In this second part of ONRSR’s focus on safety culture, we continue to look at practical steps rail transport operators can take to promote a positive safety culture, as required by the Rail Safety National Law. [Clause 3 of Schedule 1 of the Rail Safety National Law National Regulations]
ONRSR observes different operators during regulatory activities and interactions, and their differing levels of maturity around safety culture and is highlighting key practices operators have put in place to promote a positive safety culture.
While there are many practices that could be discussed, here ONRSR is highlighting how the way in which operators make changes and improvements can impact safety culture. For example, the way operators improve their systems and assets through maintenance and rectifying defects.
For simplicity, the theme above is discussed under the following 3 topics:
Proactive approach to maintenance
Reviewing and updating your Safety Management System (SMS)
Corrective actions and management of change.
1. Proactive approach to maintenance
To ensure safe operations, rail infrastructure and rolling stock need to be adequately maintained. Below is a non-exhaustive list of good practices and how they promote a positive safety culture.
Good practices:
Conduct proactive rather than reactive maintenance (e.g. fixing or maintaining assets in line with a planned schedule before
they fail or degrade to the point where operations must stop).
Encourage workers to actively report defects or faults using existing processes.
Fix or correct defects, issues or faults within timeframes set out in the SMS (e.g. don’t let defects or issues remain unrectified for weeks, months or years). Decisions about addressing defects should be determined by risk-based considerations rather than resourcing issues. es – see Safety Message – Reprioritising Defects.
Have clear, objective and unambiguous processes and criteria for correcting issues or faults e.g. have all risk assessments, corrective actions and management of change processes in place.
Ensure processes for undertaking corrective actions and rectifying defects are understood and followed by staff, and there are periodic reviews to identify opportunities for improvement.
Inspect, audit or conduct walkarounds of infrastructure and rolling stock frequently to identify faults and issues (e.g. don’t wait for a third party, ONRSR or a member of the public to report an issue).
How this promotes a positive safety culture?
When staff see that defects and faults are proactively managed, they will know the organisation they work for takes maintenance seriously and are more likely to report any issues or faults.
When this view becomes widespread in your organisation, it means there is continuous improvement, creating a ‘learning culture’ where information related to maintenance is passed on, issues are fixed, and defects are managed.
Barriers to good practice:
If defects are not fixed with no justification provided, staff may believe that safety is not a high priority. If this view becomes widespread, it may impact multiple areas of the business and lead to increased and more serious incidents.
2. Reviewing and updating your Safety Management System (SMS)
The SMS is designed to manage the risks of your railway operations, so it needs to be up-to-date, convenient to use and easily accessible. Below is a non-exhaustive list of good practices and how they promote a positive safety culture.
Good practice:
Update existing systems and procedures that are part of your SMS, rather than bypassing them if they don’t work or using workarounds.
Conduct SMS reviews within required timeframes (e.g. avoid delaying reviews or waiting until ONRSR or an external audit identifies non-conformances).
Update asset registers and other documentation following maintenance, commissioning or installation so your documentation reflects what is installed.
Follow effective document control practices such as:
ensuring documents are signed or have ‘approved by’ signatures.
including ‘approved’ and ‘review by’ dates.
updating document IDs and internal document registers.
making consequential changes to related documents (such as updating references).
How this promotes a positive safety culture?
When staff see that the SMS is regularly reviewed, updated and reflects current practice, they are more likely to see the importance of following the SMS and how it contributes to safe railway operations.
When this view becomes widespread in your organisation, it creates a culture where information related to maintenance is passed on, issues are fixed, defects are managed, and the organisation continuously improves.
Barriers to good practice:
Systems and procedures that are difficult for staff to access.
Systems and procedures that are part of your SMS but are out-of-date, ineffective or do not reflect current practice – leading to staff adopting workarounds.
If these barriers exist and are not addressed, critical safety information can be missed, increasing the risk of incidents.
3. Corrective actions and management of change
Corrective actions are changes made to improve safety and prevent incident recurrence. Management of change processes ensure such changes are effectively implemented. Below is a non-exhaustive list of good practices and how they promote a positive safety culture.
Good practices:
Corrective actions address underlying safety issues and causes, rather than the symptoms.
Corrective actions focus on engineering or controls higher on the hierarchy of controls (e.g. modifying a signal that is difficult to see rather than emails, staff circulars or training that reminds drivers to be more careful at a multi-SPADed signal).
Multiple options for controls are identified, including examining what other operators in Australia and overseas are doing to address the safety issue.
Management of change processes are in place and spell out how changes are managed.
The implementation of corrective actions follows the management of change processes.
How this promotes a positive safety culture?
When corrective actions address underlying safety issues, the risk of safety incidents will be prevented or minimised.
When staff see safety issues are rectified, they are more willing to suggest improvements to make operations safer.
When the above actions and views become widespread in your workplace, it creates a ‘learning culture’ – where corrective actions are put in place in response to safety issues and the organisation continuously improves.
Barriers to good practice:
If staff think their organisation is not addressing underlying causes of incidents, they may be less willing to report safety issues or suggest improvements.
If corrective actions only cover ‘training’, ‘staff circulars’ or ‘reminder emails’ (i.e. a focus on staff actions), it may lead staff to believe their organisation sees them only as responsible for safety issues.
If these barriers exist in your workplace and are not addressed, it creates a culture where staff don’t speak up, don’t report, don’t share information and safety issues can be missed.
Key documents and actions
Operators are encouraged to review their SMS to ensure that the good practices set out in this safety message are considered.
A comprehensive collection of ONRSR Safety Messages is available to view here.