41120 Concerns about supply chain auditing for engineering work

January 2011 in Network Rail and Suppliers

Rules and procedures Method of working Communication and teamwork South East

A reporter believes the auditing process of the Network Rail supply chain is sometimes ineffective, especially in relation to engineering work associated with Road Rail Vehicles (RRVs) and On-Track Plant (OTP). Typically, this work will involve a principal contractor and agency staff.

The reporter believes that despite the best of intentions, as well as paperwork that shows everything is in good working order, large safety critical issues are not being fully addressed. The numerous interfaces between different parties in the supply chain are thought to contribute to the problem.

Regarding agency workers, the reporter highlights the following issues noted during possession work:

• Machine Controllers (MCs) without the required level of knowledge for safe working. For example, the reporter is aware of several MCs wrongly assuming detonators should be set back only a quarter of a mile back from a derailed vehicle.
• Staff who turn up without the proper equipment such as detonators, lamps, track circuit operating clips, and OTP cards.
• Staff often appear not to receive important, written safety briefs. For example, many agency workers appear not to have read a recent brief from Network Rail about reportable incidents.
• Staff whose command of English is poor. Some have difficulty understanding basic safety instructions.

The standard Network Rail response has often been that the principal contractor should resolve issues like these. But the reporter argues excellence in this area will only be achieved if Network Rail enhances its role in the overall management of the supply chain.

The reporter would like to ask Network Rail - with particular reference to agency staff - whether current auditing practices can detect whether:

• Safety briefs have actually been read?
• Agency staff have the required safety knowledge and know what equipment to use in a given situation?
• More attention could be paid to the interfaces between Network Rail and principal contractor; and principal contractor and labour supply agencies?

Response from Network Rail

Network Rail would like to thank the reporter for bringing their concerns to our attention.

In June 2010 Network Rail introduced Standard NR/L3/INI/CP0073 ' Supplier Licensing Requirements' which clearly sets out what is expected with regard to supplier licensing, including a requirement for principal contractors to involve rail plant operating company licence holders in the planning phase of the job through to delivery. The objective of this requirement is to enhance the communication and co-ordination aspects of the Construction Design & Management Regulations, 2007 (CDM) and includes:

• rail plant operating companies involvement in the development of site safety documentation (work package plans and task briefings);
• site inductions to include Rail Plant Operators/Machine and Crane Controllers;
• accident and incident reporting arrangements to be consistent between the principal contractor and rail plant operating company; and
• emergency and contingency planning arrangements to be consistent between the principal contractor and rail plant operating company.

However, for those suppliers with Network Rail Licences not following the requirements set in NR/L3/INI/CP0073 and are involved in serious or persistent safety lapses the Head of Commercial (Investment Projects) will normally rule in consultation with other functional heads on whether a supplier has its Network Rail Licence effectively suspended (or removed altogether) pending an investigation.

In the case of serious or imminent danger the option to immediately suspend work must always be there for all on site.

Both suspension and removal of the supplier's licence are also available to us. These, clearly are severe but effective remedies - in extremis (extreme circumstances) - but this is not to say that all such reported incidents should result in either sanction. Any confirmed safety misdemeanours or serious/persistent incidents perpetrated by a supplier must result, in the first instance, in an appropriate and measured level of investigation covering (say) the areas the reporter has highlighted. These investigations may involve topic audits and the imposition of robust action plans on the supplier. However it is worthwhile to note here that if an audit takes place, the best it will ever be is a 'snapshot' of a suppliers capabilities and cannot replace robust management and supervision on site.