Department for Transport: Creating a Road Collision Investigation Branch (RCIB) Consultation - ASLEF Response

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ASLEF's response to the DFT's consultation on the creation of a Road Collision Investigation Branch (RCIB)

The DfT is consulting on the introduction of a new body to investigate road collisions / incidents (RCIB) You can read about the proposed investigation branch here

Below is ASLEF's response to the DFT's consultation on the creation of a Road Collision Investigation Branch (RCIB)

ASLEF Consultation Response - UK Government – Department for Transport – Creating a Road Collision Investigation Branch – November 2021

  1. The Associated Society of Locomotive Engineers and Firemen (ASLEF) is the UK’s largest train driver’s union representing over 21,000 members in train operating companies and freight companies as well as London Underground and light rail systems.
     
  2. As a rail-specific union, we will be mainly responding to the sections of the consultation regarding the powers of the RCIB

Q22 To what extent do you agree or disagree with the proposal that the RCIB should have the stated investigative powers? Agree

  1. It is important that the RCIB has the powers and authority to investigate and work with existing organisations such as the RAIB and those responsible for the appropriate infrastructure as and when it is deemed necessary. For example, any road collisions that involve or are close to rail and light rail infrastructure. Such as, level crossings and tramlines, should involve joined up working to ensure that any potential for recurring incidents can be identified and fixed through collaborative work with those responsible for the design and maintenance of both the roadways and rail/tramways, particularly when the two intersect.
     
  2. It would also be important for the investigations to be able to investigate how the work of those involved may contribute to incidents, for example through fatigue. Many workers will carry out jobs, which require high levels of concentration, particularly in safety critical roles, such as train and tram drivers. After a shift, these workers will often drive from a workplace, if the RCIB was able to include these factors in their investigations it could help to inform employers, the government and relevant safety bodies on safe working hours for safety critical roles particularly those that require driving or involve commuting via private car. For example through monitoring of incidents and safety standards, HGV drivers are currently monitored through a tachograph to ensure that they are driving safely and within the allowed hours to avoid fatigue impacting on their safety on the roads, this includes mandated rest time between driving. If the RCIB spotted a pattern with fatigue from certain work contributing to road incidents, it would be appropriate for recommendations to be made to counter this.

Q24. In your view how important is it that an RCIB base investigation criteria on the: scale? - Very important            
risk of harm? - Very important         
emerging risks? – Very important   
Why?

  1. Due to the high number of road traffic accidents and collisions it is logical for the RCIB to use scales of serious and fatal collisions along with the risk of harm to base its investigations.
     
  2. As a union covering train drivers we hold concerns for the impact of new technologies such as driverless vehicles and their ability to read the road effectively, particularly when it comes to navigating level crossings and roadways that are shared with light rail / tram. There are presently around 6,000 level crossings on the rail network, and 8 tramway/light rail systems in the UK that intersect roads. Any incidents on level crossings and involving light rail / tram are currently covered by the RAIB.      
     
  3. In terms of the importance of investigating emerging risks, it would be sensible for a joined up approach and for clear lines as to where the RCIB is responsible and where the RAIB is responsible for investigating. If for example the RCIB is purely looking at the scale of incidents / risk of harm it may reduce the likelihood of an investigation into incidents or emerging risks involving light rail / tramways and at level crossings due to the infrequency of these. However, the potential impact these incidents can have for the health of those involved and the knock on effect the incidents can have to the network and wider public transport systems can be high.
     
  4. It would make sense that whilst investigating emerging risks posed by new driving technologies that there is a joined up approach to assessing the impact it can have on incidents at level crossings and on tramways to ensure that the RCIB communicates with the RAIB, Network Rail and the authorities responsible for the light rail / tram networks.         
     

Mick Whelan
ASLEF

General Secretary
77 St John Street
London
EC1M 4NN