Safety concern regarding interpretations of Worksite Protection Plan (WPP)
The reporter has raised a safety concern regarding differing interpretations of the Worksite Protection Plan (WPP) procedure following the introduction of the Corridor Access Authority (CAA).
The reporter states that the introduction of the CAA is beneficial from a safeworking perspective; however, different network controls have different interpretations of the processes regarding what is approved. The reporter believes that while the CAA is done in advance to plan for site protection as best is possible without attending the site, the WPP conducted on site at the time of the work being conducted, is the plan that must take precedence.
The reporter advises that worksite protection requests are being rejected by some network controllers because they differ from the CAA. The reporter acknowledges that if there are significant differences between the two, that some protection requests may not be approved because they haven't been adequately planned for operationally. However, the reporter advises that small changes that would have no impact on operations are being rejected because it does not exactly match the CAA. One example provided is the CAA stating two x 30-minute track time is required but the protection officer (PO) determines on site that further time is required, Network Control refuses to grant additional time, which places time pressures on the PO and the rail safety workers.
Given that the PO that submits the CAA two weeks prior to the proposed work has not attended the site, and is not always the PO who is actually on site on the given day, it is imperative that the WPP that is conducted and requested by the trained PO is the plan that is approved and used to conduct the work. The reporter believes that this is preventing POs from being able to take a higher level of protection than planned for, if on the day, the PO determines that it is necessary. This results in some PO's taking shortcuts and settling for inadequate protection, to ensure the job isn't cancelled.
In addition, the process for applying for a CAA differs depending on where the work is. The reporter states that [Location] have a dedicated team for arranging / changing CAAs which is user friendly and efficient. However, elsewhere, untrained people are expected to generate the request in [operating system] and submit a WPP at least two weeks before the proposed job, generate a work order once approved and close it out once the CAA has been used.
The reporter is seeking confirmation from the [Rail Infrastructure Manager] that the WPP takes precedent over the CAA, and that there is flexibility to amend the CAA on the day if required. The reporter requests that confirmation of this is relayed to all network controllers to avoid further confusion.
The [Rail Infrastructure Manager (RIM)] would like to thank the individual who reported their concerns via the REPCON and provide the following observations and assertions:
Safety is a core value and number one priority for the organisation with a simple commitment that no harm should occur on our network to our people, customers and community who we interface with.
As the reporter articulates, the worksite protection plan (WPP) is submitted two weeks prior and not always by the PO conducting the work on the day. Following submission, this WPP is subject to review to confirm that the level of protection requested is sufficient for the work being undertaken and the time requested to complete the works is sufficient. Following the review, the CAA is approved for execution on the day. The feedback provided relates to the safety aspects of work site protection although [RIM] acknowledge much of this type of feedback to date has been focused on time efficiency and recognise that both can be interrelated.
Should it be identified on the day that a higher level of protection is available or required then this change can be requested through the relevant network control centre (NCC) and will be approved through the process outlined. If it is not possible to accommodate this change to the CAA, discussions and agreement will be reached between the PO and NCC.
It is incumbent on the worksite supervisor and the work team to ensure there is sufficient time to safely complete the work during the time allocated. If it is identified that there is insufficient time then additional time should be requested through the NCC prior to commencing work, and if none is available, then the work needs to stop and subsequently be replanned for a future time.
The CAA process is deliberately designed to prevent a lower form of authority being taken to ensure that the correct level of protection is taken for the works being completed. If a lower form of protection is requested for the work, it will be refused by NCC as per process.
[RIM] recognises that this is a new process implemented on our network impacting a wide number of stakeholders, and in January 2022 commenced a post-implementation review to identify improvement opportunities. The ongoing review and iteration of the CAA process post-implementation will continue to occur and where appropriate, this feedback will be incorporated to improve the process. [RIM] will provide transparency of these changes to ONRSR as part of the regular meetings.
[RIM] would like to thank you again for raising this report and are committed to the safety of workers on our network. The CAA process is a critical control to ensure that work on track is planned and authorised enabling safer outcomes and reduced train to trackworker incidents.
ONRSR has reviewed the reporter’s concerns and operator’s response. This matter was discussed with the operator at a meeting in January 2022 and ONRSR is satisfied with the operator’s management of this issue.