1 strategy for risk based health and safety regulation richard price irsc conference

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1 Strategy for risk based health and safety regulation Richard Price IRSC Conference

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1

Strategy for risk based health and safety regulation

Richard Price

IRSC Conference

2

My messages are….

A safe industry is an efficient industry

Key to both is excellent management and leadership

Our work….

Pushes the industry towards excellence in management

Highlights their responsibility to manage risks properly

Based on…

Our strategy for health and safety regulation, which

focuses our resources in a proportionate way on the risks

3

A reminder of the GB rail industry landscape….

4

• 3.25 million journeys each day

• 28 billion tonne km of freight

• 40,000 bridges, tunnels and viaducts

• 20,000 miles of track• 2,517 Stations• 8.200 properties

Scale of GB mainline rail

5

GB mainline regulatory landscape….

Growth

1.4 billion passenger journeys in 2010/11.

This was an 8% increase over previous year. (RSSB figures)

Complexity

Train operators, Freight operators, Infrastructure managers, Metros, Entities in charge of Maintenance, Rolling stock leasing companies, contractors, suppliers, open access etc,

Monopoly

Ownership of infrastructure

6

Our strategic priorities as an integrated regulator ….

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Our strategic priorities as an integrated regulator are…

Reducing the industry’s costs (McNulty review)

A sharper focus on customers

Excellence in health and safety culture and management across the industry

8

Our strategy for health and safety regulation aims to reduce harm…

Zero fatalities and ever-deceasing health and safety risk

Excellence

In asset management and operations

In health and safety management and culture

Result

Better management capability

Reduction in risks

Reduction in harm

Reduced likelihood of multiple-fatality incident.

9

We check compliance and push excellence in management…

Checking legal compliance

control of risks

every day

by businesses.

Pushing for excellence in management by businesses

because excellent management means

more likelihood of compliance every day.

more likelihood of control of risks every day.

10

Why excellence in management?

…because managers control risks day in, day out.

Managers’ performance varies.

If they are already high performing (“excellent”), then greater likelihood that their dips in performance will still be above the legal minimum and risks will be adequately controlled.

If they are only poorly performing (“ad hoc”), then greater likelihood that their normal performance (and any dips) are below the legal minimum and risks are uncontrolled.

Management maturity model helps us evaluate the capability of managers to control risks.

11

Our strategy’s goal is reduced harm…

Annual Health and Safety Report 2011-2012

Overall rate of harm decreased by 12%

No workforce and industry caused passenger fatalities on:

London Underground,

London Overground,

Docklands Light Railway

Recorded harm at level crossings reduced

12

And this is what one industry model tells us about safety performance over time…

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But bad events are still happening because industry management is not excellent …

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Management is not excellent…..

Numbers of bad events: Downward trend, but they still happen.

Inspection & audit findings looking at management

We most often judge management aspects as being “standardised”. This means (for example), we find:

…”Leadership is still largely viewed as a senior management role”

Rather than “excellent” leadership when..

…”Leaders at all levels…show shared values directed at continually meeting the business objectives safely...”

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Our strategy for health and safety regulation is built on understanding the risk landscape and our focus on management improvement…

16

Understanding the risk landscape….

Accident and incident data

Risk models used by the industry

London Underground’s Quantitative Risk assessment Model

RSSB’s Safety Risk Model for the mainline

Intelligence from our own inspections, investigations and enforcement activities over the years

RAIB investigation findings

Informed specialist views

Intelligence from European and international developments

17

After analysis, our priorities for regulation focus on…

Risk priorities

Level crossings

Interface system safety

Infrastructure safety

Rolling stock

Workforce safety

Occupational health

Enablers (management):

Health & safety management systems

Competency of people & human factors

Change management

18

Our strategy builds into our business plan…

The risk priorities and enablers:

Are analysed and described in our document: “Strategy for health and safety regulation”

Match our work programmes

Resources are proportionate:

allocated to the programmes

Guided by the approach set out in the strategic document for each

To the principles explained in the next slide.

It is about It is not about

Balance Too much in any area: too little or none in another

Proportionate to risk and focused on risk reduction

Proportionate to safety levy payment. The levy is linked to turnover, not risk

Targeted by evidence Targeted by whim

Right skilled and confident people Poorly trained people who lack courage

Covering the country Areas left alone

Knowing the skills you need Work determined by the skills we happen to have to hand

Letting the duty-holder control risks Man-marking the duty-holder for no good reason

Principles for how we decide on resources and build our business plan…

20

So….

For each sector

Mainline

Transport for London

Trams & light railways

Heritage

We know

Our risk priorities

Our programmes of work

Our planned activities in each programme

21

Delivering our strategy’s focus on management enablers…

22

We check safety is being managed properly from top to bottom in rail businesses….….

11Ad hoc Managed

Governance

Policy

Written SMS

Organisational Structure

Allocation of Responsibilities

Management and Supervisory

Internal Communications

System Safety and Interface

Organisational Culture

Record Keeping

Competence Management

Worker Involvement

Risk Management

Target Setting

Workload Planning

Safe Systems

Asset Management

Change Management

Control of Contractors

Emergency Planning

Proactive Monitoring

Audit

Incident Investigation

Management Review

Corrective Action

RM3

Standardised Predictable Excellent

Leadership

Achievement levels

RM3 Main Categories

Policy

Organising for Control and Communication

Securing Cooperation and Competence

Planning and Implementation

Monitoring, Audit and Review

Key

Dutyholder assessment 2010

Dutyholder Target by end 2012/13

Railway Management Maturity Model

Inspection

Investigation

Audit

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Sharpening our own capability to deliver our strategy…

24

We are sharpening up on strategy and impact…

the match of our work programmes to our strategy.

keeping strategy under regular review

Identifying potential impact of our activities in reducing the likelihood of multi-fatality events using the industry risk models

Sharpening up our own management of safety regulation

Using the ERA cross-audit results to help us do this.

Inspection quality: performance of least capable Inspectors comes closer to the practice of our best

Regulatory decision-making being more clearly in line with our policies.

25

In summary

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My messages are….

A safe industry is an efficient industry

Key to both is excellent management and leadership

Our work….

Pushes the industry towards excellence in management

Highlights their responsibility to manage risks properly

Based on…

Our strategy for health and safety regulation, which

focuses our resources in a proportionate way on the risks