterion, which has also not been precisely defined
in the CSM RA, leaves companies with considerable leeway in making decisions
regarding the use of the CSM RA in its full extent. At the same time, the
feedback from entities shows that they do not have a full understanding of the
CSM RA method and change management.
3.4 Italy
In Italy, 67 security
certificates have been issued. Fourteen companies act as Entities in Charge of
Maintenance and there are 6 AsBos. The railway lines operated in Italy have
373,461 km in length.
Compared to the other EU
Member States, in Italy, like in the Czech Republic, independent safety
assessors dedicated to CSM RA are active.
One of the producers
operating in Italy, Bombardier, emphasises that it identifies difficulties in
dealing with clients due to the lack of awareness and knowledge regarding the
use of CSM RA. Bombardier points to a significant lack of uniformity in the
application of the CSM RA at the national and international level, in
particular in the case of rolling stock.
In 2016, 531 changes
were introduced in Italy, of which 51 were considered significant. Most of the
changes were rated as operational (39%) or technical (33%), and organisational
changes accounted for about 17% of all changes. No information was given on the
type of the remaining 11% of changes. Changes made by the manufacturer were
technical in nature, related to changes in vehicles and integration control
within the railway system.
The inspections of
management methods and evidence of the use of CSM RA by rail entities in 2016
found that the CSM RA was not applied in an appropriate manner, in particular
with regard to risk reduction measures. Despite the fact that the results are
better compared to 2015, due to the interest and greater awareness of the
issue, there is still room for improvement in the way the CSM RA is applied.
3.5 Poland
In Poland, 198 safety
certificates were issued, and 62 organisations have the status of
a certified Entity in Charge of Maintenance. In addition, there are 7
AsBos. The length of railway lines is 234,298 km.
In 2017, 1,068 changes
were made to the railway system. Most of them (515) by infrastructure managers.
Up to 50 changes were introduced by railway undertakings and Entities in Charge
of Maintenance. Over 1000 changes were considered insignificant and only 37
were qualified as significant changes.
4. DISCUSSION AND
CONCLUSIONS
In order to harmonise
the approach to issues related to the safety of rail transport, a number of
common tools have been introduced across the EU. One of them is the CSM RA
– a risk management procedure related to changes introduced to the
railway system. Monitoring of compliance with this procedure was entrusted to
the National Safety Authorities, which annually publishes reports containing
information on the implementation of the CSM RA in their part of the EU railway
system.
The structure of reports
developed by the National Safety Authorities is defined in EU legislation, but
the exact scope presented in the actual reports prepared by the Member States
is very different. In some cases, for example, in the Belgian report, it is
limited to a few sentences describing the position of the Authority, some
subsections are even left empty. Other reports, for example, the Polish
authority, also contain numerical data regarding the number and types of
implemented changes.
A common issue raised in practically all of the reports analysed is the
lack of detailed definitions of terms such as significant change,
non-significant change, the impact of change on the safety of the railway
system. There
are indications of interpretation problems that make comparable changes in
different entities treated in different ways. At the same time, some Safety
Authorities (for example, German) complain about the lack of legal grounds to
impose their own understanding of the key terms. As an alternative to
administrative solutions, therefore, there are supporting activities, for
example:
-
elaboration of lists of typical significant and non-significant changes.
-
training for entities operating on the railway market.
These activities are the
result of the adoption of two different regulatory strategies for safety
management [3]. The first one assumes
that the answer to the problems related to the application of CSM RA is the
introduction of subsequent procedures that will clarify the existing provisions
and allow for the unambiguous assignment of the proposed change to one of the
categories – significant or insignificant changes. This facilitates the
supervision performed by Safety Authorities and also stabilizes the operating
conditions of, for example, rolling stock manufacturers, which can repeat their
actions for each subsequent type of vehicle.
On the other hand,
however, rigid lists of significant and insignificant changes may also have
negative effects, especially in the light of large fragmentation of entities
operating on the rail market in a given Member State. An analogous change
introduced in a large entity may be insignificant, but in the case of a smaller
carrier, it will require, for example, the creation of an additional position
and should be analysed in a more accurate manner. The introduction of lists
removes responsibility for decisions made by entities, although according to EU
law, it is them, and not the National Safety Authority, that are actually
responsible for the safety level of the EU railway system.
In summary, the
assessment of change in accordance with CSM RA is a difficult issue for many
Member States of the EU and, despite the issuance of a variety of guidelines,
it still causes a lot of difficulties for entities obliged to use it.
Therefore:
-
further steps should be taken to simplify the use of CSM RA, but in a
way, that real decision making remains at the level of entities operating on
the rail market.
-
it is worth getting to know and evaluate ideas implemented in the other
Member States, such as the appointment of dedicated safety assessors in Italy
and the Czech Republic.
ACKNOWLEDGEMENTS
Work financed from the
statutory resources of the Faculty of Transport Engineering at the Poznan
University of Technology, No. 05/52/DSMK/0286.
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Received 28.11.2018; accepted in revised form 13.01.2019
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