ORR Consultation - Draft Appendix for operation of passenger trains in Unattended Train Operation configuration - ASLEF Response

- ORR Consultation on UTO
ASLEF's response to ORR consultation on UTO
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The ORR is consulting on plans to add an appendix to the Goal Setting Principles for Railway Health and Safety. The appendix covers the goal setting principles for running passenger trains in Unattended Train Operation (UTO) configuration. 

Below is our response to the ORR's consultation on introducing an appendix to the goal setting principles for the railways. The appendix will outline the goal setting principles for passenger trains in Unattended Train Operation (UTO) configuration. https://www.orr.gov.uk/search-consultations/goal-setting-principles-railway-health-and-safety-draft-appendix-uto

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

  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. We welcome this opportunity to comment on the ORRs proposal to clearly outline the considerations to be made when introducing GOA4 UTO services.    
  3. We note that the proposals look to clearly outline what factors are to be considered when duty holders are attempting to introduce GOA4 levels of automation to the railways and we believe this is a sensible approach to ensure that health and safety is kept as a top priority when outlining the factors for consideration when working to deliver UTO.            
  4. We agree with the intention to focus the supplement on the issues identified in BS EN 62267:2009 ‘Railway applications. Automated urban guided transport (AUGT). Safety requirements.’            
  5. It is sensible to build on the research that has already been carried out to look in to the safety requirements of automated urban guided transport. We would also suggest that other UTO services in other countries are continually monitored so that any lessons from incidents can be learned and if needed the additional factors can be updated.      
  6. The push to fully automate the operation of trains is highly complex and incredibly difficult to deliver with current infrastructure, as such we do not believe the GOA4 principles should form part of the main Goal Setting Principles for Railway Health and Safety as it will impact on multiple principles and could require a complete rewrite of the current Goal Setting Principles which were reissued by the ORR in 2017.         
  7. The desire to fully automate trains is unlikely to be realised outside of very restricted settings such as those currently in use as ‘people movers’ at airports or the proposed UTO on Glasgow’s subway, although this is still to be extensively trialled. The operation of GOA4 requires a greater control of the environment in which the services are operating, this can be realised more easily on underground systems but it still brings with it great complexity and cost to amend current systems or integrate new networks with existing ones.  
  8. Despite Docklands Light Railway, London Underground and Tyne & Wear Metro being mentioned in the draft document on page 3, the complexities of running UTO in an exposed environment such as that of Tyne & Wear Metro, DLR and parts of London Underground are not touched upon. Whilst it may be technically possible, (at a great cost) to run UTO on parts of Britain’s metro systems, the cost to implement this on current networks would be extensive. Therefore, it is appropriate that the principles act as a supplement to the Goal Setting Principles to avoid wastage of resources on attempts to implement UTO on current networks when the money could be better spent on further electrification of the network, improvements to stations and to the rolling stock to improve passenger and driver comfort and safety.
  9. The requirement to change from GOA4 services to at the least GOA3 and below services to access wider parts of the rail network can also impact on the attractiveness of UTO services to rail passengers by complicating journeys as passengers will be required to change at stations to access services with a driver on board.
  10.  Due to these complexities and costs, we believe that it is appropriate that the GOA4 principles act as a supplement to the Goal Setting Principles as we would not want the inclusion of these principles in the main goal setting principles to lead to planners to try and force GOA4 on to parts of the network at the expense of investment in areas which would provide a better return to passengers, staff and the wider economy sooner.                           
  11. The draft supplement covers all of the operational safety points that we would expect it to in conjunction with the GSPfRH&S for a train to operate in UTO mode, we do however have some concerns with the proposals and we will work through these concerns one by one.            
  12. On page 6, in relation to the movement of a service from a platform after an obstacle is either detected ahead of the train or at the Platform Train Interface (PTI), there is reference to an authorised person recording the reason for the on-board train control system setting off an alarm and applying the emergency brake. It is not clear if this person is intended to be physically present or if it can be overridden by a person in the control room, we believe that due to the potential faults, blind spots and obstructions that can impact on the quality of CCTV for safe train dispatch, this ambiguity should be removed to clearly state that an authorised person will physically inspect the reasons for the activation of the detection system.        
  13. On page 6, point 9 the draft document states that, when stopped on the network at a position other than in a station platform, a GOA4 train in UTO service when given permission to move by the signalling system shall not be capable of moving until a positive signal of confirmation that it is safe to move is received by the operating system from the on-board train control system. There is no mention of what should happen when the on-board train control system does not give confirmation that is safe to proceed. This is slightly touched on under point 13 on page 7 but again there is ambiguity around where the person authorised to record the reason for the stopped train will physically be when assessing the situation.         
  14. On page 7 under derailment, there is specific mention of a UTO train entering into service from a depot and the requirement for the train to be able to detect derailment of its running gear, there is however, no mention of obstacle detection when a UTO train is entering service from a depot. We also assume this detection of derailment and obstructions would also apply for a UTO train leaving service to enter a depot, it would be sensible to remove any assumptions by explicitly stating that both detection systems would be in operation in both circumstances.               
  15. On Page 7, point 13, there is no mention of the GOA4 train in UTO service leaving or entering a depot despite it being mentioned under point 10 on the same page, this should be included with ‘line-running or departing a platform’ to ensure that there is no ambiguity around when obstacle detection is to be operating.
  16. In terms of omissions in the document, our concerns on some of the points have been laid out above but for the benefit of analysis we will mark out exactly what we believe is lacking and where.           
  17. On page 6 under point 9 there is no mention of what to do when a UTO service is stopped on the network and unable to start due to the on-board train control system not giving a positive signal to start moving again. This leaves a gap in the draft between a UTO service starting and stopping due to an obstacle. If for example a service was stopped at red signal and was then given permission to move by the signal if it then does not move, the principle under point 13 does not apply as it has already stopped. The service could not be able to move due to a fault with the obstacle sensors or there may be an obstacle which has appeared between being stopped by a signal and being given permission to move on. There should be a provision for an authorised person to investigate if the UTO service is not moving after being given permission by the signalling system.
  18. The point above could be resolved by amending point 13 to include “Any train stopped by activation of either obstacle detection equipment while line-running, departing a platform or continuing after a signal has stopped it…” this would ensure that in the situation outlined under point 17 of our response would be dealt with in the same manner as the service coming to an abrupt stop whilst line running or not continuing whilst at the platform.        
  19.  Point 10 on page 7 of the draft mentions entering into service from a depot but there is no mention of the opposite scenario where a service is entering a depot. If it is the intention of the ORR to explicitly state that the services can run in UTO mode from the depot, we would assume that operators of the services would also look to run the trains in UTO mode back to the depot. To ensure that there are no safety oversights, point 10 should include ‘entering the depot from service’ as well. It should also be made clear when entering and leaving a depot in UTO mode that the derailment and obstacle detection is still prescribed to be running on the train. Accidents can unfortunately occur at depots and we have lost members due to such accidents, we would not want any UTO trains to be running into and out of depots without the factors to be considered, explicitly stating that obstacle and derailment detection will be running in both circumstances.    
  20. We also have concerns that there is no mention of malicious entry to the controls / driving cab. We would assume that the trains would have controls on board to enable the train to be moved by an authorised person physically on board in certain circumstances. These controls would be locked away when the train is running in UTO. We believe therefore, that there is an omission in the draft that the train is able to start moving without the on board train control system checking to ensure that the panel to access the controls is shut / locked. This should also be touched on when it comes to the train stopping as a reason for the emergency brakes to be applied or at the very least for control to be alerted and to investigate the reason why the train is reporting that the control panel is accessible whilst in UTO.  
  21. Further to malicious entry to controls we also hold concerns around cyber-attacks impacting on the safety and ability to control UTO services from control. This would impact on point 26 and 27 on page 11, there should perhaps be provision for the on board systems to initiate a TSEA for factors beyond being contactable by voice by a controller to try and counter any faults or malicious attacks to the on board computer systems.             
  22.  An additional factor which we think is missing from the draft factors is for UTO trains to be required to meet height, offset and curve requirements to provide step free/ level boarding. This omission could lead to UTO services, not being accessible to passengers with mobility issues and with no assistance due to a lack of staff on the service potentially limiting the wider appeal of such services.         
  23. Overall we agree that the additional factors to be considered for operation of passenger trains in GOA4 should be a supplement to the GSPfRH&S and we agree with the approach of building on the issues identified BS EN 62267:2009 ‘Railway applications. Automated urban guided transport (AUGT). Safety requirements. We do continue to hold safety concerns with GOA4 particularly in emergency situations where on GOA3 and below a member of staff/driver on board would be able to immediately react and deal with the situation. GOA4 is likely to be operating on services that are running in tunnels and there is a lack of clarity on how authorised personnel will access or move trains that have emergencies in these situations. We are also concerned with the overreliance on computer systems and the pressure this could place on control who will be expected to respond to incidents, remotely operate trains and assess issues on the network.