This from Bill Emery's letter to Iain Coucher published today...
Our work has highlighted four significant areas of concern. These are:
1. There has been no practical test of the proposed changes. You propose simultaneous implementation across the entire network, to a very tight timescale. We recognise that there is a legitimate case for speed to reduce the period of uncertainty for your employees. However much of the changed practices you need depend upon your series of ‘how to’ guides, but they are not yet available. We are concerned that the cultural change for your maintenance employees is unlikely to be introduced safely if it is implemented nationally without proper employee engagement or before essential tools for consistently and safely changing processes are developed and have been rolled out effectively.
2. Your London North West route faces the most significant changes. The successful introduction of the Virgin high frequency (VHF) timetable was only made possible by significant increases in staffing. We are concerned that not all the technological and procedural changes necessary to support your new structures have been implemented. Your review of efficient engineering access, planned for June 2010, lags implementation of phase 2b2c. By then many of your current employees will have left. Also current performance on west coast mainline is erratic (and on our regulatory escalator) with some of your delivery units unable to resource the basic requirements in standards and you are yet to implement all the planned VHF maintenance improvements. All these factors in combination give us cause for concern on you London North West route.
3. Many of your section managers report doing significant additional hours to carry out their duties properly. Your restructuring increases their workload and decreases their support, with fewer assistants and support engineers. We are concerned that your section managers undertake safety critical work but as yet their time (and hence fatigue risks) are not recorded and appear not to be managed proactively. We agree with Steve Featherstone that resolving these issues is important and we have made it clear to him that this must be resolved quickly if you are to avoid us taking formal enforcement action.
4. Your new approach distinguishes between productive time (actually doing a task) and the preparation, travel, access, briefing etc. You appear to have designated lookouts and other essential safety roles as non-productive. Steve Featherstone has explained that your approach should help your push for more green zone working. We are concerned that it could just as feasibly encourage shortcuts in lookout provision (as we found recently in south Wales), skimping on planning and curtailed safety briefings.
We have also identified inconsistencies and gaps in your Ellipse database. This chimes with other criticisms of your asset information systems. We are pleased that the D-Quip project is progressing well but there is a long way to go. Our inspectors found examples of maintenance tasks and activity not captured in Ellipse due to interface issues, staff uncertainty and local recording systems. But in mitigating the effect of any such errors in this change, we know that your works delivery structure, and in the short term the surplus staff pool, will provide flexibility to resource maintenance tasks adequately if you have got local sizing wrong. If we find examples where shortcuts persist, or that post “go-live” reviews are not effective, we will take action.
We understand you expect targeted use of your labour-only sub-contractors and we can see the business benefit of this approach. But current employment practices in some of your labour providers are substantially different to your direct employees, with these employees having to pay for their own training, equipment, travel etc. We will intervene if we find your labour-only contractors failing to meet the requirements of health and safety law.
Of course as the duty holder, you are responsible for your safety systems and processes. We will continue to monitor and contribute to your safety validation process and we will target our inspection activity in the areas set out above.
I therefore look to you for action on the principal concerns I have highlighted in this letter before you make the go/no-go decision on your maintenance restructuring.
UPDATE: This from Network Rail's press office in response to the ORR...
"The ORR has done a thorough job on auditing our proposals and where they have raised concerns we are addressing them. Working together, we are all committed to a safe, efficient and reliable railway. Unnecessary and unwanted strike actions jeopardise the progress we have all made in transforming the railway for the British people.
"Union leaders who defend out-dated work practices from the 1950s are standing in the way of that progress. This is the digital age not the steam age so we need to change so we can deliver the railway Britain needs in the 21st century."
UPDATE: This from RMT General Secretary Bob Crow...
“Coming from the ORR this is nothing short of condemnation of Network Rail’s dangerous cost-cutting plans. If even the ORR says the plans are untested, being implemented in haste and will put pressure on managers to cut back on safety-critical lookouts and briefings, it is clear that they must be stopped and that is why we are demanding an immediate halt.
“RMT has said from the start that Network Rail’s plans, which include the sacking of 1,500 front-line maintenance workers, can only undermine rail safety with lethal consequences, and this news completely justifies the union’s decision to ballot members for strike action to defend rail safety and their jobs.”
UPDATE: This from the ORR press office in response to Network Rail...
Office of Rail Regulation (ORR) chief executive Bill Emery said:
"We welcome Network Rail's positive response and commitments to take action on some of the concerns we have raised. We note and agree that the best way for the rest of our concerns to be acted upon is through Network Rail's own safety validation process. This established mechanism ensures that these vital safety considerations remain firmly where they belong - with the company's management team.
“We are disappointed in the company's response on the potential safety impact of the non-productive time definition. More needs to be done here.
“ORR's inspectors will continue to scrutinise the change management arrangements as well as practical safety measures on the ground and if we believe our concerns have not been properly addressed, we will step in more formally."
UPDATE: This from our man at 222 Marylebone Road...
If this is the 'digital age', how is the area, as opposed to route, based technician going to plug in his diagnostic lap top when he is called out to a mechanical interlocking problem?
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