Management of safety-related change
Date issue released
Safety Issue Description

Although TasRail had a detailed change management process in place, and had documented that the project to develop the third-generation remote control equipment was a significant change, the change management process had a limited capability to:

  • assure pre-determined activities, approvals, and documentation were completed throughout progression of a change
  • identify the need for relevant safety assurance activities
  • assure the determination of whether a change had the potential to impact safety.
Issue number
RO-2018-014-SI-05
Issue Status
Closed – Adequately addressed
Transport Function
Rail: Freight
Issue Owner
TasRail
Mode of Transport
Rail
Issue Status Justification

The ATSB is satisfied that TasRail’s amended change management processes adequately addresses the safety issue.

Proactive action
Action number
RO-2018-014-PSA-08
Organisation
TasRail
Action date
Action Status
Closed
Action description

On 15 July 2022 TasRail advised the following in terms of the assurance of progression of a change:

In order to address these issues, TasRail has implemented a revised Management of Change System’s Project Delivery Process which provides step-by-step instructions to Change Leads on how to deliver a change/project from conceptualisation through to finalisation. The Project Delivery Process includes key points where safety assurance activities and safety impacts are to be identified, assessed, mitigated, and verified.

The Project Delivery Process has key hold points embedded within it as mandatory "checks" to ensure appropriate governance. Some of these include:

  • Review and approval by the accountable (risk) delegate of the Initial Change Assessment (ICA), which is the tool to assist Change Leads/delivery teams in assessing the risk and impact of a proposed change. The ICA has a multi-stage assessment approach to determine the type, complexity, and size of a project, which in turn drives the risk and impact. The tool provides Change Leads with the ability to undertake quantitative assessments of the proposed changes inclusive of business capability and safety impacts. The ICA will provide recommendations regarding the use of Technical Advisors depending on the level of technical complexity.
  • Review and approval by the accountable (financial) delegate of the Project Business Case, which is the document to justify the implementation of a change and includes risk management and project planning components.
  • Review and approval by the appropriate delegate of any Acceptance for Testing requirements, which includes the approval of any pre-prepared, reviewed and endorsed Testing/Commissioning Plans.
  • Review and approval by the appropriate delegate of any Acceptance for Operation requirements, which includes the verification that all interfacing and integration activities, as specified in the Project’s Requirements Management System, has been undertaken.
  • Review and approval by the appropriate delegate of any Handover requirements, which includes the verification that all Requirements Management System items are completed and compliant.
  • Various points through the project delivery for stakeholder review, endorsement, and approval, inclusive of any external Technical Advisors and/or Independent Safety Assessors.

In addition to these mandatory check points, the Project Delivery Process makes note that additional checkpoint approvals may be required for individual projects, and such governance processes should be determined on a project-by-project basis based on risk and impact to the business.

TasRail advised the following in terms of the need for relevant safety assurance activities and the determination of whether a change had the potential to impact safety:

It should be noted that the system itself does not identify the need for relevant safety assurance activities but provides a consistent platform for the business to be able to assess projects and determine if safety assurance activities are required. It does this by providing guidance to delivery teams about what and when certain activities (safety assurance being one) should be considered and managed. It is an embedded requirement of the system, that the personnel assessing, undertaking, reviewing and authorising Management of Change be competent in the areas that they are involved.

TasRail additionally advised:

[The newly-developed Management of Change System] provides detailed guidance and tools to assist Change Leads in ensuring safety assurance activities are considered, planned and verified throughout the implementation of a change.

The Management of Change System achieves this through the following:

  • the Integrated System Framework Manual provides information on System Safety Management (Section 5.12) inclusive of Safety Assurance elements, documentation, speciality engineering, Safety in Design and information regarding competency for personnel carrying out various safety assurance activities;
  • the Project Delivery Process provides step by step instructions to Change Leads on how to deliver a Change/Project from conceptualisation through to finalisation. This Project Delivery Process includes key points where Safety Assurance activities and Safety Impacts are to be identified, assessed, mitigated and verified;
  • risk assessment and risk management activities, in line with TasRail’s risk management framework, are embedded in the process from the initial assessment of the change (mandatory Risk Assessment and also secondary Impact Assessment if residual risks are greater than low) through the planning, design and implementation of the change with drumbeat monitoring, update and management of the project risk assessment required; and
  • the use of a Requirements Management System with minimum inclusions provides Change Leads and delivery teams with a holistic way of capturing all requirements inclusive of safety requirements and then creating a platform to verify each individual requirement to ensure that the change has met deliverables.

Finally, TasRail [has conducted] training for approximately 90 of its employees who will use, or be exposed to, the Management of Change System so that they have a proper understanding of the system and its requirements.

ATSB Response

The ATSB notes that TasRail’s wide-ranging new processes address each aspect of the safety issue in detail. In addition to the benefits described by TasRail in its response to this safety issue, the processes:

  • follow the systems engineering V-model, requiring safety arguments to be made, updated and managed throughout the life of a contract or project, supported by documented evidence in a safety assurance report
  • require system safety management through the specification, verification and validation of requirements, including quantitative safety requirements, which are addressed through the use of safety assurance plans, a hazard log, safety assurance reports, and engineering assurance registers
  • require an independent safety advisor to be engaged based on technical or safety complexity of the project.

Such activities necessarily require close engagement with the development process when using vendors or contractors and are likely to provide reliable, documented safety assurance to all types of activities.