Safety Management System Arrangements

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Safety Management System Arrangements LUKL-OCC-001 Issue 8 1 of 104 Safety Management System Arrangements Name Signature Job Title Date Prepared by: Paul Thompson Principal Consultant, HaRMUK Ltd 04/09/20 Reviewed by: Ross White Assurance Director 04/09/20 Accepted by: Health and Safety Representatives Health and Safety Committee 03/09/20 Authorised by: Richard Kelly Managing Director 04/09/20 Issue Date Details Issue 1 November 2014 First Issue Issue 2 January 2015 Amended with affected parties’ recommendations Issue 3 March 2015 Further amendments required Issue 4 May 2015 Vehicle maintenance procedures updates Issue 4a June 2015 Further amendments from ORR required Issue 5 August 2015 Substantial revision to reflect ORR comments and a critical review Issue 6 October 2015 Updated to address consultation comments Issue 7 October 2015 Minor updates to close out of items from ORR Issues Log Issue 7a November 2015 Minor corrections Issue 7b February 2016 Change of responsibility and organisational structure to lead operations Issue 7c August 2016 Renumbering and enhancement of operational procedures to support national operations, changes to range of traction operated, and re-branding for Loram UK Issue 7d December 2016 Minor changes to reflect ORR Issues Log raised during assessment Issue 7e January 2017 Minor changes to reflect Network Rail Issues Log raised during consultation Issue 8 September2020 Safety Certificate renewal submission

Transcript of Safety Management System Arrangements

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Safety Management System Arrangements

Name Signature Job Title Date

Prepared by: Paul Thompson Principal Consultant, HaRMUK Ltd 04/09/20

Reviewed by: Ross White Assurance Director 04/09/20

Accepted by: Health and Safety Representatives

– Health and Safety Committee 03/09/20

Authorised by: Richard Kelly Managing Director 04/09/20

Issue Date Details

Issue 1 November 2014 First Issue

Issue 2 January 2015 Amended with affected parties’ recommendations

Issue 3 March 2015 Further amendments required

Issue 4 May 2015 Vehicle maintenance procedures updates

Issue 4a June 2015 Further amendments from ORR required

Issue 5 August 2015 Substantial revision to reflect ORR comments and a critical review

Issue 6 October 2015 Updated to address consultation comments

Issue 7 October 2015 Minor updates to close out of items from ORR Issues Log

Issue 7a November 2015 Minor corrections

Issue 7b February 2016 Change of responsibility and organisational structure to lead operations

Issue 7c August 2016 Renumbering and enhancement of operational procedures to support national operations, changes to range of traction operated, and re-branding for Loram UK

Issue 7d December 2016 Minor changes to reflect ORR Issues Log raised during assessment

Issue 7e January 2017 Minor changes to reflect Network Rail Issues Log raised during consultation

Issue 8 September2020 Safety Certificate renewal submission

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Contents Safety Management System ..................................................................................................................................... 1

Arrangements ........................................................................................................................................................... 1

1 Introduction ........................................................................................................................................................... 6

1.1 Purpose of the Safety Management System Arrangements .......................................................................... 6

1.2 Duty Holder ..................................................................................................................................................... 6

1.3 Scope of the Safety Management System ...................................................................................................... 6

1.4 Alignment to ISO 45001:2018 ......................................................................................................................... 7

1.5 Maintenance of the Safety Certificate and Safety Management System Arrangements ............................... 7

1.6 Abbreviations .................................................................................................................................................. 7

1.7 References ...................................................................................................................................................... 8

2 Safety Management System Overview .................................................................................................................. 9

2.1 Safety Policy Statement .................................................................................................................................. 9

2.2 Structure of the SMS ....................................................................................................................................... 9

2.3 Organisation of the SMS Procedures ............................................................................................................ 10

2.4 Organisational Arrangements ....................................................................................................................... 10

2.5 Key Safety Posts and Professional Heads ..................................................................................................... 11

2.6 Safety Critical Activities ................................................................................................................................. 13

2.7 Safety Advice and Guidance .......................................................................................................................... 13

2.8 Planning and Implementing the SMS ............................................................................................................ 14

2.9 Employee Involvement ................................................................................................................................. 14

2.10 Monitoring Safety Performance ................................................................................................................. 15

2.11 Reviewing and Improving the SMS ............................................................................................................. 15

3 Identifying and Controlling Risk ........................................................................................................................... 16

3.1 Introduction .................................................................................................................................................. 16

3.2 Identification of Hazards ............................................................................................................................... 16

3.3 Assessing Risk ................................................................................................................................................ 18

3.4 Risks Associated with the Procurement of Goods and Services ................................................................... 18

3.5 Risks Associated with the Use of Contractors ............................................................................................... 19

3.6 Controlling Risk ............................................................................................................................................. 20

3.7 Monitoring the Effectiveness of Risk Control Arrangements ....................................................................... 21

4 Maintaining Compliance with Standards and Legislation .................................................................................... 22

4.1 Identification of External Requirements ....................................................................................................... 22

4.2 Development of Company Procedures ......................................................................................................... 22

4.3 Implementing Company Procedures ............................................................................................................ 23

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4.4 Monitoring the Effectiveness of Company Standards .................................................................................. 23

5 Change Management ........................................................................................................................................... 24

5.1 Overview of the Change Management Process ............................................................................................ 24

5.2 Identification of Changes .............................................................................................................................. 24

5.3 Safety Validation of Significant Changes ....................................................................................................... 25

5.4 Safety Validation of Other Changes .............................................................................................................. 26

5.5 Safety Certificate Changes ............................................................................................................................ 26

5.6 Authorising and Implementing Changes ....................................................................................................... 27

6 Training and Competency .................................................................................................................................... 28

6.1 Competence Management Overview ........................................................................................................... 28

6.2 Identification of Safety Critical / Safety Related Tasks ................................................................................. 28

6.3 Recruitment and Selection ............................................................................................................................ 29

6.4 Provision of Training ..................................................................................................................................... 29

6.5 Competence Assessment and Monitoring .................................................................................................... 30

6.6 Competence of Contractors, Consultants and Suppliers .............................................................................. 32

7 Train Integrity ...................................................................................................................................................... 34

7.1 Rolling Stock Supply and Maintenance ......................................................................................................... 34

7.2 Hired in and Sub-Leased Vehicles ................................................................................................................. 35

7.3 Maintenance Planning For Vehicles Where Loram UK are the Maintainer .................................................. 35

7.4 Maintenance Planning For Vehicles Where Loram UK are Not the Maintainer ........................................... 36

7.5 Defect Reporting ........................................................................................................................................... 37

7.6 Engineering Change ...................................................................................................................................... 37

7.7 New or Substantially Altered Vehicles .......................................................................................................... 38

7.8 Technical Audit .............................................................................................................................................. 38

8 Train Operations .................................................................................................................................................. 40

8.1 Train Operation Methods ............................................................................................................................. 40

8.2 Traincrew ...................................................................................................................................................... 40

8.3 Operational Risk and SPAD Management ..................................................................................................... 41

8.4 Loram UK Operations Control ....................................................................................................................... 42

8.5 Shunting Operations ..................................................................................................................................... 43

8.6 Urgent Operating Advices ............................................................................................................................. 44

9 Occupational Health and Safety .......................................................................................................................... 45

9.1 Introduction .................................................................................................................................................. 45

9.2 Types of Occupational Health and Safety Risk .............................................................................................. 45

9.3 Personal Protective Equipment (PPE) ........................................................................................................... 45

9.4 Refusal to Work Policy .................................................................................................................................. 46

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9.5 Welfare Arrangements.................................................................................................................................. 46

9.6 Plant and Equipment..................................................................................................................................... 46

9.7 Drugs and Alcohol Policy ............................................................................................................................... 46

9.8 Control of working hours .............................................................................................................................. 47

10 Provision of Safety Information ......................................................................................................................... 48

10.1 Document Control Arrangements ............................................................................................................... 48

10.2 Control of Records ...................................................................................................................................... 48

10.3 Internal Communication ............................................................................................................................. 48

10.4 External Communication............................................................................................................................. 49

11 Accidents, Incidents and Safety Opportunities .................................................................................................. 50

11.1 Safety Incident and Safety Opportunity Reporting ..................................................................................... 50

11.2 Safety Incidents and Safety Opportunities Investigation ........................................................................... 51

11.3 Statutory Reporting .................................................................................................................................... 52

11.4 Implementing Recommendations for Improvement .................................................................................. 52

11.5 Trend Analysis ............................................................................................................................................. 53

12 Emergency Planning........................................................................................................................................... 54

12.1 Emergency Planning .................................................................................................................................... 54

12.2 Roles and Responsibilities ........................................................................................................................... 54

12.3 First Aid Arrangements ............................................................................................................................... 56

12.4 Training and Competency ........................................................................................................................... 56

12.5 Communication of Emergency Plans .......................................................................................................... 57

12.6 Testing the Effectiveness of Emergency Plans ............................................................................................ 57

13 Monitoring and Audit ........................................................................................................................................ 58

13.1 Monitoring and Auditing Processes ............................................................................................................ 58

13.2 Health, Safety and Environment Monitoring .............................................................................................. 58

13.3 Overview of Audits ...................................................................................................................................... 59

13.4 Internal Audit .............................................................................................................................................. 60

13.5 External Audits ............................................................................................................................................ 61

14 Co-operation ...................................................................................................................................................... 62

14.1 Overview ..................................................................................................................................................... 62

14.2 Co-operation with the Network Rail ........................................................................................................... 62

14.3 Co-operation with the Landlord.................................................................................................................. 62

14.4 Liaison with other Transport Undertakings (TUs) and Suppliers ................................................................ 63

14.5 Interfaces with Other Organisations ........................................................................................................... 63

15 Safety Performance and Improvement Plans .................................................................................................... 64

15.1 Setting Health and Safety Objectives .......................................................................................................... 64

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15.2 Measuring and Monitoring Safety Performance ........................................................................................ 64

15.3 Monitoring Individual Safety Performance ................................................................................................. 65

15.4 Annual Safety Report .................................................................................................................................. 65

16 Management Review ......................................................................................................................................... 66

16.1 Reviewing and Improving the SMS ............................................................................................................. 66

16.2 Annual Management Review ...................................................................................................................... 66

16.3 Continual Improvement .............................................................................................................................. 67

Appendix 1 – Health and Safety Policy Statement ................................................................................................. 68

Appendix 2 – Loram UK Organisation Structure ..................................................................................................... 69

Appendix 3 – Key Responsibilities .......................................................................................................................... 72

Appendix 4 – Vehicle Classes Operated by Loram (UK) .......................................................................................... 80

Appendix 5 – SMS Documents ................................................................................................................................ 81

Appendix 6 – Rule Book Module Applicability ........................................................................................................ 88

Appendix 7 – Interface Organisations and Activities .............................................................................................. 89

Appendix 8 – Rules and TSI's References to Processes .......................................................................................... 92

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1 Introduction 1.1 Purpose of the Safety Management System Arrangements 1.1.1 The purpose of this document is to outline the Safety Management System (SMS) adopted by Loram UK in order to meet the requirements of the Railways & Other Guided Transport Systems (Safety) Regulations 2006 (ROGS) (Ref [2]) and other legal obligations under the Health and Safety at Work etc. Act 1974. 1.1.2 It summarises the arrangements which Loram UK has in place for:

• safe operation of trains on the mainline railway

• ensuring the integrity of rail vehicle maintenance

• managing risk arising from our operations and activities

• protecting our people and those affected by our undertaking 1.1.3 The SMS is designed to deliver safety through the effective control of risk. 1.1.4 The Loram UK Managing Director holds the principal accountability for the safety of the company’s activities under the Safety Certificate. This document describes how this accountability is discharged. 1.2 Duty Holder 1.2.1 The address of the Duty Holder of the Safety Certification is: Loram UK Limited Kelvin House RTC Business Park London Road Derby DE24 8UP Company Registered No. 06031483 1.2.2 Loram UK specialises in engineering work on railway traction and rolling stock. We are based in Derby, at the heart of the UK rail industry, and offer modern, well equipped workshops that allow us to offer customers a full range of rolling stock engineering solutions; from train servicing through routine fleet maintenance to the heaviest of vehicle and component re-engineering projects. 1.2.3 Loram UK has four workshops and office accommodation within the RTC Business Park at Derby, and operates the yard area at Derby RTC Business Park. Loram UK is obtaining a Safety Certificate to commence railway operations on the mainline railway network. 1.2.4 Loram UK is an employer and is a Transport Undertaking, as defined in ROGS (Ref [2]), but does not act as an Infrastructure Manager. 1.3 Scope of the Safety Management System 1.3.1 The Safety Management System described in this document applies to all Loram UK’s activities, operations and premises, and embraces Loram UK staff, contractors, suppliers, visitors to our site, our suppliers and any members of the public affected by our activities.

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1.4 Alignment to ISO 45001:2018 1.4.1 The Loram UK Safety Management System is independently certificated to ISO 45001:2018 (Ref[5]). This description of the safety management system arrangements is structured around the ORR Safety Certificate Assessment criteria, but follows the convention and broad structure used in ISO45001:2018, and specific clauses of the standard can be cross referenced as shown below:

ISO 45001 Section No.

ISO 45001 Section Title Loram UK SMS Arrangements Section No.

4 Context of the Organisation 1, 2

5 Leadership and Worker Participation 2

6.1 Actions to Address Risks and Opportunities 3

6.2 Objectives and Planning to Achieve Them 15

7.1 Resources 2.4, 2.5, 2.6

7.2 Competence 6

7.3 Awareness 4.3, 10.3

7.4 Communication 10.3, 10.4

7.5 Documented Information 2.3, 4.2, 10.1, 10.2

8.1 Operational Planning and Control 7, 8, 9

8.2 Emergency Preparedness and Response 12

9.1 Performance, Measurement, Analysis and Performance Evaluation 2.10, 2.11, 15

9.2 Internal Audit 13.3, 13.4

9.3 Management Review 16

10 Improvement 11, 16.3

1.5 Maintenance of the Safety Certificate and Safety Management System Arrangements 1.5.1 The Assurance Director is responsible for maintaining the Safety Certification documentation, including this Safety Management System Arrangements document. All category 1, 2 and 3 changes are managed through the revised LUKL-MSP-002-Safe Management of Change (See Section 5). 1.5.2 For substantial alterations to the type or extent of operations, Loram UK will apply to the ORR for an amended certificate before the changes are introduced. For all other significant changes (such as the introduction of new rolling stock, or major organisational changes), the ORR will be informed at the earliest opportunity. 1.5.3 Loram UK recognise that cumulative increases in non-significant changes may become significant due to the sum of progressive non-significant changes having the same cumulative effect as a significant change since the last accepted Safety Certificate, and where this is recognised, ORR will be informed. 1.5.4 The SMS Arrangements will be maintained as a controlled document and issued to relevant stakeholders as necessary. The Assurance Director will ensure that staff safety representatives are consulted on the development of the supporting safety management system, and that all employees are aware of the broad requirements of the SMS through their line manager. 1.6 Abbreviations CIRAS Confidential Incident Reporting and Analysis System CSM Common Safety Method – see Ref [3] EMS Environmental Management System NIR National Incident Reporting (NIR Online) ORR Office of Rail and Road

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ROGS Railways & Other Guided Transport Systems (Safety) Regulations (ROGS 2006) SI 2006 No.599, and Amendment SI 2011 No. 1860

RSSB Rail Safety and Standards Board RIR Railways (Interoperability) Regulations 2011 RTC Railway Technical Centre SMIS Safety Management Information System SMS Safety Management System SPAD Signal Passed at Danger TOLO Train Operator’s Liaison Officer TSI Technical Standards for Interoperability 1.7 References Ref [1] ORR Assessment Criteria for Safety Certificate and Authorisation applications for mainline railways. Safety Authorisation Assessment Manual, Office of Rail and Road, 05 December 2018

Ref [2] Railways & Other Guided Transport Systems (Safety) Regulations (ROGS 2006) SI 2006 No.599, and Amendment SI 2011 No. 1860

Ref [3] Common Safety Method on Risk Evaluation and Assessment (CSM-REA) Regulation (352/2009 repealed by 402/2013 (as amended 2015/1136)) of risks associated with significant engineering, operational and organisational changes to the mainline railway

Ref [4] Railways (Interoperability) Regulations 2011 SI 3066, including 2013, 2014 and 2015 amendments

Ref [5] BS ISO 45001:2018 Occupational Health and Safety Appendix 8 details additional key references applicable to the SMS arrangements.

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2 Safety Management System Overview 2.1 Safety Policy Statement 2.1.1 The Managing Director’s Health and Safety Policy Statement is posted on the Loram UK company intranet and also on health and safety notice boards at all relevant locations on the Loram UK site. The content is briefed to staff during induction and if the policy is significantly updated. The policy is also made available to other interested parties as appropriate. It also forms part of the Loram UK SMS. A copy of the Policy is included in Appendix 1. 2.1.2 The Health & Safety Policy Statement is supported by specific topic policies. 2.2 Structure of the SMS 2.2.1 The SMS is comprised of a suite of documents listed in the Index of Management Systems Procedures maintained by the Operations and Safety Director (LUKL-INDEX-001). The list of documents is also included as Appendix 5. This document is a summary description of the SMS. 2.2.2 The SMS procedures are written in a structure that clearly lays out responsibilities, processes and records required to manage risk. The combination of these procedures into a system is designed to meet the principles contained in the revised HSG65 ‘Successful Health & Safety Management’, using the four steps:

2.2.3 The principal documents in the SMS are:

• Safety Management System Arrangements (this document)

• Policies

• Procedures

• Forms and records

• Risk assessments

• Working instructions

These are supported by:

• Individual Safety Responsibility Statements (integrated into Job Descriptions)

• Training and competence of individuals undertaking safety critical work

• Personal objectives 2.2.4 Loram UK has developed a Quality Management System (certificated to ISO 9001:2015) and an Environmental Management System (certificated to ISO 14001:2015) which are both constructed around similar principles to the health and safety management system (certificated to BS ISO 45001:2018). The structures of the management systems are similar, supporting procedures are all in the same format, and there are a number of common procedures across the three management systems which define common processes.

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2.3 Organisation of the SMS Procedures 2.3.1 Procedure LUKL-MSP-001 Document Review and Document Control describes the structure and format of safety procedures and associated documents to ensure consistency. 2.3.2 Policies and procedures supporting the quality, safety and environment management systems are produced to a common format, in accordance with template F-MSP-001-3. Forms are linked to specific procedures, and support procedures. 2.3.3 The format of numbering system for policies and procedures is based on the following notation:

LUKL-POL-XXX Policy documents

LUKL-MSP-XXX Management System common Procedures

LUKL-OCC-XXX Occupational health and safety procedures

LUKL-OPS-XXX Operational safety procedures

LUKL-ENG-XXX Engineering quality management system procedures

LUKL-ENV-XXX Environmental management system procedures

LUKL-PRO-XXX Procurement procedures

LUKL-HRP-XXX Human Resources/People procedures

LUKL-QS-YYY-XXX Quality Standard, where YYY is the engineering trade

LUKL-WIS-YYY-XXX Working instructions, where YYY is subject matter code 2.3.4 Individual procedure numbers are determined by the individual professional heads in liaison with the Assurance Director, who maintains an overall index of policies and procedures to ensure alignment and no duplication of processes or numbers. 2.3.5 Forms are referenced as ‘child’ documents to the specific procedures, so Form F-MSP-001-1 is form number 1 of procedure LUKL-MSP-001. 2.4 Organisational Arrangements 2.4.1 The safety organisational structure of Loram UK is designed to deliver safety of train operations and safety for people. Competence of staff is assured through the arrangements described in Section 6. An overall organisational structure chart is maintained separately and is summarised in Appendix 2. 2.4.2 A safety organogram for the organisation is included in Appendix 2b. 2.4.3 The SMS Arrangements include details of the main organisational arrangements and responsibilities for safety, and the safety organisation for roles with key safety responsibilities supporting the maintenance and operation of train services. The Senior Management Team is illustrated in Figure 1 below.

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* Refer to Appendix 2 for detail on organsational structure

Figure 1 – Organisational Structure (Senior Management Team) 2.4.4 Posts designated with the letters KSP are Key Safety Posts. All key safety responsibilities are listed and described in section 2.5 with reporting lines illustrated in Appendix 2. A brief summary of key roles and responsibilities relevant to rail operations is detailed in Appendix 3. 2.4.5 All Safety critical safety posts are listed in 2.6 with reporting lines illustrated in Appendix 2 by the prefix SCP for designated safety critical posts. 2.4.6 All employees are issued with a job description which outlines the responsibilities, qualifications and experience for the post, and includes safety responsibilities, in accordance with LUKL-HRP-002 Job Descriptions and Safety Responsibility Statements, and are briefed on its contents on appointment. 2.4.7 All employees have a role to play in maintaining a safe railway. However, the principal accountability for safety is held by the Managing Director and discharged through the Executive Directors and Functional Heads. This flow of accountability is managed through job descriptions, integrated safety responsibility statements, and personal objectives. It is the duty of each of the Functional Heads to ensure that there are adequate resources, with appropriate competence, to safely discharge their functional activity. 2.4.8 All employees are issued with a job description which outlines the responsibilities, qualifications and experience for the post, and includes safety responsibilities, in accordance with LUKL-HRP-002 Job Descriptions and Safety Responsibility Statements, and are briefed on its contents on appointment. 2.5 Key Safety Posts and Professional Heads 2.5.1 Certain Loram UK staff defined in Table 1 are responsible for making key safety related decisions that are not classed as safety critical (see ROGS, Ref [2]), but could affect the safety of train operations. These posts are designated as Key Safety Posts and the job descriptions are endorsed accordingly. Loram UK defines these key safety posts as those involving:

• setting or monitoring standards for current train operations and maintenance

• provision of instruction, information and advice essential for safe day to day operation of the safety management system

• setting and monitoring training standards

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Nominated deputies are appointed for each Key Safety Post to cover for prolonged periods of absence. Nominated deputies are issued with copies of the job description of the Key Safety Post and briefed on the specific safety responsibilities of the post for which they are deputising in part or in whole. The following posts have been identified with specific health and safety responsibilities and nominated deputies: Table 1

Key Safety Post Nominated Deputy

Managing Director Finance Director

Assurance Director HSE Manager

Technical Director Professional Head of Engineering

Professional Head of Engineering Technical Director

Professional Head of Rail Operations Technical Director

Health, Safety and Environment Manager Assurance Director

Operations Standards Manager Professional Head of Rail Operations

Maintenance Manager Production Manager

Yard Manager Planning and Capacity Co-Ordinator

Head of Rail Grinding Systems and Services Rail Grinding Machine Manager

Rail Grinding Machine Manager Technical Services Manager (vice versa)

2.5.2 Loram UK has designated certain posts to act as the competent person in determining the safety strategy within a recognised discipline. These posts are termed Professional Heads. Loram UK believes the merits of having separate Professional Heads for the key disciplines of occupational health and safety, operational safety and engineering safety enables Professional Heads to maintain sufficient depth of knowledge and focus to their own specialised area. 2.5.3 Each Professional Head has specifically defined competencies, qualifications and experience for the role, and these are defined in the job description for the post (see Table 2). Where appropriate, specific competencies will be assessed, but in the main Professional Heads ensure their on-going competence through self-certification and where appropriate, Continuous Professional Development schemes. They are required to hold a recognised professional qualification in a discipline appropriate to their post, and to be a member of an appropriate professional body. Where no appropriate professional body exists, a Professional Head is required to demonstrate qualification through previous experience within the discipline. Specific minimum competence requirements are shown in the following Table 2. Table 2

Discipline Post Competence Requirements

Operations Principles & Standards

Head of Operations (Professional Head of Operations)

Extensive experience of train operation principles including detailed knowledge of all books of Rules and Regulations published as Railway Group Standards

Health and Safety Assurance Director (Professional Head of Occupational Safety)

Chartered Member of IOSH

Plant and Traction & Rolling Stock Engineering

Technical Director (Professional Head of Engineering)

Chartered Engineer and Member of The Institution of Engineering and Technology, or Member of the Institution of Mechanical Engineers

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2.5.4 Professional Heads have the ultimate authority in safety terms within their field of expertise. Professional Heads underpin the corporate competence of Loram UK. 2.6 Safety Critical Activities 2.6.1 Loram UK employees undertake a number of activities that are considered to be safety critical in accordance with the guidance provided by ORR and the Railways & Other Guided Transport Systems Regulations 2006. The arrangements for identifying safety critical roles are described in procedure LUKL-OCC-503 Determining Safety Critical Roles. Staff in safety critical roles are required to be embraced in the competence management system. Safety critical activities include:

Table 3

Driver Training Manager Competency Assessor Welding Co-ordinator IM Supervisor Rail Operations Controller Maintenance Technicians Production Supervisors IM Team Leaders Train Driver Shunters Production Team Leaders NMT Technicians

Technical Services Manager Field Technician Machine Grinding Manager Grinding Supervisor Maintenance Supervisor Field Maintenance Specialists

2.6.2 Some other roles such as staff acting as Designated Persons are subjected to LUKL-OCC-503 Determining Safety Critical Roles to determine whether their tasks and decision making could affect the safe operation of the railway. 2.7 Safety Advice and Guidance 2.7.1 The Assurance team provide advice and guidance on safety, security and health matters to all parts of the Loram UK organisation. The team are responsible for developing policy, strategy, procedures and processes to ensure the safe operation of Loram UK activities and to maintain the safety of employees and others affected by our undertaking. The team structure is illustrated in Figure 2 below. Figure 2

Figure 2 Assurance Team 2.7.2 The Assurance Director is the Professional Head of Occupational Safety and is a direct report of the Managing Director. This ensures that the post holder is close to all business decisions, whilst being able to exercise an element of independence in the event of any serious safety concerns arising in the business.

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2.8 Planning and Implementing the SMS 2.8.1 The foundation for the SMS is risk assessment. The arrangements adopted by Loram UK for risk assessment are detailed in procedure LUKL-OCC-201 Risk Assessment and are summarised in Section 3. 2.8.2 Safety procedures are developed in accordance with a standard process and format described in procedure LUKL-MSP-001 Document Review and Document Control. Development of procedures involves managers with relevant competency and experience. Safety procedures are consulted with staff representatives and accepted by the Health and Safety Committee prior to implementation. Safety procedures are implemented through a structured process and effectiveness of implementation is assessed through inspections and audits. Safety procedures are published and made available to all staff through the company Intranet, and where necessary are supported by working instructions, point of use notices, and other associated documentation made available to staff. 2.8.3 The policies and processes defined in the SMS are operated in parallel to comparable procedures in the Quality and Environmental Management Systems, and where appropriate common procedures are employed across all three management systems. 2.9 Employee Involvement 2.9.1 Loram UK recognises the importance of involving all employees in the development of the safety management system and a positive safety culture in the organisation. Improvements in health and safety performance can only be achieved if there is full commitment from all staff and managers. 2.9.2 In accordance with legislation, Loram UK recognises employees appointed to the role of health and safety representatives for the purpose of representing their colleagues on matters of health and safety and undertaking consultation on their behalf. Loram UK arrangements are documented in procedure LUKL-OCC-104 Safety Representatives Roles and Responsibilities and includes provision for health and safety representatives to be appointed covering each grade and key roles, provision of facilities for use of safety representatives, Safety Representative training, and the arrangements for release from their normal duties to undertake activities associated with their appointment. 2.9.3 The names of the appointed safety representatives are posted on the health and safety noticeboards so that all staff are aware of who their safety representatives are. 2.9.4 Safety issues are discussed with safety representatives and the senior management team through monthly Health and Safety Committee Meetings, under the chairmanship of the Assurance Director. The Health and Safety Committee considers health and safety performance, concerns raised by the workforce via their representatives, lessons learnt from within the railway industry and other industries, and is the consultation forum for all safety procedures. Health and Safety Committee Meeting actions are recorded in the minutes of the meeting and actions are tracked to conclusion through subsequent meetings. 2.9.5 The SMS is subject to consultation with Health & Safety representatives both informally on an individual basis and formally and collectively through the Health and Safety Committee. 2.9.6 Employees are encouraged to raise health and safety issues with their line manager, and through safety forums and group meetings. In addition, there are confidential reporting facilities provided through CIRAS for

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employees who feel for whatever reason unable to use a more open approach. Responsibilities for working safely, the process for refusing to undertake work on the grounds of health and safety, and the provision of a confidential reporting system are documented in procedure LUKL-OCC-103 Working Safely. 2.10 Monitoring Safety Performance 2.10.1 Proactive and reactive measures are used by Loram UK to monitor safety performance. Proactive measures include planned general inspections and safety tours of the workplace (documented in LUKL-OCC-101 Health and Safety Monitoring and Inspection), analysis of trends in accident statistics, and systematic audits to confirm the effective implementation and operation of the SMS. 2.10.2 The setting of safety objectives and targets and monitoring of safety performance is further described in Section 15. 2.11 Reviewing and Improving the SMS 2.11.1 In order to achieve continual improvement in safety management, Loram UK develops safety objectives from the annual business review process and monitors progress in their successful implementation in the form of quarterly Board updates and an annual management review process. Annual health and safety objectives and targets are documented in LUKL-OBJ-001 Health and Safety Objectives and Targets. 2.11.2 The Assurance team reviews progress against objectives and safety KPIs regularly and provides monthly based reports to the Loram UK Board in the form of a Health, Safety and Environment Balanced KPI Dashboard. 2.11.3 The Assurance Director arranges for a periodic review of the Loram UK procedures, on a risk based frequency. 2.11.4 Further details of the arrangements for management review are described in Section 16.

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3 Identifying and Controlling Risk 3.1 Introduction 3.1.1 Procedure LUKL-OCC-201 Risk Assessment details the process and arrangements for carrying out risk assessments related to Loram UK’s activities, including identification of hazards, assessment of risks, implementation of controls, and review of risk assessments. 3.1.2 Loram UK’s risk assessments cover routine and non-routine activities. Task based risk assessments are carried out in accordance with HSE guidance on risk assessments, using a simplified 5 x 5 matrix score for risk evaluation. 3.1.3 Processes are in place to manage risks during change, especially changes to engineering processes and railway vehicles (LUKL-ENG-008 Engineering Change), and safety reviews of changes of organisation, working hours and shift patterns, or working practices (LUKL-MSP-002 Safe Management of Change). 3.1.4 Risk Assessments are carried out in accordance with the Common Safety Method (CSM) on Risk Evaluation and Assessment (Ref [3]) when a significant change of the engineering or train operation conditions or arrangements is identified. This is triggered through application of procedure LUKL-MSP-002 Safe Management of Change, and consideration of the change against the screening criteria for applying the CSM. The arrangements for managing change are detailed in Section 5. 3.1.5 Where there is a significant organisational change that could impact upon the operation of the railway system this will be documented and assessed using the CSM principles. 3.1.6 Risk assessments are reviewed and amended as necessary whenever there is a significant change to the hazards and risks associated with the task or activity, when new hazards or risks are introduced, where events or incidents indicate that control measures for a risk may be inadequate, and periodically. In all instances the risk assessments are reviewed at least annually. This review process is administered by the HSE Manager who will monitor triggers for review of risk assessments. 3.2 Identification of Hazards 3.2.1 The Loram UK hazard identification and risk management activity take account of internal and external factors and include all hazards that are reasonably foreseeable. They may be hidden or visible. Some hazards are latent within processes and not evident until some event makes them relevant. Hazards may arise from defects which occur on trains or on the infrastructure, weaknesses identified in procedural controls, and actions taken by Loram UK staff, the staff of other organisations, or infrastructure workers. The Loram UK hazard identification and risk management activity must therefore take account of internal and external factors, and include all hazards that are reasonably foreseeable. 3.2.2 A Hierarchy Task Analysis (HTA) was carried out to have a clear understanding of the scope and what work is involved with mainline operations. This method was favoured as it breaks down complex tasks into a number of more simplistic ones to allow detailed examination and to allow them to be easily understood and followed. The HTA outputs formed the basis for conducting a HAZOP.

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3.2.3 Hazards outside the scope of mainline operations are identified and categorised in accordance with standard criteria, and these categories of hazard are embedded in the risk assessment templates. 3.2.4 The risk assessment process also covers risks that are not under the direct control of Loram UK. This includes third party risks, such as hired staff or plant, trespass, vandalism and level crossings, and external factors such as extreme weather and low adhesion. 3.2.5 Loram UK procedure LUKL-OCC-101 Health and Safety Monitoring and Inspection is in place for inspections and senior manager safety tours. This identifies and monitors potential workplace hazards, with deficiencies being highlighted for correction. Where this process highlights new hazards, a risk assessment will be triggered. 3.2.5 Loram UK has developed an operational risk assessment to consider the hazards associated with the proposed scope of train operations. This involved use of a HAZOP Study taking account of RSSB Safety Risk Model to identify potential hazards and assess risks for high-consequence low-frequency critical risks where Loram UK does not have operational experience on which to base the assessment of risk. Foreseeable hazardous events covered the following categories:

• Hazardous Events involving Train accidents (HETs)

• Hazardous Events involving the Movement of trains (HEMs)

• Hazardous Events Not involving the movement of trains (HENs) 3.2.6 Following the HTA, train operation hazards have been identified and risks assessed. A HAZOP Study was carried out to identify, analyse and evaluate the risks that are related to the work identified with train operation on the mainline. Key risks were then evaluated to decide the significance of each risk identified with the operation and selecting and implementing appropriate measures to control risk. 3.2.7 The HAZOP study systematically examined all the activities and identified the significant hazards involved in Loram’s operational activities. The HAZOP provided the opportunity to ensure that the significant risks identified were sufficiently well controlled and to identify areas of possible weakness with the intention that annual reviews will maintain the relevance of the study to current Loram mainline activities. 3.2.8 Loram recognises that vehicle movements on depots present different range of risk factors which require a separate causal analysis. Loram carried out a Fault Tree Analysis (FTA) exercise to identify, analyse and evaluate the risks that are related to the work identified with operation. Key risks identified from failure paths recorded five hazardous events. Train Derailment; Signal Passed at Danger; Collision; Struck or striking object and Contact with buffer stops 3.2.6 Train operation hazards are regularly reviewed and risks are assessed when significant changes to operating practices occur (such as changes of rolling stock type; modifications to the rolling stock; and major changes of workload, timetable or operating practice). LUKL-MSP-002 Safe Management of Change includes a significance test to identify when changes are significant and must be risk assessed in accordance with the Common Safety Method on Risk Evaluation and Assessment.

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3.3 Assessing Risk 3.3.1 Occupational safety risk assessments are carried out in accordance with procedure LUKL-OCC-201 Risk assessment. This method is used to assess risk in accordance with the requirements of the Management of Health & Safety at Work Regulations 1999 and associated legislation. 3.3.2 Occupational risk assessments are undertaken by individuals who are competent to do so, and have appropriate training and experience. Loram UK ensures that there are sufficient individuals in each function trained to conduct the necessary risk assessments 3.3.3 The persons undertaking risk assessments will normally be:

• The Health, Safety and Environment Manager or Safety Project Manager

• A Health and Safety representative

• A person who normally carries out the task if the Health and Safety representative is not competent to undertake the task

3.3.4 The risk assessment will be authorised by the Assurance Director. 3.3.5 When significant changes to the nature of Loram UK operations are planned, the Professional Head of Operations will commission a risk assessment, and formally consider the requirements of the CSM (Ref [3]). 3.3.6 Specific risk assessments for occasional or non-routine operational activities or circumstances will be completed where there is a higher perceived risk. These will include risks where SPADs or other operating incidents may occur. For example a medical condition where an employee has been passed fit to work by their own doctor but the condition has not been previously evaluated for safety-critical duties, will require a specific individual risk assessment in accordance with LUKL-OCC-202 Individual Health Risk Assessment. 3.4 Risks Associated with the Procurement of Goods and Services 3.4.1 The Logistics and Procurement Manager is responsible for ensuring that managers engaging in purchasing use defined processes for selecting a supplier and assessing the risk from those suppliers. 3.4.2 Loram UK procures goods and services through the arrangements defined in procedure LUKL-PRO-002 Procurement. This includes an initial assessment of the product or services being procured to assess whether they are safety related or safety critical. This initial screening is carried out by the nominated contract manager by completing a risk assessment in accordance with procedure LUKL-PRO-006 Procurement – Safety Validation of Contracts. 3.4.3 Where this initial risk assessment identifies that a product or service is safety related or safety critical, safety validation will be carried out in accordance with LUKL-MSP-002 Safe Management of Change. This will identify the legal requirements, industry standards and other control arrangements that need to be built into the contract specification 3.4.4 The contract manager will ensure that any identified safety requirements are built into the contract specification and that goods and services are only procured from suppliers approved in accordance with LUKL-PRO-003 Supplier Qualification.

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3.4.5 Where new or altered products, components or materials for use on rail vehicles are to be procured a risk assessment must be carried out before they are introduced, in accordance with procedure LUKL-ENG-008 Engineering Change. 3.4.6 The Head of Supply Chain and Logistics will ensure inspection processes are in place for inward goods to ensure safety critical components meet the required specification, to ensure traceability of component and material specifications, and initiate the investigation of incorrect or defective components in accordance with procedure LUKL-PRO-005 Control of Non-Conforming Products. 3.4.7 In cases where spares and parts are ordered and delivered direct to a site other than the Loram UK Derby site then the site delegated authority will liaise with, and under the supervision of, the Head of Supply Chain and Logistics to ensure that parts are procured, received, inspected, stored and controlled in accordance with procedure LUKL-PRO-005 Control of Non-Conforming Products 3.4.8 The contract manager is responsible for implementing systems and processes to ensure that the contractor complies with all safety requirements detailed within the contract specification. This may take the form of audit, review, monitoring and consideration of safety performance. 3.4.8 The Head of Supply Chain and Logistics will oversee monitoring of supplier performance and will arrange periodic supplier audits in accordance with procedure LUKL-PRO-003 Supplier Qualification to ensure that suppliers continue to meet the requirements for maintaining approved supplier status. 3.5 Risks Associated with the Use of Contractors 3.5.1 Loram UK uses a variety of contractors to undertake and support parts of its business activities. These include services such as statutory inspection of lifting equipment, non-destructive testing and the removal of waste materials.

3.5.2 Loram UK procures the services of contractors through the arrangements defined in procedure LUKL-PRO-002 Procurement. This includes an initial assessment of the product or services being procured to assess whether they are safety related or safety critical in accordance with procedure LUKL-PRO-006 Procurement – Safety Validation of Contracts, and to ensure safety validation is carried out and contractual controls are put in place as indicated in section 3.4 above where contractor activities are safety related or safety critical. 3.5.3 Loram UK’s arrangements for management of contractors working on the Loram UK site are detailed in procedure LUKL-OCC-105 Control of Contractors to ensure contactor’s employed by Loram UK:

• Understands the risks to the railway associated with their activity or service

• Is competent in terms of quality and safety, i.e. has a management system and certification compatible with that of Loram UK and Network Rail (where appropriate)

• Is competent to supply to the required quality to national or international standards

• Meets any environmental requirements

• Carries the appropriate Insurance

• Undertakes all necessary controls to ensure the requirements of Loram UK are met

• Manages and audits any sub-contractors they employ

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• Describes its scope of supply 3.5.4 Contractors undertaking site work must be in possession of a valid access permit. 3.5.5 Risk based monitoring will be established appropriate to the nature of the contract and this will include management safety inspections being carried out by the contract manager or other delegated manager to ensure that the contractors are complying with the requirements of the contract. 3.6 Controlling Risk 3.6.1 Loram UK controls risk through the application of the hierarchy of risk control:

E - Eliminate / Avoid the hazard at source, e.g. use alternative substance R - Reduce / Combat the hazard at source, e.g. dilution, battery rather than mains tools I - Isolate / Remove the person from the hazard, e.g. automation, task change C - Control / Contain the hazard, e.g. shielding, barriers D - Documentation and training, e.g. competence assessment, safe system of work, permit to work P - Personal Protective Equipment, e.g. face masks, gloves

3.6.2 Typically, Loram UK’s control measures are based on a combination of:

• Reducing risk at source, identifying lowest risk substances and lowest risk processes;

• Using technology to control risk and avoid individual exposure to risk;

• Giving collective control measures priority over individual control measures;

• Providing employees with the tools and equipment required to undertake the task safely;

• Designing processes and developing safe systems of work to minimise exposure to risk

• Development of operational procedures and working instructions that are fit for purpose;

• Selection, recruitment, training, supervision and assessment of competent staff;

• Regular review of risk assessments to ensure that control measures remain valid;

• A structured process for managing change;

• Investigation of accidents and incidents to determine their root cause and development of additional control measures to prevent their recurrence;

• Regular communication and feedback on safety related issues;

• Effective arrangements for dealing with emergency situations;

• Liaison with other parties (in particular Infrastructure Managers and maintenance providers) regarding risk mitigation measures for risks outside the direct control of Loram UK;

• Monitoring the effectiveness of control measures through the setting and monitoring of safety KPIs and through regular inspections and checks on working practices and compliance with the SMS;

• Internal auditing of compliance with standards;

• Learning from external sources, especially RSSB research and knowledge bases, and RAIB reports. 3.6.3 Risk control and mitigation measures are agreed by the risk assessment team during the process of completing the risk assessment, considering the risk control hierarchy detailed in 3.6.1, and are documented in

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the risk assessment. Risk controls are then implemented through provision of a combination of work equipment, tools, procedures, working instructions, training and briefing. 3.6.4 Where risks are controlled by procedures and working instructions, any significant changes to the documents will trigger a briefing and/or a revised training package to ensure staff awareness of the changed process – see 4.3 Implementing Company Procedures. Any significant changes to training packages will trigger a re-training of relevant staff. 3.7 Monitoring the Effectiveness of Risk Control Arrangements 3.7.1 The proactive monitoring activities detailed in LUKL-OCC-101 Health and Safety Monitoring and Inspection provide monitoring of workplace conditions and work practices to evaluate the effectiveness of risk controls. 3.7.2 Reactive accident and incident reporting and investigation processes (see Section 11) provide evidence of compliance or suitability of control measures. 3.7.3 Staff are made aware of risk controls and the level of residual risk during training and briefing, and are encouraged to use the feedback arrangements (see Section 11.1 Safety Incidents and Safety Opportunity Reporting) to highlight any weaknesses in the effectiveness of control measures. 3.7.4 The results of monitoring are provided to the Assurance Director who compiles and maintains a tracker in the form of a Balanced KPI Dashboard (see section 15.2 Measuring and Monitoring Safety Performance) and determines whether further action is required to address adverse trends; overall performance is monitored through the health and safety team and reported to the Board periodically.

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4 Maintaining Compliance with Standards and Legislation 4.1 Identification of External Requirements 4.1.1 Loram UK has processes in place to maintain awareness of external requirements which may impact on the business, to review these requirements, and to reflect them where necessary in internal procedures in the SMS. The processes are detailed in procedure LUKL-MSP-001 Document Review and Document Control. 4.1.2 The Health, Safety and Environment Manager is responsible for ensuring that new or updated legislation, railway industry National Safety Rules (such as Railway Group Standards), external safety/environment documents and other external requirements are identified and, where relevant to Loram UK’s operations, entered into the document review and control process by the Document Controller. 4.1.3 The Head of Engineering and Integration is responsible for ensuring that new or updated engineering related legislation; railway industry standards, Technical Standards for Interoperability, other external quality documents and customer supplied documents are identified and, where relevant to Loram UK’s operations, entered into the document review and control process by the Document Controller. 4.1.4 The identification of new or updated external safety, environmental and quality documents is assisted by subscription to various publications, websites and professional body memberships. 4.1.5 The Document Controller and the Document Control Point for Railway Industry purposes. The Document Controller maintains a record of the external quality, safety and environmental documents and customer supplied documents that are applicable to Loram UK’s operations on the Document Control Database and Legislation Register (LUKL-MSP-005). 4.1.6 External requirements are monitored and reviewed by the Professional Heads, Informed Buyers and other company experts, via a process managed by the Safety Assistant in accordance with LUKL-MSP-001 Document Review and Document Control for safety, environmental and operational requirements, and LUKL-ENG-011 Engineering Document Review for engineering and train maintenance requirements. 4.1.7 Where compliance cannot be achieved with an industry specific requirement laid down in a Railway Group Standard within the required timescale, the Assurance Director will be advised and will consider the implications of applying for a temporary non-compliance (deviation), and initiate this process if necessary. 4.1.8 The review will determine if any action is required, which may include changes to existing procedures, development of new procedures, adoption of specific customer requirements, or other changes to the safety management system. 4.2 Development of Company Procedures 4.2.1 Company Procedures are prepared where there is a need to have a documented process to ensure that the requirements of legislation, RGS or risk mitigation measures are applied consistently to manage risk. 4.2.2 Policies and procedures supporting the quality, safety and environment management systems are developed by the professional heads and are produced to a common format. Forms are linked to specific procedures, and support the procedures. Procedures and forms are written to ensure clarity of information and

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in plain English to aid comprehension. Procedures are numbered in accordance with the notation outlined in Section 2.3. 4.2.3 Notices and briefing documents use standard health and safety signs where appropriate, and are coloured to catch attention, for example orange for safety notices and green for environmental notices. Formal safety signs are produced in accordance with LUKL-OCC-312 Safety Signs and Signals using approved colours and symbols compliant with the Health and Safety (Safety Signs and Symbols) Regulations 1996. 4.2.4 Line managers may develop local working instructions to support the implementation of company procedures, or where they are required to control risks specific to the location in question. The line manager is responsible for getting these local working instructions approved by the Health, safety and Environment Manager and for ensuring that staff and contractors affected by these local instructions are briefed and fully understand, these requirements before they commence work on related tasks. 4.3 Implementing Company Procedures 4.3.1 The Assurance Director ensures that all health, and safety policies and procedures are consulted and agreed with the Health and Safety Committee prior to implementation. LUKL-MSP-002 Safe Management of Change sets out the process to implement a change and the details needed to deliver that change. 4.3.2 The author of a document and the relevant Professional Head are responsible for agreeing and initiating the implementation arrangements for internal procedures, and this must include structured and comprehensive briefing arrangements for all persons required to have knowledge of, or responsibilities allocated in the document 4.3.3 Some company procedures require supporting facilities, tools or equipment, or may require training packages to be developed and implemented. The procedure author is responsible for ensuring that all of these are provided as part of implementing the procedure. 4.4 Monitoring the Effectiveness of Company Standards 4.4.1 Monitoring of the implementation of company standards and procedures is carried out through line management inspection and the internal audit regime described in procedures LUKL-OCC-101 Health and Safety Monitoring and Inspection and LUKL-MSP-004 Audit. Successive higher levels of management undertake a hierarchy of superimposed checks, and provide feedback to functional managers. See Section 13 for more details of monitoring and audit arrangements. 4.4.2 The Managing Director and direct reports (the Senior Management Team) satisfy themselves that procedures are implemented and operated effectively through a program of Director Safety Tours and provide feedback on the overall effectiveness of the SMS to the HS&E team. 4.4.3 Planned internal audits are carried out in accordance with LUKL-MSP-004 to confirm compliance and efficacy of procedures – see Section 13.3. 4.4.4 The Assurance Director ensures that safety procedures are subject to periodic review as part of the ongoing development of the company’s SMS, and a wider holistic review of the safety management system is carried out annually involving the senior team see Section 16.

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5 Change Management 5.1 Overview of the Change Management Process 5.1.1 Any change has the potential to introduce new risks or to change existing risks. LORAM has established a change assurance process that is set out in LUKL-MSP-002 Safe Management of Change. It ensures that the safety implications of any change are identified and assessed before the change is made. 5.1.3 Procedure LUKL-MSP-002 Safe Management of Change provides a formal governance and assurance process managed and supported by the SMT. The process incorporates a categorisation system appropriate to the nature of changes experienced on LORAM operations. A series of decision gates within a change life-cycle that is adaptable to the specific change and the associated risks. The appropriate decision gate is to be passed in advance of a change being implemented. 5.1.3 The objectives of the change management process are to ensure that:

• The safety and performance implications of proposed changes are identified • All relevant stakeholders are involved in the change review process and that comments raised by

the stakeholders are resolved • Safety risks are identified and effectively managed • Changes are planned and implemented safely.

5.1.4 Assurance determinations are made by an independent Change Review Panel (CRP) voting members, primarily based on recommendations made by suitably competent persons. 5.1.5 Other procedures provide additional support and guidance where specific changes are identified, including:

• Externally driven changes arising from a document review (LUKL-MSP-001)

• Changes which trigger the requirement to apply CSM or Interoperability processes (LUKL-OCC-209)

• Engineering changes that do not trigger CSM or Interoperability (LUKL-ENG-008) 5.1.6 Changes related to technical, operational or organisational changes affecting safety which are deemed a significant risk will trigger additional safety validation processes to comply with the requirements of the Common Safety Method on Risk Evaluation and Assessment in accordance with LUKL-OCC-209 Change Management for Significant Risks. 5.1.7 The category of change is used to determine the level of assurance that will be applied during the change, including independent review and submissions to the Change Review (CRP). 5.2 Identification of Changes 5.2.1 Any manager becoming aware of or intending to make a change that falls within the scope identified above must, in the first instance, obtain authority to proceed from a sponsoring Director. 5.2.2 Following authority to proceed from the sponsoring Director, the manager (Owner) registers the change by completing a Change Assessment Form (F-MSP-002-1) and sends this to the Health, Safety and Environment

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Manager. The Health, Safety and Environment Manager (in liaison with the relevant professional heads) will determine what level of safety validation is appropriate for the proposed change. 5.2.3 As part of the change assurance process, the initial safety risks are assessed in accordance with arrangements set out in Section 3 to determine the main risks associated with the change and the category of change. The assessments are carried out by staff with the necessary competence to identify hazards, assess risks and determine actions necessary, before, during and on completion of the change. 5.2.4 Where the Change Assessment Form indicates that there is no impact on health and safety the Health, Safety and Environment Manager will notify the Owner that the change can be progressed locally without any further formal safety validation. 5.2.5 Where the Change Assessment Form indicates that there is a potential that the change will impact on safety and involves a technical, operational or organisation change, the Health, Safety and Environment Manager will liaise with the relevant professional heads to identify the significance of the change based on the screening criteria in the Common Safety Method for Risk Evaluation and Assessment [ref 4]. 5.3 Safety Validation of Significant Changes 5.3.1 Where a change is deemed to be Significant, the relevant Professional Head will lead safety validation and will apply the requirements of the Common Safety Method for Risk Evaluation and Assessment by reference to the ORR Guidance (Common Safety Method for Risk Evaluation and Assessment, ORR Guidance, March 2015). 5.3.2 RSSB have developed extensive guidance on the risk evaluation and assessment methodology which can be applied to demonstrate compliance with the CSM, and this will be used by the Professional Head when planning the safety validation process. This includes:

• GE/GN8646 Guidance on the Common Safety Method on Risk Evaluation and Assessment

• Common Safety Method for Risk Evaluation and Assessment – Guidance on the application of Commission Regulation (EU) 402/2013

5.3.3 The Railway (Interoperability) Regulations 2011 [ref 5] require new, upgraded or renewed structural subsystems or vehicles to be authorised to be placed into service on railway network in the UK. The design has to comply with the relevant Technical Specifications for Interoperability (TSIs) in order to meet the ‘essential requirements'. The essential requirements cover health, safety, environment, technical compatibility and reliability. The Professional Head will use the DfT’s published interoperability help notes to provide guidance on ensuring the change complies with the regulations. 5.3.4 For Significant changes the Professional Head will develop a safety validation plan in accordance with procedure LUKL-OCC-209 Change Management for Significant Risks, taking the above guidance (5.3.2 and 5.3.3) into account. 5.3.5 Detailed records of the safety validation are maintained by the Professional Head to demonstrate compliance with the CSM and RIR.

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5.4 Safety Validation of Other Changes 5.4.1 Where the change falls within the scope in Section 5.1 requiring independent safety validation, but outside the requirements for significant change, the Owner will be notified of this by the Health, Safety and Environment Manager, along with identification of any specific safety validation arrangements which may be required for the change. 5.4.2 On receipt of this notification, the Owner must then complete a Form F-MSP-002-2 Safety Validation of Change Proposal and any other specified safety validation requirements. The form template provides guidance on following a structured change process. 5.4.3 The level of detail provided to explain the change is required to be proportionate to the degree of risk potentially introduced by the implementation of the change. The level of detail must be adequate to ensure that the change is clearly defined, adequately controlled, well argued, necessary and will deliver the intended benefits. It must also confirm that the change will, when implemented, not increase risk to affected persons or operations, nor will it result in an unintended reduction in operational performance. 5.4.4 On completion of the Form F-MSP-002-2 the Health, Safety and Environment Manager will review the nature of the change and determine which of the Professional Heads is best placed to validate the proposal and will liaise with them to ensure that all the required information has been submitted. The Professional Heads will evaluate the safety validation submission against the safety management system using their professional judgement. 5.4.5 The Professional Heads will liaise with the owner via the Health, Safety and Environment Manager on any issues that they believe require further attention and when satisfied that the safety validation demonstrates ALARP will confirm their approval of the change by advising the Health, Safety and Environment Manager and counter-signing the Safety Validation of Change Proposal. 5.4.6 The category of change and the assurance arrangements are agreed with the CRP. 5.4.7 Assurance is carried out throughout a change, depending on the agreed category of change, through a series of submissions to the CRP to ensure that the risks associated with the changes have been identified and assessed, and that the agreed control measures to eliminate or mitigate the risks have been implemented. 5.5 Safety Certificate Changes 5.5.1 Where the change is considered to warrant it, the Assurance Director will ensure:

• A review is carried out on the safety validation documentation that considers the impact of the change on the Safety Certificate, with reference to the ORR Acceptance Criteria

• The Safety Certificate is amended accordingly

• Arrange distribution of the revised Safety Certificate to interested parties

• Notify the ORR – if the change is considered to be significant 5.5.2 Records of less significant changes will be recorded and will either cumulatively trigger a review or will be absorbed into the Safety Certificate at the three yearly review.

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5.5.3 For substantial alterations to the type or extent of operations, Loram UK will apply to the Office of Rail and Road (ORR) for an amended certificate before the changes are introduced. For all other significant changes (such as the introduction of new rolling stock, or major organisational changes), the ORR will be informed without delay. 5.6 Authorising and Implementing Changes 5.6.1 Following receipt of the necessary approval of the safety validation from the CRP, the Health, Safety and Environment Manager will issue a Certificate of Approval of Safety Validation (Form F-MSP-002-3) to the owner. 5.6.2 Following receipt of the Certificate of Approval of Safety Validation the Owner is responsible for implementing the change in accordance with the implementation plan defined in LUKL-MSP-002 Safety Management of Change Appendix C. This will include making any necessary changes to the safety management system or associated documentation, carrying out any management briefing, staff toolbox talks or staff training as necessary to support the change, and monitoring the outcome of the change to ensure it meets the expected outcome.

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6 Training and Competency 6.1 Competence Management Overview

6.1.1 Loram UK recognise that for the safety management arrangements to be effectively implemented and for the safety risks associated with its activities to be properly managed, it is essential that staff and others who work for Loram are competent to do so. 6.1.2 The minimum qualifications, experience, training and competence requirements for a particular job are detailed in the Job Description / Safety Responsibility Statement for the post in accordance with procedure LUKL-HRP-002 Job Descriptions and Safety Responsibility Statements. The Human Resources (HR) Business Partner is responsible for ensuring that the expertise and resources are available to support the Loram Line Managers in:

• The recruitment and selection of staff • The verification of qualifications of applicants.

6.2 Identification of Safety Critical / Safety Related Tasks 6.2.1 Loram UK is committed to ensuring that tasks that have a safety element (including those classed as safety critical in line with the definition in ROGS [Ref 2]) are identified and that persons do not undertake such duties unless they are fit and competent to do so. Procedure LUKL-OCC-503 Determining Safety Critical Roles is used to identify roles which undertake safety critical work, by screening roles against the activity criteria contained in ROGS and ORR Railway Safety Publication 4 – Safety Critical Tasks – Clarification of ROGS Regulations Requirements. 6.2.2 Loram UK has identified safety critical activities in Section 2.6 Safety Critical Activities in which competence standards have been developed.

6.2.3 Competence standards are developed for each job identified as having a safety critical role as defined in Railways and Other Guided Transport Systems (Safety) Regulations 2006 Regulation 23. As a minimum, a competence standard shall take account of the operational risk and make a statement of;

• what an individual can do and how well, in order to achieve the intended outcome of work. • the range of circumstances in which the ability is to be demonstrated. • the knowledge needed to complete the work. • the types of evidence required to confirm that performance is consistent and can be sustained. • how this would be assessed. • the NTS behavioural elements required to perform those competences where specified.

6.2.4 Competence standards have been established for managing and assessing competency (including the provisions in place for recruitment and training), maintaining competency, and monitoring levels of competency (see Section 6.1).

6.2.5 Where managers or supervisors carry out safety critical activities on an ‘as required’ basis, they are designated as safety critical and are subject to the same competence standards and assessment criteria as individuals who undertake these activities on a regular basis. The table 4 illustrates those managers and supervisors and the relevant safety critical duties that they may be called on to undertake:

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Table 4 Train driving On Call Train maintenance Operations Standards Manager Y Y Production Leads and Team Leaders Y Y

6.2.6 Certain posts have designated authority for specific matters that are essential to the SMS and to the safety of operations, e.g. approving or authorising standards. These posts are not classed as safety critical, but are Key Safety Posts and their key safety responsibilities are reflected in the job descriptions and safety responsibility statements. Loram UK ensures that post holders are competent to the standards and qualifications established in the personal specification for these posts, and such posts must have a designated deputy who is equally qualified and competent. Further details on Key Safety Posts can be found in Section 2.5 and Appendix 3. 6.3 Recruitment and Selection 6.3.1 The Human Resources Director is responsible for ensuring appropriate standards are applied in the recruitment and selection process for all managers and staff. 6.3.2 Where people are to be appointed to safety-critical roles specific criteria are applied for medical fitness, as detailed in procedure LUKL-OCC-205 Recruitment, Selection and Medical Fitness Standards for Safety Critical Roles. This procedure complies with the requirements of railway industry Group Standards GO/GN3655 Guidance on Medical Fitness for Safety Critical Workers and RIS-3451-TOM Train Drivers – Suitability and Medical Fitness Requirements 6.3.3 The Human Resources Director will ensure that when recruiting train drivers, medical fitness assessments and occupational psychological fitness assessments are only carried out by doctors and providers recognised by ORR in accordance with the Train Driving Licensing and Certificates Regulations 2010. 6.3.4 All new entrants, and existing employees promoted into posts where they could affect safety, undergo screening for drug/alcohol in accordance with procedure LUKL-POL-004 Drugs and Alcohol. This procedure complies with railway industry Group Standard RIS-8070-TOM Testing Railway Safety Critical Workers for Drugs and Alcohol. Any individual who fails the screening will not be considered for employment, or will be dealt with under the disciplinary process as appropriate. 6.3.5 All new entrants will receive company induction in accordance with procedure LUKL-HRP-001, which includes basic safety training and awareness, and a training needs analysis to identify individual training needs. 6.4 Provision of Training 6.4.1 Line managers ensure that all employees receive sufficient training to ensure the competent and proficient performance of their work. 6.4.2 Loram UK will ensure that the training needs for each post are identified in the job description and that the training needs of those appointed to such posts are met. Classroom and practical training modules have been developed which are appropriate to the tasks to be performed. The content and duration of the training are scaled to match the competence requirements and the specific needs of individual candidates.

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6.4.3 The Professional Heads are responsible for ensuring that training standards are established and maintained that are suitable and sufficient, and that training is delivered by trainers competent both in training techniques and also in the subject matter as set out in 6.5.1. 6.4.4 Trainers are required to deliver training to meet the competence standard and shall, as a minimum, be trained in:

• maintaining a training environment suitable for the learning process. • delivering training according to the competence standard, appropriate delivery techniques, relevant

approved training schedules, session plans, materials, and question analysis. • providing an open environment and encourage candidate engagement. • evaluating candidate progress, including additional learning support where appropriate • encouraging and review candidate feedback for continuous improvement • recording candidate progress to specific competences in the competence standard

6.4.5 Trainer competence for delivering training should be based on one of the following qualifications or equivalent recognised certification:

• City & Guilds (C&G) Certificate - C&G 7301, 7306 or 7331, OR • Employment National Training Organization (ENTO) ‘L’ Units L9, L10, L11 and L13, OR • NVQ Level 3 in Direct Training or in Training and Development (or equivalent).

6.4.6 Trainers must also be able to demonstrate suitable occupational competence in the subject area in which they are required to deliver training. 6.4.7 Safety critical roles require specific job training relevant to the role in accordance with specified Loram UK standards as follows:

• Train Drivers – LUKL-OPS-402 Train Driver Training, LUKL-OPS-404 Traction Training, Assessment and Refresh, and LUKL-OPS-404 Train Driver Route Learning

• Depot Drivers – LUKL-OPS-411 Depot Driver Training • Shunters – LUKL-OPS-421 Shunter Training • Train maintenance staff – LUKL-ENG-002 Maintenance Policy • Rail grinder operator/drivers • Rail grinder shift managers

6.4.8 Loram UK will source train driver training from a training provider who is recognised by ORR in accordance with the Train Driving Licensing and Certificates Regulations 2010. The Head of Operations will ensure that prospective train drivers either hold a Train Driving Licence or will apply for one on their behalf from ORR during their training period, prior to them operating a train unsupervised. 6.4.9 Functional Heads are responsible for ensuring that suitable training and/or qualifications are held by their line managers, supervisors and other staff, in accordance with the Job Descriptions and Safety Responsibility Statements for their roles. 6.5 Competence Assessment and Monitoring 6.5.1 LUKL-OCC-504 Competence Management of Safety Critical Work describes the arrangements for maintaining and assessing the competence of staff performing safety critical activities. It covers the over-arching

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competence management system requirements and works in conjunction with supporting procedures detailing the competence standards for specific safety critical roles as follows:

• LUKL-ENG-003 Rail Vehicle Maintenance, Overhaul, Repair and Modification Competence Requirements

• LUKL-ENG-016 Engineering Technician Competence Management Standards • LUKL-ENG-017 Grinder Technician Competence Management Standards • LUKL-OPS-405 Train Driver Competence Management Standards • LUKL-OPS-412 Depot Driver Competence Management Standards • LUKL-OPS-422 Shunter Competence Management Standards • LUKL-OPS-432 Duty Control Manager Competence Management Standards • LUKL-OPS-442 OSM Competence Management Standards • LUKL-OPS-471 Depot Safety Certificate Competence Management Standards • LUKL-OPS-500 Rail Grinding Operational Procedures

6.5.2 Only employees with the correct knowledge, experience and expertise are allowed to undertake competence assessment of other staff. Assessors required to undertake competence assessments to meet the competence standard shall, as a minimum, be trained in:

• the application of the assessment procedures and documentation for assessment. • the relevant occupational skills, knowledge and experience to assess the categories of work

competence as set out in 6.5.1. • assessing competence against the relevant competency standard as set out in 6.5.1 and

assessment tools. • applying suitable assessment techniques and methods. • evidence collection requirements as defined in relevant competence standards. • recording requirements and processes. • V1 qualification for those assessor’s responsible for internal verification ensuring the quality of

assessment practice 6.5.3 Loram UK Assessor competence for delivering assessments should be based on one of the following qualifications or equivalent recognised certification:

• NVQ Level 3 Award in Assessing Competence in the Work Environment (Unit 1 &2), OR • Employment National Training Organisation Unit (NTO) A1/A2 or D32/33 NVQ assessor

qualification Assess Candidates Using a Range of Methods. 6.5.4 If a candidate fails to demonstrate appropriate competence, the competence assessor will inform the person’s Line Manager, giving the reasons for failure and the recommendations for further training. Candidates will not undertake any safety critical work until competence is restored, except as part of further training and assessment. 6.5.5 The Line Manager will make arrangements to ensure that any person failing to achieve the required standards of competence will only work under direct supervision of a competent person e.g. trainer or assessor, as part of a training programme aimed at achieving the appropriate competence standard. 6.5.6 Practical assessments consist of observing natural performance in the normal working environment and are supported with supplementary questions relevant to each performance criteria in the assessment file. This evidence is collected and evaluated throughout the assessment period.

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6.5.7 Line managers are responsible for ensuring that the procedures for fitness and competence are complied with, so that employees:

• are medically fit to undertake their duties

• undergo refresher training and periodic assessment at predetermined frequencies

• do not work excessive hours that are likely to result in loss of concentration due to fatigue (see LUKL-OCC-502 Safety Critical Working Hours and LUKL-OCC-507 Fatigue Management)

• are interviewed and/or their fitness and capability checked after being involved in accidents or incidents, or after return from a long absence (see LUKL-OPS-442 Operational Accident and Incident Investigation and LUKL-OPS-444 Chain of Care and Support)

6.5.8 Assessment files are maintained for all safety critical staff and any other staff in a formal competence management system (such as Designated Persons). The personal assessment file will record evidence of an individual’s competence and will contain records detailing:

• The individual’s personal details

• Assessment of performance recorded against the relevant criteria

• Records of exceptional or significant events as well as sub-standard performance

• Methods of assessment and decisions of competence 6.5.9 In addition train drivers are licenced in accordance with The Train Driving Licences and Certificates Regulations 2010 as detailed in Loram UK procedure LUKL-OPS-407 Train Driver Licensing and Certification. 6.5.10 Line managers must monitor employees who perform safety critical work and take action when performance is inadequate. Where there are circumstances potentially affecting a safety-critical worker’s performance, the Line Manager must ensure that the person is monitored in a way that permits review and improvement, and that the risks of harm are mitigated. Examples include return after long absence, personal or home related problems, and involvement in accidents or incidents affecting the person or colleagues. LUKL-OPS-444 Chain of Care and Support outlines appropriate measures that managers may need to take. 6.5.11 Monitoring of employees’ continued fitness and competence takes place through the assessment regimes for safety-critical staff. In addition, checks are carried out when employees sign on duty. LUKL-OPS-463 Operational Staff Booking on and Off Arrangements outlines the signing on checks for drivers and shunters. 6.5.12 Specific processes are in place for managing issues which may affect the individual performance of train drivers, in accordance with procedure LUKL-OPS-406 Personal Development Plans. 6.5.13 Managers and staff are set personal safety objectives and personal development plans, and are assessed against their performance annually through an appraisal process (see Section 15.3). 6.6 Competence of Contractors, Consultants and Suppliers 6.6.1 Loram UK recognises the potential risks that can be imported by the use of suppliers and contractors, particularly those providing support on train operations and train maintenance, and seeks to control these risks by the implementation of procurement and contractor management processes. These policies apply to anyone carrying out specialist safety related work on behalf of Loram UK whether undertaken remotely or on LUKL-managed property.

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6.6.2 Procedure LUKL-PRO-006 Procurement – Safety Validation of Contracts details the arrangements in place to procure services which may have a safety implication. This includes initial screening to determine the safety implications, triggering of safety validation where services are safety critical, and specification of the contract to ensure adequate competence and adherence to standards. These arrangements are summarised in section 3.4. 6.6.3 Procedure LUKL- OCC-105 Control of Contractors details the management processes in place to control use of contractors at the Loram UK site, and covers the following key elements:

• pre-qualification of contractors to adequate competence and supporting health and safety management systems ensure robust arrangements are in place

• selection of competent contractors relevant to the activity being undertaken • identification, assessment and control of risk to Loram UK, and Loram UK site risks relevant to the

contractor • agreement of safe methods of work • site access requirements • arrangements for monitoring of contractor performance • arrangements for post contract review

6.6.4 Loram UK procures goods and services from approved suppliers, which ensure any industry or vehicle owner standards and requirements are satisfied. Loram UK will pre-qualify suppliers in accordance with LUKL-PRO-003 Supplier Qualification. 6.6.5 Following approval, suppliers of safety critical materials are subject to on-going supplier assessment in accordance with LUKL-PRO-003 Supplier Qualification to ensure they maintain adequate quality control processes in place to ensure the safety and integrity of the products they supply.

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7 Train Integrity

7.1 Rolling Stock Supply and Maintenance 7.1.1 The arrangements to ensure the integrity of trains through effective planned maintenance are described in LUKL-ENG-004 Rail Vehicle Maintenance and Overhaul Plans. This procedure details the processes in place for developing and approving rail vehicle maintenance and overhaul plans and also details the processes for revising and adjusting maintenance intervals when required. 7.1.2 Loram UK will only operate vehicles that have been approved or authorised to operate on UK rail infrastructure in compliance with the relevant standards. The locomotives and track machines currently owned and operated are detailed in Appendix 4.

7.1.3 All vehicles currently planned to be used comply with all relevant requirements for the acceptance of rail vehicles onto Network Rail managed infrastructure on the basis of ‘Grandfather Rights’. This includes TSIs, and RGSs currently in force, specifically RGS RIS-2700-RST Rail Industry Standard for Verification of Conformity or Engineering Change for Rail Vehicles and RIS-8270-RST Assessment of Route Compatibility of Vehicles and Infrastructure. 7.1.4 LORAM also has a Wheelset Policy and Axle Bearing Policy, both of which form LUKL-ENG-026 ‘Wheelset and Axle Policy’, LUKL-ENG-004 – Rail Vehicle Maintenance and Overhaul Plans and LUKL-ENG-022 Handling and Storage of Wheelsets that meets the requirements of GMRT2004 ‘Rail Vehicle Maintenance’, GMRT2466 ‘Railway Wheelsets’ and GMGN2646 ‘Guidance on Axle Bearing Maintenance’. 7.1.5 The maintenance plans for rail vehicles Loram UK undertakes work on are detailed on the maintenance certificates for each vehicle. Maintenance plans are developed in accordance with LUKL-ENG-004 Rail Vehicle Maintenance and Overhaul Plans, and are published in the form of Vehicle Maintenance Instructions which detail the maintenance work required to be carried out at specific periodicities to maintain the integrity of the vehicles. 7.1.6 Changes to maintenance plans are managed in accordance with LUKL-ENG-004 Rail Vehicle Maintenance and Overhaul Plans. 7.1.7 Where Loram UK is registered as the Entity in Charge of Maintenance (ECM), it is the responsibility of the Professional Head of Engineering to maintain the technical file for that vehicle, including all current certification, and to ensure that the documentation in use is current and reflects the rail vehicles status. This is achieved by controlled issue of the Vehicle Maintenance Instructions to the IM Fleet Production Manager for planning and controlling maintenance on the vehicles. 7.1.8 Where Loram UK is not the ECM, customer supplied documentation will be issued on a controlled basis to the IM Fleet Production Manager for planning and controlling maintenance on the vehicles. 7.1.9 Vehicle Maintenance Instructions are translated into block cards, organising maintenance tasks by trade and safety condition, for staff to use when carrying out maintenance. Documentation is laid out clearly to identify the tasks to be undertaken, the sequence of tasks where this is important, any specialist tools required, and the expected outcome for any tests which may be required. Maintenance staff will sign off to indicate completion of work.

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7.1.10 Routine rail vehicle maintenance and repairs are planned by the Loram UK IM Fleet Production Manager in accordance with LUKL-ENG-012 Control of Rail Vehicle Maintenance. This mandates that rail vehicle maintenance is planned in accordance with either of the following methods. 7.2 Hired in and Sub-Leased Vehicles 7.2.1 The following arrangements are in place when LORAM hires in vehicles from an owner:

i. The supplier must be qualified in accordance with the requirements of RIS-2450-RST and LUKL-PRO-003 Supplier Qualification.

ii. The hirer confirms current approvals status including the transfer of information relating to any limitations for operation.

iii. The hirer confirms an approved maintenance plan which conforms to the requirements of GM/RT2004 and ECM Regulations.

iv. The hirer has arrangements in place carrying out safety inspections of the vehicles following maintenance, repair, overhaul etc.

v. The hirer has arrangements in place to ensure compliance with Railways and Other Guided Transport Systems (Safety) Regulations 2006, Regulation 23 ‘Safety critical tasks’, Regulation 24 ‘Competence and fitness of safety critical workers’ Regulation 25 ‘Manage fatigue’ and RIS-8270-RST ‘Drugs and Alcohol’ governing the competence and fitness to work of those undertaking maintenance on the vehicles concerned.

vi. The hirer provides reasonable access to LORAM to audit their engineering and operational management systems for the T&RS and OTMs.

vii. A list of hired in type of vehicle agreements operated by LORAM staff is included in the table Rolling Stock Hired and Operated by LORAM which can be referenced in Appendix X ‘Vehicle Classes Operated by Loram (UK)’.

7.2.2 Regular and long term hiring of vehicles not under direct engineering control which LORAM intend to use in service require assurance through regular audit and monitoring. Such services shall not be accepted or continued unless acceptable processes are in place and compliance is verified. The Technical Director is responsible for 3rd party suppliers from whom LORAM hire ensure those fundamental checks and inspections are carried out. 7.3 Maintenance Planning For Vehicles Where Loram UK are the Maintainer 7.3.1 The IM Fleet Production Manager, supported by the Planning and Capacity Co-ordinator, uses a planning tool – essentially a spreadsheet – which predicts the dates of the next planned maintenance of each type for each vehicle in accordance with the specifications of the relevant Vehicle Maintenance Instruction (VMI). Upon completion of planned maintenance of any given type, the records of the work are reviewed and when satisfied that the planned maintenance requirements have been met, the Maintenance Manager will update the planning tool with the date of completion for that planned maintenance in accordance with LUKL-ENG-004 Maintenance and Overhaul Plans. In most cases, the tool then calculates the date of the next planned maintenance of that type, and re-calculates the date of any other planned maintenance which is affected, for example where an annual exam resets the next planned date of a quarterly exam. 7.3.2 The planning tool is regularly reviewed by the Maintenance Manager, usually at intervals of no less than 8 calendar days. During this review process the Maintenance Manager will, as appropriate, schedule forthcoming

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maintenance on each vehicle in accordance with the output data from the planning tool, and check that the previous scheduling of any maintenance during earlier reviews is still valid. The Maintenance Manager will also review the forthcoming operational requirements advised by relevant customers and allocate the fleet vehicles to meet operational demand. At this time, in order to determine the most appropriate date upon which maintenance is to be scheduled, consideration will be given by Maintenance Manager to such things as:

• the location of the given vehicle and the type of maintenance required

• the operational requirements for that vehicle

• the maintenance requirements for other vehicles operating simultaneously with the vehicle being considered

• the availability of facilities and resources for completing works

• permitted tolerances for scheduled maintenance as specified in the relevant VMIs

• other forthcoming maintenance including that which could be scheduled simultaneously or earlier to promote efficiency

7.3.3 The planning tool colour codes the dates of forthcoming scheduled maintenance in order to assist the Maintenance Manager in determining the proximity of the date at which the maintenance is required. 7.3.4 In some cases for a relatively small number of fleet vehicles, the IM Fleet Production Manager is required to ‘manually’ calculate the date of some planned maintenance. Typically, manual calculations are carried out by the IM Fleet Production Manager for minor exams on class 97/3 locomotives (wherein the VMI specifies Service Checks / A Exams based on days in operation, assuming an annual accumulated mileage of 30k, but B Exams and above are based on calendar days). The IM Fleet Production Manager is responsible for collating the data relevant to each class 97/3 locomotive in order to compliantly schedule manually calculated maintenance. The principles of scheduling each specific maintenance event are identical to those described where the planning tool automatically calculates the date. 7.3.5 Maintenance is carried out in accordance with the requirements of the relevant Vehicle Maintenance and Overhaul Instructions:

7.3.6 The Maintenance Manager will allocate maintenance work to staff in accordance with their skills and competence for undertaking the necessary work, as detailed on the safety critical staff competence matrix, which records the specific competencies for maintenance staff. 7.3.7 Material used in train maintenance is sourced from accredited suppliers (see Section 6.6) which ensure that safety critical material meets Group Standard and other requirements and is traceable. 7.4 Maintenance Planning For Vehicles Where Loram UK are Not the Maintainer 7.4.1 For each vehicle, the Maintenance Manager will be advised by the vehicle maintainer of the next type of maintenance and any specific requirements related (i.e. maintenance location, and date). The Maintenance Manager will then allocate the vehicles as required to meet planned operational demand with due regard to the maintenance information provided by the maintainer. The Maintenance Manager will subsequently monitor the planned versus actual operational demand for the vehicle and ensure that when the next maintenance is due, that arrangements are made as appropriate with the maintainer for either:

• the vehicle to be returned to a location where the maintainer can provide the required maintenance, or

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• the maintainer to provide (or sub-contract) the required maintenance at a suitable location as mutually agreed

7.4.2 The maintainer is responsible for ensuring that all maintenance records are collated, reviewed updated and that subsequent maintenance events are recalculated as appropriate. 7.4.3 Maintenance providers are monitored in accordance the controls for contractor management as described in Sections 3.4 and 6.6 and interface communication and liaison as described in Section 13. 7.5 Defect Reporting 7.5.1 Rail vehicle defects found during maintenance will be rectified in accordance with the LUKL-ENG-012 Control of Rail Vehicle Maintenance, with suitable records retained to confirm defects have been rectified. Where these are ‘safety-critical’ defects, they must be reported to the Maintenance Manager in accordance LUKL-ENG-006 Rail Vehicle Safety Defect Reporting, who will allocate a risk priority and initiate corrective action. 7.5.2 Rail vehicle defects arising during service will be advised by the driver to Control if they affect the quality of service or operational safety. Control will ensure that any in-service vehicle defects are managed in accordance with LUKL-OPS-434 Operational Contingency Plan for Defective On Train Equipment to ensure the safe operation of the vehicle until the vehicle can be taken out of service or the defect rectified. 7.5.3 Control will notify in-service defects to the Maintenance Manager or other maintenance provider (where this is other than Loram UK) in accordance LUKL-ENG-006 Rail Vehicle Safety Defect Reporting, with the risk priority indicated. 7.5.4 The Maintenance Manager will ensure that safety-critical defects are cleared and appropriate corrective and preventive actions are put in place, notifying Control of any remaining defects or restrictions. Additionally, the Maintenance Manager will liaise with the Head of Engineering to report items of significant risk to others who might be affected in accordance with LUKL-ENG-006 Rail Vehicle Safety Related Defect Reporting to ensure that RIS-8270-RST Reporting High Risk Defects is complied with (i.e. via the NIR process). 7.5.5 The Maintenance Manager must arrange for defects to be recorded and cleared in the TOPS system. 7.5.6 Where a defect arising in service has been reported by Control to a third party maintenance provider, the Head of Engineering will liaise with the maintenance provider to ensure suitable corrective and preventative action is taken to close out the defect. 7.5.7 The Maintenance Manager will track safety-critical defects and analyse them by cause and significance to identify emerging adverse trends and will liaise with the Head of Engineering to ensure early preventative interventions to address such adverse trends. 7.6 Engineering Change 7.6.1 The arrangements to manage changes to any train through design change, test and experiment, or other modification are defined in LUKL-MSP-002 Safe Management of Change and in particular the supporting procedure LUKL-ENG-008 Engineering Change. Further details of the change process are described in Section 5.

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7.6.2 These procedures require proposed changes to be accompanied by risk assessments, and subject to Loram UK approval before implementation. The proposed change must also include methods for ensuring compatibility with TSIs and any other requirements of interfacing parts of the railway. Updates to the Technical File and Maintenance File are required for each vehicle type. 7.6.3 For changes that are Substantial or Significant, formal safety and compliance verification methods are required in accordance with LUKL-MSP-002 Safe Management of Change which meets the requirements of ROGS, Railways (Interoperability) Regulations, and the Common Safety Method for Risk Evaluation and Assessment. 7.6.4 A register of proposed and implemented engineering changes is maintained by the Professional Head of Engineering. 7.7 New or Substantially Altered Vehicles 7.7.1 For projects that are substantial in size compared with the routine management of engineering change (such as proposals to develop or introduce a new vehicle or train type to UK operation, or where the vehicle types are substantially different from the types in current operation), the requirements of LUKL-MSP-002 Safe Management of Change require that a formal project is established in accordance with LUKL-OCC-209 Change Management for Significant Risks to manage all aspects of safety validation including:

• Formal Safety Validation, and application of the Common Safety Method for Risk Evaluation and Assessment

• Obtaining all necessary approvals to allow the vehicles to enter service, including:

o Conformance with the requirements of applicable TSIs as confirmed by the issue of a Notified Body Certificate of Verification and technical file

o Conformance with the requirements of Notified National Technical Rules as confirmed by the issue of a Designated Body Certificate of Verification and technical file

o Demonstration that the vehicle is compatible with the infrastructure through completion of the compatibility assessment process defined in RIS-8270-RST

o Demonstration of an acceptable level of safety in the vehicle through the completion of a risk assessment in accordance with the CSM as confirmed through a Safety Assessment Report issued by an Assessment Body

• Production of or amendments to operating practices, training, processes and documentation

• Production of or amendments to engineering processes and documentation

• ORR notification and amendments to Safety Certificate 7.8 Technical Audit 7.8.1 The Technical Director, in conjunction with the Professional Head of Engineering, shall ensure through audit processes in accordance with LUKL-MSP-004 ‘Audit’, LUKL-PRO-006 ‘Safety Validation of Contracts’ and LUKL-PRO-003 ‘Supplier Qualification’ and LUKL-PRO-004 ‘Supplier Assessment’ that processes are in place such that the following is satisfied:

• Maintenance Instructions & Planning (GM/RT2004) • Safety Performance Monitoring and Defect reporting (RIS-8250-RST) • Qualification of Suppliers of Safety Critical Engineering Products & Services (RIS-2450-RST)

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• Railway Wheelsets (GM/RT2466) • Guidance on Axle Bearing Maintenance (GM/GN2646) • Data Recorders (GO/RT3272) (Note: withdrawn 2007 but remains a duty holder responsibility) • Assessment of compatibility of rolling stock and infrastructure (RIS-8270-RST) • Vehicle Registration (RIS-2453-RST) • Braking Principles for Rail Vehicles (GM/RT2045) • Certification (RIS-2700-RST) • Periodicity of VOI’s • Maintenance Records, input, storage, retrieval current (Shared systems) • Interface arrangements • Adequate facilities

7.8.2 Detailed lists of rail vehicles safety critical systems and services, which are incorporated in such an audit, can be referred to in LUKL-PRO-003 ‘Supplier Qualification’ and LUKL-PRO-004 ‘Supplier Assessment’. 7.8.3 LORAM do not sub-lease any vehicles to other operators

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8 Train Operations 8.1 Train Operation Methods 8.1.1 The safety of operation of trains is assured by Drivers and Shunters complying with the requirements of the national Rule Book, GE/RT8000, and supporting other Railway Group and Rail Industry Standards which are incorporated into Loram UK operational safety procedures. 8.1.2 The operational method is primarily Driver Only Operation (Non-Passenger). 8.1.3 Where defects and/or incidents arise during train operation, the driver is required to report the details to Network Rail, Loram UK Control or local management according to the type of defect and location. The driver is also required to complete the locomotive repair book, as a further method of recording defects. 8.2 Traincrew 8.2.1 Loram UK currently employs 3 mainline train drivers and a Driver Manager competent for operating mainline train operations. Loram has procedures in place to manage the training, assessment and development of existing and newly recruited drivers according to operational requirements and train resource plan. Where necessary, in house employed drivers will be supplemented with hired-in drivers to meet future demands. 8.2.2 Contractual arrangements are in place, in accordance with LUKL-PRO-006 Procurement – Safety Validation of Contracts, with approved providers for the hiring of drivers on an ‘ad hoc’ basis. Loram UK contact terms will stipulate strict adherence to relevant Railway Group Standards relating to the specific occupational fitness and operational competence of the hired driver for the operations they are expected to undertake. The contract will also specify which Loram UK standards and procedures must be complied with by hired in drivers. 8.2.3 Train drivers will only be hired in from train operators holding a current operating license and Railway Safety Certificate and operating similar traction to Loram UK. Where drivers are hired in, the supplying company is required to ensure that the drivers supplied are fit for duty, competent for the duties required (including traction and route competence), carry Safety Critical Work Identification or a Train Driving Licence, comply with the Loram UK Drugs and Alcohol Policy and have had an adequate rest interval before starting duty. The Loram UK Duty control Manager will request sight of confirmation of this competence and compliance, and will check this prior to the driver being permitted to drive a Loram UK train. 8.2.4 Loram UK will recruit train drivers in accordance with section 6.3 in accordance with LUKL-OCC-205 Recruitment, Selection and Medical Fitness Standards for Safety Critical Roles. This includes a psychometric assessment and assessment of communication skills to assess suitability for a driver role. Where recruited drivers have previous experience they will receive a training needs analysis against Loram UK’s train driver competence requirements to determine their training requirements. Otherwise recruited drivers will receive full basic driver training. 8.2.5 Loram UK employed train drivers will be trained in accordance with procedure LUKL-OPS-402 Train Driver Training and will be passed competent in accordance with procedure LUKL-OPS-405 Train Driver Competence Management Standards prior to operation of trains in service. Drivers must have rule book, traction and route competence for the train service to be operated.

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8.2.6 All drivers are required to achieve competency standards that meet or exceed industry guidelines. Assessments are carried out by assessors and verifiers who are competent to the standards set out in LUKL-OCC-504 Competence Management of Safety Critical Activities (See Section 6.5). 8.2.7 Route learning procedure LUKL-OPS-404 Train Driver Route Learning details the method of determining route norms for route learning purposes, lays down the acceptable methods for learning and maintaining route knowledge, and details the method of calculating minimum frequencies over which a route can be worked corresponding to the nature of the route to ensure route knowledge retention. Drivers who fail to meet the minimum criteria are restricted from working trains over that portion of the line until such a time as a route review has taken place with them. 8.2.8 Traction knowledge is gained in accordance with LUKL-OPS-403 Traction Training, Assessment and Refresh. Determination of route knowledge learning requirements is achieved by profiling key features relating to route characteristics and potential hazards associated with train operations in accordance with a route risk assessment process detailed in the procedure. The arrangements for route learning cover initial briefing, provision of minimum information, the required number of trips between two points, one to one briefing at complex centres, route learning diagrams and theoretical and practical assessments. 8.2.9 Route knowledge retention is built into driver diagrams to ensure drivers receive adequate experience over the planned route at various times, and always within the minimum frequency specified. Other methods of route knowledge retention may be employed for low frequency, low speed routes, including such methods as route videos and DVDs. 8.2.10 Traction knowledge is trained in accordance with LUKL-OPS-403 Traction Training, Assessment and Refresh. Traction risk assessments identify the specific training required for specific classes of traction, and conversion courses for trains with similar characteristics. Training always involves a mixture of theoretical and practical training. Traction knowledge is retained in a similar way to route knowledge, by ensuring adequate instances of working specific types of traction in the diagram cycle. 8.2.11 Routine information relating to changes in the infrastructure (e.g. speed restrictions) are communicated to traincrew through the issue on a signed for basis of Network Rail publications such as the Sectional Appendices, Periodic Operating Notices and Weekly Operating Notices, as detailed in procedure LUKL-OPS-401 Management of Train Drivers. Rule Book changes are communicated through a combination of personal issue of rulebook updates and briefing on changes. 8.2.12 Urgent or late notices are posted at the traincrew signing on point. Management of information through notices at signing on points is controlled as described in procedures LUKL-OPS-463 Operational Staff Booking On/ Off Arrangements and LUKL-OPS-433 Operations Control Manual. 8.3 Operational Risk and SPAD Management 8.3.1 Loram UK has a policy of reducing SPADs and other safety of the line incidents by the adoption of appropriate measures which reduce the occurrence of, and mitigate the consequences of, an incident. The Loram UK Health and Safety Objectives includes targets for the numbers of operational incidents and Loram UK has a process in place to develop an Operational Risk Management Strategy and supporting action plan to deliver these targets.

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8.3.2 Drivers are trained, briefed and periodically re-assessed in the adoption of ‘defensive driving techniques’ as defined in LUKL-OPS-408 Professional Driving Policy for use during periods of low rail adhesion and where signals are displaying restrictive aspects. This helps to reduce the risk of a SPAD occurring by ensuring that the train is driven in accordance with the prevailing conditions. Defensive Driving techniques are defined as Core Driving Skills within LUKL-OPS-405 Train Driver Competence Management System and form a critical part of any driver competence assessment. 8.3.3 LUKL-OPS-408 Professional Driving Policy, which has specific instructions concerning defensive driving and guidance to drivers on human factors and lifestyle factors contributing to SPADs, as well as key lessons learnt from previous SPADs (see section 11). 8.3.4 Loram UK locomotives are also fitted with a number of features that will reduce the risk of, and/or mitigate the consequences of SPADs. These features can be summarised as follows:

• Automatic Warning System – (as specified in GERT8075 AWS and TPWS Interface Requirements) fitted to all trains and signals as per the Sectional Appendix, to provide advance warning and reminder of a cautionary signal aspect

• Driver Reminder Appliance (as specified in GMRT2491 Design Requirements for a Driver’s Reminder Appliance) – fitted to all locomotives to ensure that, when set in accordance with the Rule Book, the risk of ‘start away’ type SPADs is reduced

• Driver’s Vigilance Device – (as specified in RIS-2761-RST Rail Industry Standard for Driving Cabs) fitted to some locomotives to maintain driver alertness by requiring release and reapplication of the Driver’s Safety Device (DSD), a foot pedal fitted to all trains requiring the driver to maintain a pressure to keep it depressed, otherwise the brakes are automatically applied

• Train Protection and Warning System (as specified in GERT8075 AWS and TPWS Interface Requirements) – fitted to all Locomotives to ensure, where equipment is fitted to signals, trains which pass the signal at danger are stopped within the signal overlap to mitigate the risk of collision

8.3.5 The arrangements for the continued operation of trains in service on Network Rail infrastructure, where the above on-train equipment is defective, are outlined in LUKL-OPS-434 Operational Contingency Plan for Defective On Train Equipment, which meets the requirements of Railway Industry Standard RIS-3437-TOM Defective On Train Equipment. 8.3.6 All operational safety incidents are investigated in accordance with Loram UK procedure LUKL-OPS-443 Operational Accident and Incident Investigation. This procedure details the investigation requirements, reporting processes and timescales. 8.4 Loram UK Operations Control 8.4.1 Loram UK Operations Control is responsible for managing and monitoring company train service activities and responding to events in conjunction with Network Rail which controls the minute to minute operation of the UK rail network. 8.4.2 The Loram UK Operations Control performs the following key functions:

• controlling and monitoring of the train service and drivers; • carrying out the booking on and off requirements of operational staff; • liaising with Network Rail over operational matters affecting the train service;

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• managing service recovery following disruption; • co-ordinating response and liaising with on-call staff concerning incidents; • implementing contingency plans; • liaison with the Maintenance Manager, the Professional Head of Operations, suppliers and other

parties over movement requirements; • maintaining a log of all operating incidents and safety-critical defects affecting the service, and

forwarding urgent information to Network Rail, maintenance providers and other affected Operators.

8.4. LUKL-OPS-433 Operations Control Manual details the protocols and processes in place in the Operations Control to discharge the above functions. LUKL-OPS-432 Rail Operations Controller Recruitment, Training and Assessment Competence Management Standards details the competence standards applicable to Operations Controllers. 8.5 Shunting Operations 8.5.1 Shunting has the potential to cause accidents giving rise to fatal and major injuries. They are associated with train collisions; train derailments; collisions with objects; and crushing or striking people on the line. Personnel who are required to carry out shunting duties are classed as safety critical workers. They are trained and assessed in accordance with Loram standards (see Section 6). 8.5.2 Any shunting which is carried out on Network Rail managed infrastructure by Loram UK is generally confined to terminal, service turn-back (reversal) points, fuelling points and associated stabling sidings. Staffing of moves corresponds to the type of signalling and move being made. Shunting at these locations is carried out as fully signalled movements with signals and points controlled by the relevant signaller for that location or can be carried out under the control of a shunter (unsignalled area). The Loram UK Operations Controller makes the necessary planning arrangements. 8.5.3 The RTC Yard is located adjacent to the Derby to Trent Junction lines. The yard is accessed off of these lines at two points. The limits of the Loram UK operated infrastructure are defined by ground position signals TD5043 & TD5049, which protect the main lines. The yard forms part of the RTC Business Park. 8.5.4 The only persons allowed to carry out shunting moves or control rail movements within the RTC yard are competent operational staff including shunt drivers, Yard Team Leader, his designated deputy, Shunter or TOC Trainman engaged in the arrival or departure of a train. 8.5.5 The RTC Business Park contains numerous buildings, several of which are rail connected that are operated by Loram UK. All rail connected buildings are protected by depot protection systems. Procedures are in place for use of this system as detailed in LUKL-OCC-501 Depot Protection. 8.5.6 For trains arriving into the RTC Yard, the signaller at Derby EMCC will advise the Shunter of trains approaching the RTC yard and agree the access route with the Shunter. The driver will stop when in clear of the main line and remain at a standstill until authorised to move by the Shunter. Unattended arrivals will be controlled in a similar fashion, except that the Shunter will advise the train driver, signaller and Control of the arrangements, including head code, prior to leaving duty. The Shunter will also give the driver instructions as to where the train should be stabled. In the event of disruption, these arrangements can be amended by agreement between the Control, signaller and drivers involved. Only one unattended arrival is allowed.

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8.5.7 For train departures, the Shunter will advise the signaller controlling Derby PSB Centre Panel of the train details, agree the departure route, obtain authority from the signaller to allow the driver to proceed to the agreed signal and advise the driver to obey the signal’s indication. If possible, the Shunter will observe the train whilst it runs towards the departure signal to check for anything untoward. 8.5.8 Unattended departures are controlled in a similar fashion, except that the Shunter will advise the train driver, signaller and Loram UK On call manager of the arrangements, including head code, prior to leaving duty. The train driver must seek authority from the signaller to move before the train is driven towards the exit signal. In the event of disruption, these arrangements can be amended by agreement between the Loram UK Control, signaller and drivers involved. 8.5.9 Trains are normally prepared / disposed of outside of depot protection to avoid disrupting activity within the associated workshop. Trains are prepared in accordance with the appropriate Loram UK operating procedures. 8.5.10 All shunting movements are undertaken in accordance with Rule Book GE/RT 8000 Module SS2. Local Instructions on the movement and protection arrangements on vehicles within the RTC Yard is detailed in LUKL-OPS-467 Depot Working Instruction – RTC Yard and are briefed to all relevant staff and embraced in their competency assessments. 8.5.11 The process for assessing the competence of shunters in the requirements of the Rule Book and local publications is detailed in LUKL-OPS-422 Shunter Competence Management Standards. 8.6 Urgent Operating Advices 8.6.1 Urgent Operating Advices issued by Network Rail in accordance with RIS-3350-TOM Communication of Urgent Operating Advice are received by the Loram UK Operations Controller who notifies the Loram UK Operations Standards Manager. The Operations Standards Manager will determine whether immediate action is necessary and if so will decide what actions are necessary and will then be responsible for initiating such immediate corrective action. The Operations Controller is responsible for initiating any preventative action, and follows the procedure in LUKL-OPS-433 Operations Control Manual. Copies of all RIS-3350-TOM Urgent Operating Advices are forwarded to the Professional Head of Operations who will review this immediate corrective action and determine whether any further preventative actions are necessary. 8.6.2 Operations Standards Manager is responsible for generating any Urgent Operating Advices identified as being necessary to communicate urgent operational safety information to Network Rail and other Train Operating Companies.

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9 Occupational Health and Safety

9.1 Introduction 9.1.1 Loram UK recognises the importance of protecting staff from occupational accidents and illnesses and providing effective welfare support. This Section outlines the arrangements in place to achieve these aims. 9.2 Types of Occupational Health and Safety Risk 9.2.1 Loram UK has undertaken task based risk assessments in accordance with LUKL-OCC-201 Risk Assessment to determine the occupational health and safety risks to which its staff may be exposed. It details the principal process by which we assess risks associated with the work activities carried out by our employees and documents and makes available the findings of those assessments (see Section 3). 9.2.2 Occupational health risks may be:

• Physical (e.g. noise (LUKL-OCC-302); vibration (LUKL-OCC-301), slip, trip and fall hazards)

• Biological (e.g. risks from contact with contaminated train underframes (LUKL-OCC-404))

• Chemical (e.g. risks from diesel exhaust (LUKL-OCC-402))

• Ergonomic (e.g. manual handling risks (LUKL-OCC-305))

• Psychosocial Factors (e.g. Wellbeing (stress – LUKL-OCC-401), alcohol and drugs (LUKL-POL-004)) 9.2.3 Other risk assessments are also completed by those competent to do so. These include occupational risk assessments required under specific legislation. Depending on the level of complexity, assessors will use both qualitative and quantitative assessment tools which have the overarching aim of reducing risk to ALARP.

9.3 Personal Protective Equipment (PPE) 9.3.1 PPE is regarded as a last resort and is only adopted to deal with the residual risk once all other practicable control measures have been implemented. The need for PPE is identified as part of the task risk assessments. 9.3.2 Suitable Personal Protective Equipment (PPE) is provided for all employees exposed to a risk to their health or safety while at work in accordance with Regulation 4 of the current PPE at Work Regulations. Minimum standards and requirements for PPE and workwear arrangements are set out in LUKL-POL-008 Personal Protective Equipment. Rail Industry High Visibility clothing conforms to RIS-3279-TOM High Visibility clothing. 9.3.3 Where the risk assessment identifies a need for PPE, such equipment is issued to relevant employees on a personal basis. The PPE is procured to meet the appropriate performance standards. All equipment complies with either BS or EN standards where applicable. 9.3.4 Employees are trained on the correct use, maintenance and storage of the PPE at the time of issue. The Line Manager/Supervisor keeps a record of PPE issued. 9.3.5 Line Managers/Supervisors undertake periodic checks on the correct use, maintenance and storage of PPE as part of the planned inspections process.

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9.4 Refusal to Work Policy 9.4.1 Loram UK’s safety policy encourages all staff not to start work if it is not safe to do so. In the event of any employee refusing to work on the grounds of health and safety, they report the circumstances to their supervisor, who will investigate the problem and make the required changes to the method of working so as to implement a safe system of work. 9.4.2 If the employee is still concerned that the proposed method of working is unsafe, there is a process to escalate the matter through the management chain, seeking guidance from the ORR where appropriate. 9.4.3 Loram UK’s refusal to work policy is detailed in LUKL-OCC-103 Working Safely. 9.5 Welfare Arrangements 9.5.1. Loram UK has in place a welfare and counselling policy that offers staff the opportunity to obtain assistance and specialist advice on a wide variety of issues that may affect their lives, with confidential access to professionally qualified counsellors provided through a contractual arrangement with an approved supplier. These counsellors are able to offer a range of professional, confidential services covering work related and non-work related issues. 9.5.2 The Human Resources Manager or another manager will support line managers in making home visits to employees who are on sick leave. The purpose of these visits is to ensure that employees are not encountering any difficulties as a result of their illness and to give advice and support where possible. 9.5.3 Loram UK has processes in place to support staff who have been involved in or affected by a traumatic incident. These arrangements are detailed in LUKL-OPS-444 Chain of Care and Support. 9.6 Plant and Equipment 9.6.1 Loram UK recognises the importance of ensuring that all plant and equipment is properly specified, purchased, stored, used and maintained in order to reduce the risk of accidents. These arrangements are detailed in LUKL-OCC-306 Provision and Use of Work Equipment, LUKL-OCC-310 Safe Use and Testing of Portable Appliances at Work, and LUKL-OCC-307 Facilities Management, Maintenance and Inspection. 9.7 Drugs and Alcohol Policy 9.7.1 Loram standard LUKL-POL-004 Drugs and Alcohol defines the policy and related implementation arrangements to control the risks of employees and contractors working for or on behalf of Loram being unfit through drugs or alcohol while at work. This Policy complies with railway industry Group Standard RIS-8070-TOM demonstrates Loram’s commitment to:

• the health and safety of its employees and contractors • prevent as far as reasonably practicable problems resulting from drug and alcohol misuse arising at

work • raise awareness of all Employees and Contractors to the effects of Drugs and Alcohol and recognise

the common symptoms of Misuse, including the impact on themselves and on their work • encourage those employees who Misuse Drugs and Alcohol to seek help voluntarily at an early

stage, before their performance at work is adversely affected and to deal fairly, consistently and in a

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supportive manner with those employees, provided they co-operate fully with the treatment programme

• assist managers/supervisors in dealing with drugs and alcohol misuse incidents at work • establish clear guidelines for dealing with misconduct arising from drugs and alcohol misuse

9.7.2 It requires contractors to provide their own drugs and alcohol policy to support Loram’s Standard as part of their health and safety management arrangements. 9.8 Control of working hours LUKL-OCC-502 Safety Critical Working Hours set out arrangements to control working hours for staff undertaking Safety Critical Work, specifically:

• designing and risk assessing working patterns. • working time limits and managing exceedances of working time limits. • monitoring and reviewing working patterns.

This standard applies to all operations and maintenance staff who undertake safety critical work and those who have responsibility for the rostering and/or management of staff who undertake safety critical work. Where exceedances are unplanned, they must be authorised by the Operations Controller. Where exceedances are planned, they must be authorised by the Head of Operations or nominated person. Any exceedance to the working time limits shall:

• consider the risks involved to make sure that the exceedance does not result in unacceptable risk to the individual or safety of the railway;

• consider the alternative options available. • identify mitigation measures to address the fatigue risks associated with the exceedance. • record the authorisation, including the additional mitigation measures to be implemented as

appropriate.

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10 Provision of Safety Information

10.1 Document Control Arrangements 10.1.1 LUKL-MSP-001 Document Review and Document Control details the responsibilities and controls in place for the review of external and customer documentation, production of internal management system procedures, and the issue, update, withdrawal, disposal and distribution of all Loram UK management system policies, procedures, drawings, work instructions, and externally supplied engineering and safety related information. 10.1.2 Internally produced documents associated with the quality, safety or environmental management system are issued and made available through the company intranet. Policies, procedures and other standards are watermarked as ‘uncontrolled when printed’ before being uploaded to the intranet. 10.1.3 Where an External Document is supplied to Loram UK and is required to be issued on a controlled basis within the business, or an internally produced document needs to be issued in controlled hard copy form, the relevant department document controller (safety or engineering) will be responsible for distributing the documents on a controlled basis. Documents issued on a controlled hard copy basis will be identified with a controlled copy stamp, showing the document reference number, issues number, issue date and location, and a record of such issue will be maintained by the department responsible for issue. 10.1.4 Where a controlled document is updated the relevant department document controller (safety or engineering) will be responsible for withdrawing and cancelling previous issues of the controlled document. 10.1.5 The Business Services team acts as the document control point for receipt by Loram UK of controlled documents from third parties. 10.2 Control of Records 10.2.1 Each procedure in the safety management system include details of records which are required to be created and maintained to satisfy the requirements of that procedure. This will also state the responsibility for maintaining the records and the retention period. 10.2.2 Records must be maintained in a legible, identifiable and traceable state. They should be stored either electronically or in hard copy form in a secure environment, enabling easy retrieval by authorised persons, and in a manner that preserves their integrity for the required retention period. 10.3 Internal Communication 10.3.1 The company aim is to provide effective channels of communication, ensuring that correct information is provided to and understood by all who require it to ensure safe operation. 10.3.2 A variety of methods are used to encourage effective communication with employees. These include:

• discussions with Health & Safety Representatives • workshops on particular health and safety issues and the ongoing development of the SMS • display of information on health and safety notice boards • mechanisms for safety induction and safety training

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• participation in national confidential reporting schemes • regular safety briefings • face to face briefing and coaching • cascade briefing through line managers • targeted training/coaching

10.3.3 Health and Safety meetings are seen as a two-way process and feedback on briefing material is encouraged. Items that cannot be dealt with locally are fed back to the appropriate level of management. Issues that can improve health and safety across the company are fed back to the Assurance Director so that they can be considered and incorporated in the SMS is relevant. 10.3.4 LUKL-OPS-401 Professional Driving Policy specifies that all drivers receive a safety briefing every 13 weeks at which the latest information about company safety performance, company policies and safety risks relevant to the vocational group are discussed. Other employees receive regular safety briefings as part of team meetings. Participants can raise issues regarding health and safety for discussion at these meetings. 10.4 External Communication 10.4.1 Loram UK maintains day-to-day communication with Network Rail and other key interface organisations relevant to train operations through the Operations Control, as described in 8.4 above. 10.4.2 More detail on the arrangements for communication with interface organisations is provided in Section 14.

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11 Accidents, Incidents and Safety Opportunities

11.1 Safety Incident and Safety Opportunity Reporting 11.1.1 LUKL-OCC-102 Safety Incidents and Safety Opportunities Reporting and Investigation describes the control arrangements in place within Loram UK for the reporting and investigation of Safety Incidents and Safety Opportunities. Safety Incidents include close calls, near misses, personal accidents and operational safety accidents and incidents. Safety Opportunities can include anything identified which has the potential to cause injury or damage. 11.1.2 In the event of a Safety of the Line Incident, Reportable Dangerous Occurrence or Specified Injury occurring, the Operations Controller will immediately notify the Loram UK On Call Manager as defined in LUKL-OCC-505 On Call Arrangements. The Operations Controller must liaise with the infrastructure owner, arrange for any immediately required emergency action or response to be initiated and follow the procedures and escalation process to the Senior Management Team as set out in LUKL-OCC-102 Safety and Environmental Incidents and Opportunities Reporting and Investigation. 11.1.3 For an operational Safety of the Line Incident or Accident it may be necessary to notify RAIB and ORR. LUKL-OCC-102 Safety and Environmental Incidents and Opportunities Reporting and Investigation indicates the type of operational Safety of the Line incidents or accidents where it is necessary to notify RAIB and ORR. The On Call Manager will normally arrange this through Network Rail Control, but for lower level incidents this reporting may be carried out by the Head of Operations. 11.1.4 For any other Safety Incident which occurs or Safety Opportunity that is identified, this is recorded and reported by the local manager or member of staff involved on an Initial Report Form (Form F/OCC/102/1), which is then forwarded to the Business Services team either directly by email or hand, or by posting in the reporting boxes provided in each workshop on the Loram UK site. 11.1.5 Traincrew and/or local management may be notified of accidents or potential accidents by members of the public or other railway industry staff. In all cases, this information should be forwarded to the Loram UK Control for logging and follow up by the appropriate team. 11.1.6 Operational staff report all safety of the line incidents to Network Rail in the first instance via the Signaller in line with Rule Book requirements. 11.1.7 In addition, when a personal accident occurs, either the first aider in attendance or the injured person must report the injury at an appropriate time on an initial report form. This is also recorded in the local Accident Book, and the slip removed from the book and forwarded to the Business Services Team in accordance with the instructions in the Accident Book, along with the Initial Report Form. 11.1.8 The Business Services team is responsible for collating records associated with Safety Incidents and Safety Opportunities, and where appropriate will also report such events into SMIS. 11.1.9 All staff are made aware (during the induction process) of the need to report accidents, incidents close calls and safety opportunities. Employees are reminded as part of the safety briefing process of the importance of timely and accurate reporting of accidents and incidents.

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11.1.10 Loram UK subscribes to the industry confidential reporting system CIRAS, and staff may use this system to report close calls, safety opportunities and other concerns if they do not feel able to report them through company systems. Reports forwarded to Loram UK by CIRAS are reviewed and actioned by the Health, Safety and Environment Manager, who also compiles a response to CIRAS for feeding back to the reporter. 11.2 Safety Incidents and Safety Opportunities Investigation 11.2.1 The purpose of the investigation process is to ensure that the root cause(s) and precursor(s) of the Safety Incident or Safety Opportunity are identified, and appropriate action taken to prevent any recurrence. The extent of the investigation will depend on the nature of the event, the potential severity, causes and cost. 11.2.2 The Business Support team capture and enter all Safety Incidents and Safety Opportunities into a tracking database. A responsible manager is appointed in line with LUKL-OCC-102 Safety and Environmental Incidents and Opportunities Reporting and Investigation to review and identify what corrective and preventative action may be appropriate, and to trigger an investigation where appropriate. 11.2.3 All Accidents and significant (In terms of potential consequences) Close Calls/Near Misses/Safety Opportunities are investigated. Most are investigated by local managers, but where a Safety Incident results in serious injury (i.e. Specified Injury) or a Reportable Dangerous Occurrence occurs, the Health, Safety and Environment Manager may carry out a more detailed investigation. For serious or reportable operational incidents, this responsibility falls to the Professional Head of Operations. In exceptional circumstances it may be necessary to convene a Formal Investigation. 11.2.4 Operational safety accidents, incidents and near misses are investigated by the Professional Head of Operations in accordance with LUKL-OPS-416 Operational Accident and Incident Investigation which conforms to RIS-3119-TOM Rail Industry Standard for Accident and Incident Investigation. 11.2.5 Loram UK will co-operate with other transport undertakings where accidents or incidents occur at points of interface with their infrastructure or with their operations. 11.2.6 Upon being notified of a Safety Incident falling within their responsibility the investigating manager must follow the measures described in LUKL-OCC-102 Safety and Environmental Incidents and Opportunities Reporting and Investigation and record the findings on the Accident/Incident Investigation Form F/OCC/102/3. 11.2.7 The Investigating Manager is responsible for retaining and recording all relevant evidence, involving and consulting other managers as necessary, determining the adequacy or otherwise of any control measures or systems of work in place, establishing the immediate and underlying causes, and determining any remedial actions or recommendations which might be necessary to prevent a repetition. 11.2.8 Where accidents and dangerous occurrences are reportable under RIDDOR, the local manager will advise the local Health and Safety Representative and encourage their involvement in the investigation. 11.2.9 Loram UK has identified in its Job Descriptions the training needs for designated managers in the investigation of Safety Incidents and Safety Opportunities. This training has been arranged so that they have the necessary skills to conduct impartial investigations, recognise potential severity, identify root causes and recommend remedial action.

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11.3 Statutory Reporting 11.3.1 Where a Safety Incident, Dangerous Occurrence, or Occupational Ill-Health occurs which requires reporting under RIDDOR, this reporting will be carried out by the Health, Safety and Environment Manager to either HSE or ORR as appropriate. 11.3.2 ORR is the safety regulator for Loram UK’s operational and train maintenance activities within the scope of our Safety Certificate where such reportable events occur on the operational railway, while HSE is the safety regulator for all of Loram UK’s other activities and the Loram UK site at Derby. 11.3.3 Formal reporting to ORR, when necessary, will be carried out using the on-line reporting tool on the ORR website. Any serious incident will be notified without delay by the on Operations Controller (e.g. by telephone). Confirmation details will be submitted within 10 days by the Health, Safety and Environment Manager. Less serious incidents and other RIDDOR reportable events will be reported by the Health, Safety and Environment Manager within 3 days using the on-line reporting tool on the ORR website 11.3.4 Formal reporting to HSE, when necessary, will be carried out by the Health, Safety and Environment Manager using the appropriate F2508 series form, usually completed on line. Any death, major injury or dangerous occurrence will be notified without delay (e.g. by telephone). Confirmation details and other less serious reports will be submitted within 10 days. 11.3.5 The Operations Controller will carry out initial reporting to RAIB of notifiable events by telephone. The Health, Safety and Environment Manager will arrange for notifiable events to be reported to RAIB using Form N1 notification form. 11.4 Implementing Recommendations for Improvement 11.4.1 Safety Incident and Safety Opportunity investigations and the recommendations arising from them are tracked by the Safety Assistant. Loram UK ensures that appropriate follow-up action is taken following every investigation where lessons to be learnt are identified. 11.4.2 Where specific remedial action is required, the investigating manager will define the responsible manager and the timescale for implementation in the investigation report. Recommendations from accident investigations will be recorded and tracked by the Health and Safety Manager to ensure they are closed out. 11.4.3 The Assurance Director will ensure that Loram UK learns from other by:

• Taking into account lessons learnt from other transport undertakings

• Reviewing RAIB reports for relevant lessons learnt

• Reviewing ORR repots of enforcement for relevant learnt

• Reviewing HSE bulletins and reports of enforcement for lessons learnt

• Reviewing formal inquiry recommendations for relevance to Loram UK 11.4.4 Any relevant lessons learnt will be summarised in a report which will be shared and discussed at the Health and Safety Committee, and this report will then be briefed to all staff through the monthly briefing process. 11.4.5 The Assurance Director will lead the implementation of any HSE or ORR recommendations on Loram UK.

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11.5 Trend Analysis 11.5.1 Loram UK uses data collected from its own records, as well as those input to SMIS, to analyse safety information and to identify trends. This enables the company to identify and eliminate precursors to accidents, with the aim of continuous improvement in safety performance – see 15.1. 11.5.2 The Assurance Director monitors the quality and accuracy of information input to SMIS and to Loram UK’s own databases. Compliance with the reporting procedures is monitored through internal safety audits.

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12 Emergency Planning

12.1 Emergency Planning 12.1.1 Loram UK has developed plans and procedures designed to provide an effective response to foreseeable emergency situations. These plans have been developed based on risk assessment, local knowledge, and experience, and are designed to bring accident/incident situations under control as quickly as possible. 12.1.2 For emergencies which occur on Loram UK’s site at RTC Business Park in Derby, procedure LUKL-OCC-107 Emergency Planning Arrangements details the arrangements in place and ensure that Loram UK’s arrangements comply with and are co-ordinated with the site emergency plans issued by Site Services and which are applicable to all site tenants. 12.1.3 For emergencies which occur on the main line railway involving Loram UK operated trains, procedure LUKL-OPS-465 Major Operational Incident Emergency Response details the arrangements in place which comply with industry requirements including the rule book GE/RT8000 and RIS-3118-TOM Incident Response Planning and Management. 12.1.4 In addition Loram UK has developed a suite of specific procedures that describe the arrangements for managing non-critical emergencies, incidents and de-graded working, including:

• Safety Incidents involving Loram UK staff and/or on Loram UK infrastructure – LUKL-OCC-102 Safety Incidents and Safety Opportunities Reporting and Investigation

• Minor accidents and incidents occurring on Network Rail controlled infrastructure – LUKL-OPS-408 Professional Driving Policy and LUKL-OPS-433 Operational Control Manual

• Dealing with defective on-train equipment – LUKL-OPS-433 Operational Control Manual and LUKL-OPS-434 Operational Contingency Plan for Defective On-Train Equipment

• Operational response arrangements for rail head treatment activities

• Dealing with adverse weather conditions and low rail adhesion – LUKL-OPS-433 Operational Control Manual, LUKL-OPS-408 Professional Driving Policy, and LUKL-OPS-461 Seasonal Preparation

12.1.5 Loram UK will participate in emergency planning exercises carried out by other occupiers of the RTC site and/or other Railway Group Members. 12.1.6 Loram UK will co-operate with Network Rail and other Transport Undertakings on co-ordinating emergency plans and participating in exercises and post-incident reviews. Where appropriate Loram UK will also engage with Network Rail in the Route Emergency Planning and Coordination Committee (REPACC). 12.2 Roles and Responsibilities 12.2.1 The Operations and Safety Director acts as the overall coordinator of emergency planning for Loram UK, and ensures that the company has appropriate contingencies in place to deal with any foreseeable emergency or other incident.

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12.2.2 The Health, Safety and Environment Manager will coordinate plans for emergency preparedness throughout Loram UK and with Site Services for emergencies on the RTC Business Park. This co-ordination will ensure that all plans align with each other and with those of other external parties, such as local authorities. 12.2.3 The Professional Head of Operations will lead co-ordination of operational emergency planning arrangements with Network Rail and other railway operators, ensuring plans are aligned and complementary. 12.2.4 Drivers are responsible for notifying the Network Rail signaller or other person in charge of the location in the first instance in the event of any emergencies, and then notifying the Loram UK Operations Control. Drivers are assessed on their understanding of emergency communication requirements, their capability to pass emergency messages clearly and effectively, and their ability to react quickly and accurately to messages passed to them from the infrastructure manager. 12.2.5 In the event of a major rail incident involving a Loram UK train service, Loram UK may be required to provide a Train Operator Liaison Officer (TOLO) who will liaise with Network Rail’s Rail Incident Officer (RIO). The duties and responsibilities of the designated TOLO are described in LUKL-OPS-465 Major Operational Incident Emergency Response. The Professional Head of Operations and Operations Standards Manager and others who may be required to be a TOLO undertake a dedicated training course, and subsequent validation and assessments to maintain their ongoing competence to act as a competent TOLO. 12.2.6 Where a train accident or incident involves a vehicle being operated by Loram UK but which is not maintained by Loram UK, in accordance with the notification procedure in LUKL-OPS-465 Major Operational Incident Emergency Response the Loram UK Operations Controller must inform the Professional Head of Engineering who will be responsible for liaising with the Entity in Charge of Maintenance for the vehicle. 12.2.7 The On Call Manager is responsible for activating the on-site emergency plans when notified of an emergency which requires escalation in accordance with LUKL-OCC-102 Safety Incidents and Safety Opportunities Reporting and Investigation. 12.2.8 The Loram UK Duty Control Manager is responsible for activating operational emergency plans, and for co-ordinating arrangements with those of Network Rail. The Operational Control Manual (LUKL-OPS-433) or equivalent procedures in the contractor’s safety management system detail the procedures for contacting relevant staff in the event of an incident, and the process of setting up an incident control centre of this becomes necessary. The Operational Control is responsible for managing the restoration of normal service following resolution of the emergency situation. 12.2.9 The Loram UK Head of Engineering or Head of Operations will provide information to Loram UK Operations Control for onward transmission and liaison directly with the Network Rail National Control Centre for the urgent communication of significant defects to rolling stock or significant operational irregularities in line with Railway Industry Standards RIS-8250-RST Reporting High Risk Defects and RIS-3350-TOM Communication of Urgent Operating Advices. In all other cases, the primary point of contact is through Network Rail’s Route Control Centre. 12.2.10 Loram UK do not carry dangerous goods or hazardous substances on our trains. In the event of a Loram UK train being involved in an incident with a train carrying dangerous goods, drivers are trained in the basic rule book requirements relating to incidents involving trains conveying dangerous goods, to ensure they can take basic precautions to protect everyone in the vicinity and themselves.

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12.2.11 Loram UK has a number of on call staff available covering both engineering and operational activities, and they have access to road vehicles that contain specific equipment to assist on call staff in an emergency situation. Details of this are in LUKL-OCC-505 On Call and Call Out Arrangements. 12.3 First Aid Arrangements 12.3.1 LUKL-OCC-314 First Aid at Work details the arrangements Loram UK has in place to provide adequate and appropriate equipment, facilities and personnel to enable first aid to be given to people who are at work or on Loram UK’s work premises who suffer injuries or ill health. 12.3.2 The Health, Safety and Environment Manager is responsible for carrying out a First Aid Assessment of Need for all Loram UK working locations and activities. The Assessment of Need is carried out in accordance with HSE Guidance L74 taking into account the circumstances of the workplace and work activities performed to ensure the provision of adequate and appropriate equipment, facilities and personnel for first aid. 12.3.3 First Aid boxes are provided in all workshops, with responsibility for maintaining the First Aid box allocated to an Appointed Person to carry out regular inspections of the First Aid box, checking its contents are correct. Loram UK has a defibrillator located on site, and first aid training includes the use of this equipment. 12.3.4 First Aid boxes are provided on trains, along with other emergency equipment such as ladders and fire extinguishers. Emergency equipment on trains is checked during routine maintenance and on train preparation. 12.3.5 All employees receive basic First Aid training during induction. Traincrew are trained in accordance with LUKL-OPS-402 Train Driver Training to render basic First Aid, contact the emergency services and to liaise with the Network Rail signaller as to the most appropriate location to meet an ambulance if necessary. 12.3.6 First Aiders/Emergency First Aiders undergo a training course in administering first aid at work which complies with HSE Guidance L74 and hold a current First Aid at Work Certificate. 12.4 Training and Competency 12.4.1 All Loram UK train drivers are trained on how to stop and protect trains and how to summon the emergency services in an emergency. 12.4.2 Certain local managers are appointed as evacuation wardens for Loram UK controlled premises and briefed on their role for ensuring that areas are clear during an evacuation. 12.4.3 All staff receive basic fire safety awareness training during induction, with refresher training at periodic intervals, and instruction on how to summon the emergency services. 12.4.4 The competence of operational safety critical staff to comply with their role in an emergency is assessed through the competency assessment program described in Section 6 above.

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12.5 Communication of Emergency Plans 12.5.1 The contents of emergency plans, including other organisations’ plans where applicable, are communicated to all relevant personnel through briefing, training, or during table top exercises with outside agencies, including emergency services. 12.5.2 Contractors working on Loram UK controlled premises must sign in and will be briefed on their role in an emergency before they commence work. 12.5.3 The Health, Safety and Environment Manager will lead liaison with Site Services and the emergency services as required. 12.6 Testing the Effectiveness of Emergency Plans 12.6.1 Loram UK will ensure that where emergency plans are developed they are tested prior to implementation, to ensure they are practical and realistic, and will then test them periodically to ensure effectiveness and staff familiarity with the emergency arrangements. 12.6.2 Loram UK will liaise with Site Services to participate in emergency exercises and evacuation drills on the RTC Business Park site. 12.6.3 Loram UK will participate in industry emergency exercises, including table-top exercises, with other organisations, including Network Rail, to ensure that the emergency plans are co-ordinated and effective, and that they can be applied in practice. 12.6.4 Loram UK will also participate in emergency planning meetings and exercises with other external organisations, and will provide access to its premises and trains for familiarisation purposes if required. 12.6.5 Rail grinding operations engenders specific hazards for which specific emergency plans have been developed e.g. lineside fires, infrastructure damage. Tailored tests will be periodically implemented to confirm that the Loram UK response provides suitable and sufficient mitigation and maintains the safety of all stakeholders.

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13 Monitoring and Audit

13.1 Monitoring and Auditing Processes 13.1.1 Loram UK has in place a health, safety and environment monitoring regime, described in LUKL-OCC-101 Health and Safety Monitoring and Inspection. This procedure describes the arrangements in place within Loram UK for workplace inspections and safety tours. It describes the different levels of monitoring, who will conduct the monitoring, how monitoring will be recorded, and how actions will be followed up and tracked. 13.1.2 Loram UK procedure LUKL-MSP-004 Audit outlines the arrangements and methodology for carrying out internal audits of the safety, environment and quality management systems. 13.1.3 Loram UK monitors health, safety and environmental performance through a range of activity and outcome indicators, as described in Section 15. 13.2 Health, Safety and Environment Monitoring 13.2.1 The health and monitoring regime consists of a framework of layered monitoring as follows: Level 1 – Workplace Inspections (WPI) Carried out supervisors and / or managers on a weekly basis, covering their specific work area/project, focusing on the condition of the work environment, to identify hazards and non-compliances. Level 2 – Planned General Inspections (PGI) Carried out by the Head of Business Services and the Facilities and Tooling Controller on a twelve-weekly basis (6 locations each inspected fortnighly), accompanied by the Health, Safety and Environment Manager. For rail operations, a PGI is carried out in the Yard by the Yard Manager or a Rail Operational Manager. PGI’s are a more detailed inspection of health and safety arrangements. Level 3 – Safety Tours (SMTST) Safety tours are carried out by members of the Senior Management Team (SMT), a Manager, a Safety Representative and a Supervisor with direct control over the location being visited. Tours are based around a simple proforma and checklist, prompting observation and conversations with staff, to gain a perception of the condition of the environment and culture of the workforce. Safety Tours are undertaken every 8 weeks, with a roster drawn up so that one safety tour of one facility (3 x sheds and yard) occurs each week and all four locations are covered each month. Tours are based around a simple proforma and checklist, prompting observation and conversations with staff, to gain a perception of the condition of the environment and culture of the workforce, and to record findings. 13.2.2 Progress against inspection plans is tracked by the Business Services Team and reported in the weekly and monthly KPI reporting. Records of inspections are collated by the Business Services Team and any actions arising are tracked to ensure they are closed out. 13.2.3 Loram UK has in place a suite of other proactive monitoring arrangements including:

• In-process inspection of engineering and maintenance quality and assurance • Periodic appraisal of the performance of managers and staff against set safety objectives

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• Monitoring by Loram UK Board of progress against targets set in the annual Health and Safety Plan • Monitoring by the professional heads of implementation of recommendations following audit

reports, formal inquiries and formal investigations • Assessment of employee competence, including the assessment of compliance with rules and

procedures, and supervision of work methods and employee behaviour • Specific monitoring of high-risk activities and individuals (e.g. specially monitored employee

process), using human factor monitoring techniques where applicable • Monitoring of compliance with specific functional safety requirements, by means of Key

Performance Indicators. • Monitoring of communications procedures, including safety critical communications monitoring,

receipt of personal issue documentation and the safety/team briefing process • Monitoring employee attitude towards safety through behavioural and safety climate surveys • Monitoring of safety performance of other organisations providing services to Loram UK • Monitoring of contractor activities and safety performance

13.2.4 The results of monitoring activities are considered in the annual management review of the safety management system to inform on the effectiveness of the management arrangements. 13.3 Overview of Audits 13.3.1 The Loram UK audit framework aims to provide the Board and management groups with confidence in the levels of compliance with Loram’s Health & Safety Management System, formal company standards, procedures, legislation, and contractual requirements. Figure X sets out the different levels of audit and the self-assurance processes within Loram UK, and how to plan, carry out and review these effectively.

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13.4 Internal Audit 13.4.1 Procedure LUKL-MSP-004 explains the internal audit process applied by Loram UK. It defines the arrangements to be adopted for planning, conducting and reporting audits of the safety, environment and quality management systems and how to manage any non-conformances arising from the audits. 13.4.2 The Assurance Director will liaise with the other professional heads to develop an annual audit program. The audit program will be risk based and will include external, internal and safety critical supplier audits of the quality, safety and environment management systems, and will be supplemented by other regular internal monitoring systems, such as workplace monitoring, planned general inspections and safety tours. 13.4.3 Progress against the audit plan is tracked and the plan will be revised during the year should events or the monitoring of performance highlight the need for additional audits. 13.4.4 Audits must be conducted by a suitably qualified and experienced auditor or team of auditors competent in auditing skills. Auditors must be sufficiently familiar with the subject area that is covered by the audit. The Assurance Director will monitor audit reports and corrective actions raised to ensure as far as possible that impartiality is maintained. Impartiality on internal audits will further be checked by the commissioning of annual external audits of the management systems (see Section 13.5) 13.4.5 For each audit, the auditor must plan the audit including contacting the function/facility to be audited and arranging dates and times for the audit to be carried out. 13.4.6 The function/facility to be audited must nominate a person to assist the auditor with the audit. This person is known as the auditee. The auditee must have sufficient knowledge and experience of the standards and/or processes being audited. 13.4.7 The auditor will produce a remit for the audit, and will share this with the function/facility to be audited. 13.4.8 The auditor will use prepared audit protocols or recognised standards when conducting the audit. These may include; reviewed legislation, Approved Codes of Practice, Railway Group Standards, internal management system procedures and any other internal documentation required. 13.4.9 Any non-compliances, opportunities to improve, or examples of good practice are captured and classified as follows: Major Non-Conformance – the failure/absence to implement and maintain one or more elements of a management system which results in a significant non-compliance with a legislative requirement, which may pose a significant risk or is a systemic breach of the policy, objectives or public commitments of the organisation. Minor Non-Conformance – a weakness in the system which does not impact significantly on the capability of the management system but needs to be addressed to assure future reliability of the system. Observation – a weakness that has little adverse impact on the management system, does require remedial action but not within an urgent timescale. Good Practice – exceeds the requirement of the audit criteria, and is an example of best practice.

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13.4.11 The auditor will produce an audit report that contains details of the scope of the audit, the activities and locations audited, and will detail all audit non-conformances supported by evidence. The report will also highlight any areas of good practice identified during the audit. Any observations made during the audit that are not classed as non-conformances within the scope of the audit, but may be useful to highlight safety concerns, are also be clearly identified. 13.4.12 On completion of an audit, a close-out meeting will be held with a representative of the function/facility audited to discuss and review the non-conformances identified, to agree the classification, and to discuss and agree both corrective action to resolve the non-compliance and preventative action to ensure no repetition of the issue. 13.4.13 The auditor will document any non-conformance and agreed corrective action and preventative action on a Corrective Action Request, and the auditee is responsible for completing and signing off the Corrective Action Request and returning this to the auditor within the agreed timescale. 13.4.14 The Assurance Team maintains a register of audits and corrective actions raised, and will track these to ensure close out. 13.4.15 Audit results are shared with the Board on a quarterly basis, and trends in audit results are considered in the annual management review of the safety management system to inform on the effectiveness of the management arrangements. 13.5 External Audits 13.5.1 Where audits are carried out by or on behalf of external third parties, the Health Safety and Environment Manager will organise for the auditors to be accompanied by a competent member of staff who can verify any findings and corrective actions raised. 13.5.2 When an external audit raises a corrective action, the Assurance team led by the Health, Safety and Environment Manager will track progress against that action until complete and where required provide evidence to the external party raising the corrective action. 13.5.3 Loram UK contracts an external body to carry out an annual independent audit on the adequacy of its safety management system to maintain certification to ISO45001:2018.

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14 Co-operation

14.1 Overview 14.1.1 Loram UK recognises the need for co-operation to achieve the required standards of safety within the railway industry. Loram UK will ensure that resources and facilities are available to provide for effective co-operation with interfacing organisations. 14.1.2 Loram UK is committed to comply with the specific duty of co-operation detailed in Regulation 22 of ROGS, and summarised in section 6 of the ORR’s A Guide to ROGS, and RIG-2018-03 ROGS Duty of Cooperation. 14.1.3 Loram has arrangements for liaising and cooperating with interested parties relevant to Loram UK’s operations through LUKL-MSP-007 Register of Interested Parties. It provides a directory of interested parties and the nature of their interest in Loram operations. Interested parties include Loram Maintenance of Way, our staff, customers, suppliers, neighbours, and regulatory authorities. This document is referred to in situations where Loram UK need to consider the operations and impact who are relevant to the business. 14.2 Co-operation with the Network Rail 14.2.1 Loram UK’s train services operate over infrastructure managed by Network Rail, and a number of arrangements are in place to manage these interfaces. These arrangements include:

• contracts (including access agreements, reciprocal provisions for out-of-course and emergency arrangements)

• liaison and co-operation, including meetings

• co-operation in accident and incident investigations

• joint monitoring of performance for shared systems (e.g. radio, speed checks)

• joint inspections for shared risks 14.2.2 The Assurance Director ensures that Loram UK and Network Rail implement action plans to tackle shared operational risks such as SPADs, those associated with level crossings, and those resulting from route crime. 14.3 Co-operation with the Landlord 14.3.1 The RTC Business Park premises are part of a site that is controlled by Derby Facilities Management Group (DFMG) on behalf of the site landlord. The site is occupied by a number of organisations as well as Loram UK, although Loram UK leases all the track on site and has control and responsibility for that track. 14.3.2 Loram UK has adopted a number of DFMG instructions for use as detailed in LUKL-OCC-107 Emergency Planning Arrangements. Loram UK will co-operate with DFMG in the application and testing of relevant emergency procedures.

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14.4 Liaison with other Transport Undertakings (TUs) and Suppliers 14.4.1 Loram UK will interface with the Train Operators which share Loram UK routes of operation as necessary, both directly and in conjunction with Network Rail. This will be through a combination of liaison and meetings. 14.4.2 A key interface for Loram UK is with the Rail Innovation and Development Centre – Melton at Old Dalby, where Loram UK require conducting services provided in order to enter the site. Network Rail own the site and have a contract, currently with Serco, who control operations on the test track site. Loram UK take part in site co-ordination meetings with Network Rail and Serco as necessary. 14.5 Interfaces with Other Organisations 14.5.1 Loram UK also manages Key interfaces with the following organisations for information sharing and co-operation:

Interface Subject Office of Rail

and Road (ORR) The issue of rail operator licences, and (through the HMRI) the issuing of Safety Certificates and Authorisations. The ORR also establishes and manages the conditions for which access to the UK rail network is granted. The safety regulator for Loram UK’s train operations. Sharing information about safety performance. Annual safety reporting. Safety Certification and ROGS issues. Interventions and inspections.

Rail Safety and Standards Board (RSSB)

RSSB sets industry standards and promotes research into safety issues affecting the railway. Loram UK will co-operate with joint operator safety forums hosted by RSSB either through direct membership.

Health and Safety Executive (HSE)

The safety regulator for Loram UK’s activities other than train operations. Provides a regulatory framework for workplace health and safety. Periodic inspections.

*Other operators Purchase / hire of contracted services including train planning /scheduling / reporting, mainline driver competence assessments, training and operational on-call response Other suppliers / customers. Provider / client for contracted services including train movements, hire of Loram UK mainline drivers, maintenance services and/or training.

* Details of operators and activities in relation to interface and affected parties are outlined in Appendix 7

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15 Safety Performance and Improvement Plans

15.1 Setting Health and Safety Objectives

15.1.1 Loram UK is committed to establishing annual health and safety objectives and targets to drive continual improvement in health and safety performance and culture. These objectives are consistent with the Loram UK business long term plan, and complementary to it. 15.1.2 The Assurance Director leads development of the objectives and targets which are based on considering:

• Safety management issues arising from current Loram UK safety performance trends

• A review of the significant risks associated with Loram UK operations

• Actions that require implementation of control measures identified by risk assessment and the results of audits

• The introduction of new legislation or Railway Industry Group Standards

• The outcome of the annual management review of the safety management system

• Lessons learned from companies elsewhere in the Railway Group and from internal lessons learnt

• Actions identified from concerns expressed by employees and the annual safety climate survey 15.1.3 The objectives and targets are published in LUKL-OBJ-001 Health and Safety Objectives and Targets. Each objective is allocated to a responsible manager for delivery, and target completion dates are set. 15.1.4 Progress against the Health and Safety Objectives is reviewed periodically by the Loram UK Senior Management Team to ensure that the plans are on target. The purpose of this monitoring is to identify potential or actual non-achievement of an objective as soon as possible and to initiate appropriate corrective action. This could include the requirement for modified, new or additional control measures or objectives. 15.2 Measuring and Monitoring Safety Performance 15.2.1 Loram UK produces a monthly safety performance report in the form of a Health, Safety and Environment Balanced KPI Dashboard and supporting reports, which include the following information:

• performance against safety and environmental activity and outcome KPI targets

• brief details of accidents to staff and others

• brief details of operating incidents

• analysis of close call, near miss and safety opportunity reporting

• performance against targets for monitoring and safety tours

• summary of working hours exceedances

• details of any key health, safety or environment issues 15.2.2 Health, safety and environmental performance is discussed at the monthly Senior Management Team and quarterly Board meetings, and at the bi-monthly health and safety committee meetings.

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15.2.3 The Health, Safety and Environment Balanced KPI Dashboard and a Safety Incidents and Safety Opportunities Feedback Report is published each month on the company intranet and posted on the health and safety noticeboards for the information of staff, copies are also circulated to stakeholders on request or through contractual arrangements. 15.2.4 The Assurance Director will periodically benchmark Loram UK’s safety performance against other industry parties’ performance and Common Safety Targets, to identify where there may be opportunity to learn lessons to improve Loram UK’s performance. 15.2.5 Where health and safety performance is deviating from target, the Assurance Director will recommend action to correct the deviation. 15.3 Monitoring Individual Safety Performance 15.3.1 All Loram UK managers and staff are set personal safety objectives that are relevant to their role, with at least one objective being designed to support LUKL-OBJ-001 Health and Safety Objectives and Targets. 15.3.2 Personal objectives are set annually and reviewed every six months through an appraisal process which considers the individual’s performance to identify performance against set objectives and to review personal development needs. Performance appraisals are recorded and reviewed by the reviewing line manager’s manager. 15.3.3 Loram UK promotes a ‘just’ culture, where errors and omissions are differentiated from negligence and intentional acts. 15.3.4 Errors and omissions are usually corrected by briefing, training and individual action plans, with individuals being monitored where necessary. Where necessary this will involve invoking the poor performance procedure, (or for train drivers LUKL-OPS-406 Personal Development Plans) to assist the individual to reach the required performance levels, or if this is not possible, to see if the individual is capable of carrying out an alternative role within the business. 15.3.5 Where breaches of safety policy, rules or training occur through negligence or deliberate acts, Loram UK believe that disciplinary action is appropriate, and ultimately such actions may lead to discipline up to and including dismissal. 15.3.7 LUKL-POL-013 Safety and Environmental Enforcement Policy provides a framework for dealing with breaches of health, safety and environmental policy and procedures through informal discipline, and where necessary formal discipline, to ensure fair, consistent and equal treatment of all individuals. 15.4 Annual Safety Report 15.4.1 Loram UK will compile an annual safety performance report for submission to the Office of Rail and Road (ORR) which complies with the requirements of the Railways and Other Guided Transport (Safety) Regulations and ORR Guidance, such that Loram UK safety performance can be aggregated by ORR for reporting on a national basis in compliance with European requirements. Loram UK will submit the annual safety performance report by the deadline of 30th June, to cover the preceding calendar year.

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16 Management Review

16.1 Reviewing and Improving the SMS 16.1.1 Loram UK Management review is a critical part of the evaluation of the safe performance of the organisation and focuses on results and opportunities for improvement. LUKL-MSP-009 Annual Review sets out agreement on objectives and review on safety performance. This deepens the understanding of risk and informs the development of systems and controls based on a philosophy of “predict and prevent”. Accordingly, Loram has processes in place to ensure such review takes place where there are changes which materially affect the SMS, and any actions arising are implemented. 16.1.2 Loram UK’s Safety Management System is built on the principles defined in HS(G)65 and hence all safety management system procedures include appropriate levels of review within the processes they describe. This may take a variety of forms, ranging from counter-signing records through to specifically mandated review processes, introduction of new technology or changes in national policy or guidance. 16.1.3 Safety procedures are subject to a risk based periodic review, which may be between three and five years. In addition, safety procedures are reviewed whenever inadequacies or improvements are identified, which may be through accidents, incidents, near misses, audit findings or staff feedback. 16.1.4 New or amended safety procedures are reviewed and consulted through the Health and Safety Committee prior to implementation. 16.1.5 Key records are required to be reviewed periodically. The review periodicity of specific records are detailed in the procedures to which they relate. Examples are risk assessments, CoSHH assessments and Environmental Aspect and Impact statements. The Assurance Director will lead a quarterly management review with the health and safety team of key records and associated policies and procedures, to ensure such reviews are programmed and completed on a timely basis. 16.1.6 The Assurance Director reviews the SMS Arrangements annually for alignment with procedures and against any relevant safety validation of change documents. This is managed by maintaining a mark-up copy of SMS Arrangements document as procedures change and safety validations of change are received. 16.2 Annual Management Review 16.2.1 A holistic review of the SMS is carried out annually (normally in the winter of each year) which incorporates a comprehensive review of effectiveness of SMS, to assess whether the SMS is meeting its stated aims (as stated in 1.1.2). 16.2.2 This annual management review will be structured around BS OHSAS 18001:2007 and will consider a range of defined inputs to the review, including:

• The extent to which the health and safety objectives and targets have been met

• Evaluation of compliance with legislation and other requirements

• Status of incident investigations, corrective actions and preventative actions

• Results of internal audits, external audits, and supplier audits

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• Results of monitoring and inspection

• Feedback from staff and suppliers

• Relevant communication from external interested parties, including complaints

• Results from any regulatory inspections

• Follow up actions from previous management reviews 16.2.3 The annual management review is led by the Assurance Director. The review group includes Directors and senior managers, and takes input from the health and safety committee. 16.2.4 The annual management review identifies actions which may be incorporated into the annual Health and Safety Objectives, or may be taken forward separately as projects to improve the SMS. 16.2.5 The annual management review of the SMS is co-ordinated with parallel review of the quality and environmental management systems, and these reviews are linked to the annual business planning process, with key improvement initiatives being incorporated in the annual business plan. 16.3 Continual Improvement 16.3.1 The Continual Improvement (CI) Manager is a vital member of the Assurance Team and is dedicated to improvement activities throughout the business, in all areas as detailed in LUKL-CI-001 Continual Improvement Policy and Procedure. 16.3.2. Through the internal reporting arrangements, staff are encouraged to raise initial reports where they identify opportunities for improvement in which the CI Manager apply the appropriate tools and project proposals. The process incorporates various methods to continual improvement underpinning the DMAIC (Define Measure Analyse Improve Control) Improvement cycle.

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Appendix 1 – Health and Safety Policy Statement

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Appendix 2 – Loram UK Organisation Structure Level 1 Senior Management Team

Level 2a Technical Directorate

Level 2b Assurance Director

* Level 2a * Level 2b * Level 2d * Level 2e * Level 2f * Level 2g * Level 2h * Level 2c

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Level 2c Finance Directorate

Level 2d Human Resources Directorate

Level 2e Vehicle Systems & Services Director

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Level 2f Business Development Directorate

Level 2g Commercial Directorate

Level 2h Rail Grinding Systems & Services

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Appendix 3 – Key Responsibilities

Managing Director

• Develop and execute strategies that interface with Loram globally to achieve Loram’s Mission and Vision, and Long-Range Plans, in accordance with the Core Values.

• Develop and execute growth strategies and leverage knowledge throughout Loram to grow market share with new and improved products and services.

• Build and sustain organisational capabilities to ensure close customer relationships, identification of business opportunities, prediction of competitive behaviours, and expertise within global railroad infrastructure markets.

• Build and sustain organisational capabilities to ensure operational excellence and unrivalled customer service.

• Plan and direct activities to define and achieve safety, quality and performance targets within all major functions.

• Target, and execute strategic merger and acquisition opportunities and successfully lead organisational integration into Loram and its culture.

• Enhance Loram’s brand by developing meaningful and mutually beneficial relationships with key customer decision makers, cultivating other industry relationships, and actively participating in railway industry organisations.

• Genuinely inspire the team and be the voice of Loram’s culture, to motivate and capture personal commitment in creating a path for sustainable growth.

• Actively leverage Loram talent planning processes to continuously measure leadership effectiveness, bench strength, and organisational structure (including the interface with Loram globally) and adjust where necessary.

• Personally, represent Loram’s high level of integrity internally and externally, and inspire customers and employees to be part of the positive journey of growth.

• Recruit, select and develop team members and ensure effective succession planning for all pivotal positions.

• Develop strong discipline of role clarity and hold leaders accountable for: (i) performance and collaboration for the whole enterprise, and (ii) establishing and maintaining an inclusive and diverse culture that provides a positive experience for all employees.

• Develop a team with the appropriate mixture of experience, competencies, and skills to consistently meet company goals and departmental initiatives in the most cost-effective manner.

The Finance Director is the Managing Director’s nominated deputy.

Assurance Director

• Assure that the company complies with legal, regulatory and corporate governance requirements for Health, Safety, Environment, Quality and Rail Operations.

• Assure that the company has a self-improving mind-set with the capacity to use established improvement practices to enable continuous improvement.

• Identify potential areas of concern for performance improvement and develop pro-active initiatives to enable improvement including through training and development of employees.

• Maintain accurate and transparent KPI reporting to management, regulators and the parent company including management of statutory reporting.

• Support the MD in holding management to account for performance against management systems and standards.

• Identify and control (through mitigation) the business’s compliance risks including where they arise through current performance to known standards, changes to best practice, regulation or legislation.

• Ensure that appropriate external accreditations are sought, that relevant management systems are compliant including through internal audit and that external audit is conducted in an open and transparent way.

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• Maintain Loram’s UK rail operations safety certificate and operating licences including management of main-line driver competence.

• Ensure that corporate and national reporting standards are met, that reports are compliant, transparent and complete including their timely submission.

• Ensure compliant and timely reporting of exceptional incidents and accidents to the HSE and ORR. • Assure that sufficient competent, qualified, trained and equipped staff are available to meet the

needs of the business and that they are robust and independent. • Assure that appropriate suitably qualified and experienced professionals are available to fulfil

Professional Head roles including their oversight and independence irrespective of their organisational location or other reporting arrangements.

The HSE Manager is the Assurance Directors Nominated deputy

HSE Manager

• Responsible for Loram UK’s HS&E Management Systems that support and enhance Loram UK’s Mission, Vision, Corporate values and Long Range Business Plans and additionally track, monitor and report on resultant KPIs.

• Build and sustain capabilities that ensure the HS&E management systems identify and eliminate or mitigate safety or environmentally unsafe processes and reduce impacts and defects with the goal of achieving and maintaining safe operations and independent certification to nationally accepted standards.

• Deliver monitoring and improvement plans including inspections, audits and system objectives • Establish and manage monitoring activities which identify hazards and unsafe behaviour. • Ensure that effective emergency response and crisis management measures are in place and

tested periodically and that accidents and incidents are investigated and recommendations for corrective and preventative action are tracked and implemented.

The Assurance Director is the HSE Managers nominated deputy.

Technical Director

• Ensuring in collaboration with the Assurance Director that a suitably qualified and experienced person is appointed to the role of Professional Head of Engineering.

• Development of bid document technical content including initial opportunity development discussions with both potential customers and supply chain partners.

• Approval of bid document technical aspects including initial indications (which may be verbal). • Development of technical standards and work control documents. • Operational oversight of key controlled processes including welding, painting and safety critical

systems testing. • Development and fitness for purpose of engineering designs for modification and re-engineering

projects including the selection, oversight and control of external technical consultants and supply chain partners.

• Non-project specific technical aspects of relationships with external partners and collaborators. • Selection, recruitment, retention and development of technical staff in collaboration with the Human

Resources Director. • Management and maintenance of tools, systems and processes for the development and control of

technical information and subsequent management of intellectual property and engineering records arising.

• Development of Patent applications, control of patents and other intellectual property devices arising including the management of licenses.

• Oversight of technical aspects of service delivery to Technical Service Agreements including - a) Provision of technical services to external clients. b) Provision on demand of technical services to Loram NA.

The Professional Head of Engineering is the Technical Directors nominated deputy.

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Professional Head of Engineering

• Review customer technical and engineering standards (eg. VMIs, VOIs, modification instructions) and determine their needs to the business

• Influence change across all delivery focused areas of operations to meet strategic objectives and goals

• Create and implement best practice engineering quality vision, strategy, policies, processes to aid and improve business performance

• Evaluate the engineering and quality challenges faced by the business and take action to mitigate risks and develop opportunity

• Responsible for all areas of the engineering function and quality of service delivery, striving for the best in class products and business practices to deliver and exceed the customers’ expectations.

• Ensure health, safety and environmental issues are prioritised and facilitate, direct and drive implementation of Lean business strategy to drive continuous improvement across all engineering related areas of the business.

• Work with the technical support and operations teams to turn customer maintenance and overhaul specifications into working instructions and block cards

• Lead the preparation of technical and contract documentation for issue and the analysis of tenders • Approve engineering documents for the use within Loram UK • Ensure best practice reporting, data collection and asset management processes are implemented

and maintained consistently throughout the production department • Approve modification instructions and vehicle change instructions • Lead on vehicle certification and other engineering design and change approval, processes, liaising

with external certification bodies to obtain all required approvals in accordance with the CSM and industry safety verification

• Provide the technical lead on the development of proposals for a new platform for IM testing and development of proposals to replace the existing IM fleet of vehicles.

The Technical Director is the Professional Head of Rail Engineering’s nominated deputy.

Professional Head of Rail Operations

• Develop and deliver the agreed objectives to improve the operational management system and overall performance of rail operations

• Develop and oversee the delivery of the competence management systems for the Loram UK Rail Operations staff

• Work closely with and provide assurance of safety critical supplier audits on nominated third party suppliers, working closely with and auditing key members of the operations team and others to ensure the ORR issued Rail Operators licence is maintained to the required standards

• Investigate incidents and opportunities for improvement applicable to rail operations. Track and follow through to satisfactory conclusion all identified corrective and preventive actions

• Support the operations team with monitoring and developing training, briefing, shunting/shunter, driver, controller assessments, competence and development plans for new drivers, shunters/depot drivers, controllers to ensure these are compliant with Loram UK standards, ORR / RSSB/TDLCR and industry guidelines

• Working closely with the rail operations team. Implementation and continual improvement of operational processes, procedures, work instructions, risk assessments and policies

• Develop and assist with delivery of the rail operations risk based annual audit plan • Carry out depot safety training for all new employees • Support the operations team in conducting competence assessments for drivers/ depot drivers/ yard

managers/ shunters/ controllers and emergency shunters as required. • Review industry standards and legislative changes for applicability to Loram UK and where

appropriate, reflect those changes in the management system • Develop and manage rail operational Key Performance Indicators and produce periodic

performance reports

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The Technical Director is the Professional Head of Rail Operations nominated deputy.

Operations Standards Manager

• Act as Duty Control Manager for Loram UK rail operations as required. • Develop and deliver the agreed objectives to improve the operational management system and

overall performance of Rail Operations • Day to day management of Loram UK Mainline Train Drivers and Operational Control team • Develop and oversee the delivery of the competence management systems for the Loram UK

mainline drivers, depot-based drivers and shunters • Ensure the ORR issued Rail Operators licence is maintained to the required standards • Investigate incidents and opportunities for improvement applicable to rail operations. Follow through

to satisfactory conclusion all identified corrective and preventive actions • Support the operations team with monitoring and developing training, briefing, shunting/shunter

driver assessments, competence and development plans for new drivers, shunters/depot drivers, to ensure these are compliant with Loram UK standards, ORR / RSSB/TDLCR and industry guidelines

• Working closely with the Rail Operations team. Implementation and continual improvement of operational processes, procedures, work instructions, risk assessments and policies

• Support the operations team in Verification of competence assessments for drivers/ depot drivers/ yard managers/ shunters and emergency shunters as required

• Review industry standards and legislative changes for applicability to Loram UK and where appropriate, reflect those changes in the management system

• Develop and manage rail operational Key Performance Indicators and produce periodic performance reports

The Professional Head of Rail Operations is the Operations Standards Managers nominated deputy

Driver Training Manager

• Develop and oversee the delivery of the competence management systems for the Loram UK mainline drivers, depot-based drivers, shunters and other operational team members

• Develop and deliver the agreed objectives to improve the operational management system and overall performance of Rail Operations

• Ensure the conditions of the ORR issued Rail Operators licence are observed to the required standards

• Prepare and deliver approved training programmes for drivers, shunters and operational staff • Update Loram UK’s operational standards and training material to meet current national rail industry

standards • Act as the industry contact for counterparts on key areas of Loram UK’s main line Safety Certificate

including driver / shunter training, SPADs, operational irregularities, driver / shunter error and similar issues

• Support the operational management team in monitoring and developing training, briefing, shunting/shunter driver assessments, competence and development plans for new drivers, shunters/depot drivers, to ensure these are compliant with Loram UK standards, ORR / RSSB/TDLCR and other industry and legislative guidelines

• Prepare items of operational importance for the 3 monthly driver briefing, urgent advices and company safety briefs.

• Investigate incidents as required and identify opportunities for improvement applicable to rail operations. Follow all incidents through to satisfactory conclusion, identifying and communicating corrective and preventive actions.

• On behalf of the Rail Operations team, identify the need for and implement the continual improvement of operational processes, technology, procedures, work instructions, risk assessments and policies

• Support the operations team in the conducting of competence assessments for drivers / depot drivers/ yard managers / shunters and emergency shunters as required

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• Meet rail operational Key Performance Indicators, produce periodic performance reports and submit proposals for improvement

Train Driver

• Prepare and dispose of trains safely and in accordance with company and rule book requirements • Drive the vehicle/traction in a safe and effective manner in accordance with the relevant

requirements of Rule Book GE/RT8000, Sectional Appendix and company instructions or procedures as required

• Drive in a safe and effective manner responding to all signals and other operating instructions as appropriate

• Drive in accordance with LUKL-OPS-405 Train Driver Competence Management Standards and LUKL-OPS-408 Professional Driving Policy

• Report any safety of the line incidents in accordance with GE/RT8000 to the controlling signaller and Loram UK Operations Control

• Report on-train safety equipment faults to controlling signaller and Loram Operations Control, in accordance with GE/RT8000 and LUKL-OPS-434 Operational Contingency Plan for Defective On-Train Equipment

• Ensure that any vehicle defects are recorded in the vehicle defect book and reported to Loram UK Operations Control

• Carry out shunting / depot driving duties, including operation of manual points and coupling and uncoupling of rail vehicles as required

• Carry out route conducting duties for Network Rail and other train operators in accordance with route and traction competence

• Maintain good cleanliness and tidiness of the cab environment

Rail Operational Controller

• Responsible for real-time management of rail movements both within the RTC Yard on behalf of Network Rail and Loram UK Mainline Rail Operations movements

• Booking drivers on/off duty and arranging driver/route conductor cover from third party suppliers • Liaising with third party controls and communicating essential operational information to the Rail

Operations team. • Co-ordinating servicing, fuelling and watering of fleet. • Managing mainline operational incidents, including; SPADs/GOTCHA/HAB involving Loram UK

services • Arranging ‘for cause’ screening for Loram UK staff • Recording of any accidents/incidents and assisting in investigations where necessary • Tracking fleet faults & failures and removing and releasing vehicles from traffic • Ensure that all Loram UK Rail Operations and maintenance are conducted in accordance company

standards, procedures, Rule Book and ORR guidance. • Escalation of incidents to Loram UK Senior Managers and industry bodies • Monitoring of working hours, exceedances, lone workers and out-based teams.

Vehicle Systems & Services Director

• Capitalisation of orders, revenues and cash-flow targets from responsible operational activities. • Management of no-time delivery including production and capacity planning and management of

inventory and WIP levels. • Safe and compliant management of contract staff and contractors. • Identification and profitable capitalisation of up-selling opportunities from ongoing operations • Recruit and develop suitably qualified and experienced staff and further develop them through

training to enable provision of: o Rail vehicle repair maintenance and overhaul services. o Routine maintenance to rail vehicles in works and remote from the works.

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o Emergency maintenance support to rail vehicles at line side. o Yard operations including vehicle shunting.

• Establish and enforce safe operating practices and systems of work. • Identify and coordinate acquisition of new operational technologies and enable appropriate

technology transfer to the UK operation. • Continuously develop best practice processes for delivery of vehicle services including maximising

transfer of good operating practice from headquarters operations. • Design and implement operational key performance indicators that allow for effective performance

evaluation and management of responsible operations.

The Maintenance Manager is the Operations Director nominated deputy

Maintenance Manager

• Implement safety best practice to meet requirements across the operations division in line with industry legislation.

• Ownership and delivery of the customer planned maintenance schedule (NwR DCS) to meet external KPI’s.

• Implement applicable activities received from customer safety bulletins in to the internal maintenance plan.

• Translate external demand in to internal objectives via the Operations and Planning teams to meet internal KPI’s.

• Own the relationship with Network Rail, other maintenance customers, train operators with respect to the contract management.

• Develop and implement best practice in maintenance activities to meet the customer needs, extend the life of the asset, and improve productivity and profitability.

• Drive efficacy with all maintenance activities to ensure waste is eliminated, productivity is maximised and profitability is grown.

• Providing specialist engineering advice and expertise on the maintenance and safe use of new, existing and modified Network Rail owned rail vehicles.

• Identify and develop the process to capture and eliminate waste and faults by means of corrective actions and lessons learnt process and people development.

• Manage the interface with the production manager to ensure all maintenance activities have the required resource, footprint and facilities available to meet the maintenance schedules.

• Track and report metrics that measure the quality of production, production effort effectiveness and secure the resources necessary to achieve delivery on time, to budget and the required quality.

• Monitor safety critical maintenance standards, implement quality-control programmes to meet and exceed safety goals and objectives.

• Ensure that effective emergency response and crisis management measures are in place and tested periodically.

The Production Manager is the Maintenance Managers nominated deputy.

Yard Manager

• Lead the day to day management and operation of RTC yard rail operational activities, allocating and delegating work in a timely manner to meet the maintenance and operations plan

• Lead and direct the Loram UK yard rail operations team to ensure consistent application and adherence to driving, shunting and other operational standards

• Plan and manage the safe delivery of yard rail operations, including forming and berthing trains main line trains for arrivals and departures, and shunting the yard and workshops to meet the needs of internal and external customer requirements

• Monitor RTC yard stabling and usage to ensure capacity is managed at a safe level so that all train movements can be carried out safely, in accordance with the Rule Book

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• Control the safe movement of all rail vehicles within the RTC Yard in accordance with applicable standards, procedures, specifications and instructions, including performing depot driving and shunting duties as required

• Ensure efficient rostering of staff to meet the train operating and movement plans, liaising with Network Rail, the Infrastructure Monitoring Fleet Engineer, the Operations Manager, and other Loram UK managers as necessary

• Monitor fuel levels and liaise with the Procurement and Logistics team to ensure fuel is procured as required to maintain capacity for planned rail operations

• Carry out investigations into yard operational accidents and incidents as required • Assist in maintenance of the competence management system for yard operations staff, including

carrying out competence assessments of depot drivers and shunters • Develop team members and regular development discussions, challenge unacceptable behaviour,

and promote adoption of the Loram UK Life Saving Behaviours. Leading the appraisal process for all direct reports and ensuring the appraisals are carried out consistently across the reports.

• Provides overall direction, coordination, supervision and evaluation of the yard operations team. Managing direct reports to ensure implementation and compliance of Loram UK’s engineering, quality, health, safety and environmental standards including HR policies and procedures ensuring best practice

The Planning and Capacity Co-Ordinator is the Yard Managers nominated deputy.

Head of Rail Grinding Systems and Services

• Development of a whole territory market view thorough fact-based understanding of target countries including political and economic stability, market size and competitive accessibility.

• Development of budget and long-range plan for rail grinding revenues including commentary and ongoing reporting.

• Capitalisation of orders, revenues and cash-flow targets from responsible operational activities meeting targets for operational cost,

• Recruit and develop suitably qualified and experienced staff and further develop them through training to enable provision of: - Technical service support to OEM machinery. - Spare/replacement parts and consumable items. - Railhead treatment operational services.

• Establish and enforce safe operating practices and systems of work. • Identify and coordinate transfer of critical technologies and core processes from headquarters and

enable appropriate technology transfer to the UK operation. • Develop best practice processes for delivery of railhead treatment services in the UK rail operating

context maximising transfer of good operating practice from headquarters operations. • Design and implement operational key performance indicators that allow for effective performance

evaluation and management of responsible operations. The Rail Grinding Machine Manager is the Head of Rail Grinding Systems and Services nominated Deputy.

Rail Grinding Machine Manager

• Responsible for Asset financials, provide evidence of robust control for management reports • Effective and safe utilisation of Supervisors, Operators and Machine support staff • Support the implementation of any innovation • Maintain records of machine level competencies and report / Highlight potential gaps/ deficiencies • Manage on board shift critical stock levels and provide parts request to maintain level of Asset as

per contract requirements • Agree and plan machine level holidays to ensure continued contract performance • Safeguard the safety, occupational health and welfare of employees and the environment by

providing: - Safe plant and equipment and safe system of work

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- Risk assessment and risk control information including training and instruction - A safe working environment with adequate welfare facilities and arrangements

• Lead the Loram UK rail grinding team to ensure consistent application and adherence to operational, maintenance competence and other management system standards

• Carry out investigations into operational accidents and incidents as required The Technical Services Manager is the Rail Grinding Machine Managers nominated Deputy.

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Appendix 4 – Vehicle Classes Operated by Loram (UK)

Vehicle Type Model Vehicle No. Vehicle Owner Sets Vehicles Total

OTM Plainline Rail Grinder

C21(01) DR79231 DR79232 DR79233 DR79236 DR79237

Loram UK Ltd 1 5 5

Notes:

i) All vehicles are fitted with TPWS / AWS.

ii) No vehicles fitted with DRA.

iii) Contingency arrangements for defective on train equipment are referenced in LUKL-OPS-434 Operational Contingency Plan and reported in accordance with LUKL-ENG-006 Safety Related Defect Reporting.

iv) Maintenance is managed in accordance with LUKL-ENG-012 Control of Rail Vehicle Maintenance and maintenance schedule procedures are managed as declared in Chapter 12.

Fleet Vehicles Operated By Loram (UK)

Type Model Vehicle No. Vehicle Owner Sets Vehicle

s Total

Locomotive 50 Class Fifty Operations Ltd 1 2 2

Locomotive 97 Network Rail 1 1 1

Locomotive 73 Network Rail 1 1 1

Locomotive 31 Network Rail 1 1 1

Locomotive 37 Colas Rail LTD 1 1 1

Locomotive 47 Colas Rail LTD 1 1 1

Locomotive 57 Colas Rail LTD 1 1 1

Locomotive 20 20189, 20147, 20007, 20205

Class 20189 LTD 1 4 4

TRU 150 Colas Rail LTD 1 1 1

Locomotive 08 08558 RSS 1 1 1

NMT 43 Colas Rail LTD 1 2 2

Multi Purpose Vehicle

MPV Balfour Beatty 1 1 1

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Appendix 5 – SMS Documents Procedure No. Procedure Title

LUKL-MSP-001 Document Review and Document Control

LUKL-MSP-002 Safe Management of Change

LUKL-MSP-004 Audit

LUKL-MSP-005 Compliance Obligations Register

LUKL-MSP-006 Management Systems Communications Strategy and Plan

LUKL-MSP-007 Register of Interested Parties

LUKL-MSP-008 Loram UK Supervising Safely Booklet

LUKL-MSP-009 Annual Review

LUKL-POL-001 Health & Safety Policy

LUKL-POL-002 Environmental Policy

LUKL-POL-003 Corporate Social Responsibility Policy

LUKL-POL-004 Drugs & Alcohol Policy

LUKL-POL-005 Harassment and Bullying Policy

LUKL-POL-007 Smoking Policy

LUKL-POL-008 Workshop PPE Policy

LUKL-POL-009 Mobile Phones and Other Electronic Devices Policy

LUKL-POL-010 Lone and Remote Working Policy

LUKL-POL-011 Road Vehicle Policy

LUKL-POL-012 Good Neighbour Policy

LUKL-POL-013 Safety and Environmental Enforcement Policy

LUKL-POL-014 Quality Policy

LUKL-POL-015 Continual Improvement

LUKL-POL-016 Adverse Weather Policy

LUKL-OBJ-001 Health and Safety Objectives and Targets

LUKL-OBJ-002 Environmental Objectives and Targets

LUKL-OBJ-003 Quality Objectives and Targets

LUKL-OBJ-004 Health, Safety, Quality and Environment Audit Plan

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Procedure No. Procedure Title

LUKL-OBJ-005 Rail Operations Objectives and Targets

LUKL-OBJ-006 Continual Improvement Objectives and Targets

LUKL-OCC-001 Safety Management System Arrangements

LUKL-OCC-002 Safety Certificate Application Parts A & B

LUKL-OCC-003 Health and Safety Strategy

LUKL-OCC-101 Health, Safety and Environmental Monitoring and Inspection

LUKL-OCC-102 Safety Incidents and Safety Opportunities Reporting and Investigation

LUKL-OCC-103 Working Safely

LUKL-OCC-104 Safety Representatives Roles and Responsibilities

LUKL-OCC-105 Control of Contractors

LUKL-OCC-106 Visitor Safety

LUKL-OCC-107 Emergency Planning Arrangements

LUKL-OCC-201 Risk Assessment

LUKL-OCC-202 Health Surveillance and Individual Health Risk Assessment

LUKL-OCC-203 Control of Substances Hazardous to Health

LUKL-OCC-204 Young Persons and Work Experience

LUKL-OCC-205 Recruitment, Selection and Medical Fitness Standards for Safety Critical Roles

LUKL-OCC-207 Safety Justification (ALARP)

LUKL-OCC-208 Risk Register

LUKL-OCC-209 Change Management for Significant Risks

LUKL-OCC-301 Control of Hand Arm Vibration at Work

LUKL-OCC-302 Noise Management

LUKL-OCC-303 Control of Legionella in Train Toilet Water Systems

LUKL-OCC-304 Control of Asbestos in Rail Vehicles

LUKL-OCC-305 Manual Handling

LUKL-OCC-306 Provision and Use of Work Equipment

LUKL-OCC-307 Facilities Management, Maintenance and Inspection

LUKL-OCC-308 Confined, Enclosed and Restricted Spaces

LUKL-OCC-309 Hot Process Work

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Procedure No. Procedure Title

LUKL-OCC-310 Safe Use and Testing of Portable Appliances at Work

LUKL-OCC-311 Fire Safety

LUKL-OCC-312 Safety Signs and Signals

LUKL-OCC-314 First Aid

LUKL-OCC-315 Lifting Operations and Lifting Equipment

LUKL-OCC-316 Working at Height

LUKL-OCC-317 Safe Working Practice Around Vehicle Mounted Equipment

LUKL-OCC-318 Working in Hot and Cold Environments

LUKL-OCC-319 Working on Rail Vehicles safely

LUKL-OCC-401 Managing Stress

LUKL-OCC-402 Control of Diesel Engine Exhaust Emissions

LUKL-OCC-403 Display Screen Equipment

LUKL-OCC-404 Controlling Occupational Diseases at Work

LUKL-OCC-501 Depot Protection

LUKL-OCC-502 Safety Critical Working Hours

LUKL-OCC-503 Determining Safety Critical Roles

LUKL-OCC-504 Competence Management of Safety Critical Work

LUKL-OCC-505 On Call Arrangements

LUKL-OCC-506 Sentinel Control Arrangements

LUKL-OCC-507 Fatigue Management

LUKL-OPS-401 Management of Train Drivers

LUKL-OPS-402 Train Driver Training

LUKL-OPS-403 Traction Training, Assessment and Refresh

LUKL-OPS-404 Train Driver Route Learning

LUKL-OPS-405 Train Driver Competence Management Standards

LUKL-OPS-406 Personal Development Plans

LUKL-OPS-407 Train Driver Licensing and Certification

LUKL-OPS-408 Professional Driving Policy

LUKL-OPS-410 Management of Shunters and Depot Drivers

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Procedure No. Procedure Title

LUKL-OPS-411 Depot Driver Training

LUKL-OPS-412 Depot Driver Competence Management Standards

LUKL-OPS-421 Shunter Training

LUKL-OPS-422 Shunter Competence Management Standards

LUKL-OPS-423 Professional Shunting Policy

LUKL-OPS-432 Rail Operations Controller Recruitment, Training and Assessment Competence Management Standards

LUKL-OPS-433 Operations Control Manual

LUKL-OPS-434 Operational Contingency Plan for Defective On Train Equipment

LUKL-OPS-442 Operational Managers Management of Competence

LUKL-OPS-443 Operational Accident and Incident Investigation

LUKL-OPS-444 Chain of Care & Support

LUKL-OPS-461 Seasonal Preparation

LUKL-OPS-462 Access to Driving Cabs

LUKL-OPS-463 Operational Staff Booking On/Off Arrangements

LUKL-OPS-464 Shift Working Lifestyle Guide

LUKL-OPS-465 Major Operational Incident Emergency Response

LUKL-OPS-466 Operation of Vehicles Fitted with Wheelskates

LUKL-OPS-467 Depot Working Instruction – RTC Yard

LUKL-OPS-471 Depot Safety, Personal Track Safety, and Designated Person Competence Standards

LUKL-RG-500 C2101 Rail Grinding Operation and Maintenance

LUKL-RG-501 Refuelling On-Track Machines

LUKL-ENG-001 Quality Management System Summary

LUKL-ENG-002 Maintenance Policy

LUKL-ENG-004 Rail Vehicle Maintenance and Overhaul Plans

LUKL-ENG-005 Control of Vehicle Examination Records

LUKL-ENG-006 Safety Related Defect Reporting

LUKL-ENG-007 Management of Engineering Projects

LUKL-ENG-008 Engineering Change

LUKL-ENG-009 Calibration

LUKL-ENG-010 Rail Vehicle Handover and Handback

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Procedure No. Procedure Title

LUKL-ENG-011 Regulatory Engineering Document Review

LUKL-ENG-012 Control of Rail Vehicle Maintenance

LUKL-ENG-014 Post Incident & Accident Vehicle Inspection

LUKL-ENG-015 Engineering Design

LUKL-ENG-016 Engineering Technician Competence Management Standards

LUKL-ENG-017 Grinder Technician Competence Management Standards

LUKL-ENG-018 Quality & In Process Monitoring

LUKL-ENG-019 Control of Resident Engineers

LUKL-ENG-020 Quality Strategy

LUKL-ENG-021 Welding Management Policy

LUKL-ENG-022 Handling and Storage of Wheelsets

LUKL-ENG-023 Welding Co-ordination Procedure

LUKL-ENG-024 Reservoir Overhaul Procedure

LUKL-QS-CRIMP-001 Quality Standard for the Application and Inspection of Crimped Connectors

LUKL-QS-MECH-001 Quality Standard for the use of Mechanical Fasteners

LUKL-QS-MECH-002 Quality Standard for Tightening of Terminal Connectors

LUKL-QS-SOLDER-001 Quality standard for the Application of Soldered Electrical Joints

LUKL-QS-PAINT-001 Work Instruction for the Inspection of Painted Vehicles

LUKL-PRO-001 Commercial Process

LUKL-PRO-002 Procurement

LUKL-PRO-003 Supplier Qualification

LUKL-PRO-005 Control of Non-Conforming Products

LUKL-PRO-006 Procurement – Safety Validation of Contracts

LUKL-PRO-007 Rail Grinding Spare Parts Provision

LUKL-PRO-008 Warranty Process

LUKL-ENV-001 Environmental Management System Summary

LUKL-ENV-002 Environmental Impacts and Aspects

LUKL-ENV-003 Chemical Storage and Handling

LUKL-ENV-004 Waste Management

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Procedure No. Procedure Title

LUKL-ENV-005 Utilities Management

LUKL-ENV-006 Environmental Emergency Preparedness and Response

LUKL-ENV-007 Environmental Sustainability Strategy

LUKL-ENV-008 Waste Management Register

LUKL-HRP-001 People Policy

LUKL-HRP-002 Recruitment Policy

LUKL-HRP-003 Equal Opportunities and Diversity Policy

LUKL-HRP-004 Discipline Policy

LUKL-HRP-005 Referencing Policy

LUKL-HRP-006 Induction Policy

LUKL-HRP-007 Job Evaluation and Grading Policy

LUKL-HRP-008 Performance Review Policy

LUKL-HRP-009 Performance Management Policy

LUKL-HRP-010 Employee Welfare Policy

LUKL-HRP-011 Grievance Policy

LUKL-HRP-012 Data Protection Policy

LUKL-HRP-013 Capability Policy

LUKL-HRP-014 Social Media Policy

LUKL-HRP-015 IT Security Policy

LUKL-HRP-016 Maternity Policy

LUKL-HRP-017 Dress Code Policy

LUKL-HRP-018 Parental Leave Policy

LUKL-HRP-019 Mentoring and Coaching Policy

LUKL-HRP-020 Training and Career Development Policy

LUKL-HRP-021 Apprentice Training Policy

LUKL-HRP-022 Succession Planning Policy

LUKL-HRP-023 Promotion Policy

LUKL-HRP-024 Pension Policy

LUKL-HRP-025 Pay and Grading Policy

LUKL-HRP-026 Secondment Policy

LUKL-HRP-027 Inter-company Transfer Policy

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Procedure No. Procedure Title

LUKL-HRP-028 Retirement Policy

LUKL-HRP-029 Selection Interview Policy

LUKL-HRP-030 Clear Desk Policy

LUKL-HRP-031 Business Communication Policy

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Appendix 6 – Rule Book Module Applicability

Applicability is approved by the Senior Management Team (SMT). Applicability is reviewed where a level 1, 2 or 3 change is proposed in accordance with LUKL-MSP-002 Safe Management of Change. The Health, Safety and Environment Manager is responsible for the currency and timely issue of GE/RT 8000 Rule Book Modules to applicable personnel.

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Appendix 7 – Interface Organisations and Activities Interface Activities In the course of its activities LORAM interfaces with the Mainline Railway Infrastructure Manager Network Rail and with several other Infrastructure Managers (IM) and Transport Undertakings (TU). The main interfaces are set out below:

Interface Activity Description Railway Undertakings (IM & TU)

Accident Investigation

Communication and co-ordination managed through Controls. Includes incidents such as SPaDs.

Network Rail Passenger and Freight TUs

Best Practice in operations and engineering safety

Sharing and review of safety performance reports and significant audit findings relating to interface safety risk

Passenger and Freight TUs in Rail Delivery Group (RDG) Passenger and Freight TUs in cross industry Infrastructure Strategy Leadership Group (ISLG) M&EE Operations Focus Group (OFG) Network Rail Infrastructure Contractor TUs; Freight & Passenger TUs to monitor safety performance and the implementation of industry initiatives: SPAD Risk Subgroup (SRSG) Train Accident Risk Group (TARG) Operations Safety Risk and Mitigation (OPSRAMs) Train Operator Safety Group (TOSGs)

Driver Training Transfer of personnel Accredited trainers Driver Licensing

Infrastructure Contractor TUs Freight & Passenger TUs

Emergency Planning

Loram’s role in Emergency Planning and attending/establishing EP forums, live and tabletop exercises.

Network Rail Infrastructure Contractor TUs Freight & Passenger TOC TUs

Emergency Response

Communication and co-ordination managed through respective IM & TU Controls.

Network Rail Operations Control Infrastructure Contractor TUs Freight & Passenger TOC TUs

Risk Identification and Assessment

Managed through RSSB Application for an amended certificate through consultation with ORR Significant changes to the type or extent of operations managed though ORR

Network Rail Infrastructure Contractor TUs Freight & Passenger TOC TUs Affected Parties

Real Time Control (Including T&RS contingency planning)

Communication and co-ordination managed through respective Loram Operations Control and Network Rail Operations Control.

Network Rail Operations Control

Route Conductors Prior checks & regular audit to ensure provision of competency for contracted services. Route learning on services.

Infrastructure Contractor TUs Freight & Passenger TUs

TOPS Input Total Operations Processing System for updating train operation data such as destination, load and location status for managing locomotives and rolling stock owned by or operated on a rail system. Also includes Network Rail’s TRUST system

Network Rail

Train Path Planning

Running line movements including into / out of Possessions / Depots / HOOBs

Network Rail Infrastructure Contractor TUs

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Interface Organisations

Interface Organisation Purpose Responsible Post

British Transport Police (BTP) (Incl. Community Safety Partnership Groups

Security and safety (Crime) Emergency arrangements and plans, and in the periodic testing of the effectiveness of those arrangements

HSE Manager Professional Head of Operations

Emergency Services (Fire, Police, Ambulance)

Fire, Police, Ambulance See BTP above. Involved in project-specific and issue-specific security and safety initiatives

HSE Manager Professional Head of Operations

Freight Operating Companies

Training of LORAM drivers and support provision. TOPS input and provision of rail haulage services. Route learning and familiarisation. Provision of T&RS or route or traction competence Planning and delivery of train movements required for testing, commissioning,

Operations Standards Manager Professional Head of Operations

Network Rail Infrastructure Contractor TUs

Emergency Response Liaising with their counterparts in their organisation for the establishment of emergency arrangements and plans, in the periodic testing of the effectiveness of those arrangements, and in response to operational incidents.

Operations Standards Manager Operations Control Duty Control Manager

Network Rail Infrastructure Contractor TUs Freight & Passenger TUs

Key safety issues and Improving safety of operation Working groups established jointly by the senior executives tasked with improving safety of operation. Participate in well-established groups such as OPSRAM, ISLG and M&EE FSC which spread good practice and target improvements in the field of train operation.

Professional Head of Operations Operations Standards Manager

Network Rail Infrastructure Contractor TUs Freight & Passenger TUs

Accident Investigation Operational and engineering professionals to sit on joint incident inquiry panels.

HSE Manager Professional Head of Operations Professional Head of Engineering

Infrastructure Contractor TUs Freight & Passenger TUs

Competence and Fitness Transfer of personnel. Arrangements for route learning and familiarisation for LORAM drivers.

Professional Head of Operations Operations Standards Manager Operations Trainers and assessors

Express Medicals Medical Examinations. Health Advice Responsible Posts liaise with OHS to set up arrangements for recruitment screening, periodic examinations, referrals, ongoing health checks, where appropriate health surveillance, and the testing of employees for drugs and alcohol.

Human Resources Director Professional Head of Operations

Office of Rail and Road Inspections. Monitoring of H&S performance Responsible Posts work with ORR on specific safety issues and incidents, on planned inspection and evidence-based assessment, and in making statutory applications, notifications and reports. Regular (6 monthly) Meetings.

Assurance Director Professional Head of Operations Professional Head of Engineering

Rail Safety and Standards Board

Industry standards and best practice Responsible Posts participate in Standards Committee work, leadership themes through conferences, development work through workshops and in the development of the Railway Strategic Safety plan etc.

Professional Head of Operations Professional Head of Engineering

Trade Unions Consultation with Safety Representatives / Committees Responsible Posts work with full-time Trades Union personnel and company representatives in operating arrangements for formal consultation and negotiation. Regular meetings (3 monthly) and ad-hoc meetings

Assurance Director HSE Manager

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Details of Interface Organisations

Interface Organisation Purpose(s) Responsible Post

Colas Rail (OTM) Supply, operate and maintain C2101 rail grinder for possession grinding only, with operational and maintenance crew Provide 2 x mainline drivers for C2101 where Colas have identified resourcing issues

Head of Rail Grinding, Machine Manager, trainers and assessors

Colas Rail (IM Fleet) Supply of Loram UK Train Drivers/route conductors to Colas Rail Request of Colas Rail LTD Train Drivers/route conductors to assist with Loram UK services when required Loram UK carry out maintenance services on Colas vehicles for the I.M fleet

Professional head of Rail Operations Professional Head of Engineering, Maintenance Manager, assessors and trainers

Network Rail Execute the maintenance program for the Infrastructure Monitoring fleet. Provide On-call engineering support to the fleet of vehicles

Professional Head of Engineering, Maintenance Manager, assessors and trainers. Operational Control Duty Manager(s)

Direct Rail Services Supply of Rail delivery services for mainline test runs

Professional Head of Rail Operations Professional Head of Engineering

Balfour Beatty Supply of Loram UK Train Drivers/route conductors to Balfour Beatty ltd

Professional head of Rail Operations Operations Standards Manager

Class 20189 ltd Supply of Loram UK Train Drivers/planning & control function to carry out movements of locomotives on behalf of Class 20189 ltd Supply of Class 20189 ltd locomotives to Loram UK on an ad hoc hire agreement

Professional head of Rail Operations Operations Standards Manager

GB Railfreight Supply of Loram UK Train Drivers/route conductors to GB Rail freight Request of GB Railfreight Train Drivers/route conductors to assist with Loram UK services when required Provision of GB Railfreight Operational control and planning function to assist with Loram UK Services when required Provision of Train driver assessments for Loram UK staff

Professional Head of Rail Operations Operations Standards Manager

Aegis Engineering Supply of specialist engineering support for engineering issues and projects to Loram UK Ltd.

Professional Head of Engineering,

TUV Rheinland Supply of specialist engineering support for engineering issues and projects to Loram UK Ltd.

Professional Head of Engineering,

Rail Operations Development Ltd

Supply of specialist operations support for rail operations and development to Loram UK Ltd.

Professional Head of Rail Operations Operations Standards Manager

HARMUK Supply of specialist operations support for rail operations and development to Loram UK Ltd.

Assurance Director Professional Head of Rail Operations Operations Standards Manager

SYLAD Management Limited

Supply of specialist operations support for rail operations and development to Loram UK Ltd.

Professional Head of Rail Operations Operations Standards Manager

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Appendix 8 – Rules and TSI's References to Processes

Key Standard/Legislation Description of Requirement Procedure Contained Within Owner

Initial Integrity

RGSC 01 Railway Group Standards Code RGSC 02 Railway Group Standards Manual

Derogations, Deviations, Temporary Non -Compliance LUKL-ENG-001 Quality Management System LUKL-MSP-005 Compliance Obligations Register LUKL-MSP-001 Document Review and Document Control

8.1 Train Operation Methods

Technical Director

Safety Validation of Organisational Change Documented Process, Contractor selection, adequacy LUKL-MSP-001 Document Review and Document Control LUKL-MSP-002 Safe Management of Change includes consequential Health and Safety Management System Changes. LUKL-PRO-003 Supplier Qualification LUKL-PRO-006 Safety Validation of Contracts LUKL-OCC-105 Control of Contractors Independent review on change management system dated 14.7.20 recommends improvements. LORAM and National Safety Authority (ORR) interface and liaison arrangements. Assurance Director is POC for ORR, HSE & other regulators. All responses to requests and statutory reporting will be co-ordinated and submitted expediently

5 Change Management

Assurance Director

Railways Act 2005 Transfer of responsibilities regarding railway safety purposes to the office of rail regulation from health and safety executive

Health & Safety/Enforcing authority for Railways & other guided transport systems) regulations 2006

Ensure the office of rail regulation for the enforcement of health & safety in law in relation to the operation of railways

Railways Infrastructure (access & management) Regs 2005

Set out number of requirements (para 2, Schedule 2) in relation to access to railway infrastructure by both international and domestic operators (access, type of facility needed; length of stay; time of day; refuelling; cleaning, light maintenance services, telecommunications, technical inspections and specialised maintenance

ORR’s guidance on The Railways (Access, Management and Licensing of Railway Undertakings) Regulations 2016. LUKL-MSP-007 Register of Interested Parties.

- SMT Assurance Director

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Railways (Interoperability) Regulations 2006 Interoperability aims to harmonise technical standards and other processes governing the supply of equipment & the running of trains on trans-European networks

Engineering Change set out arrangements for compliance with interoperability regulations projects LUKL-ENG-008 Engineering Design LUKL-ENG-010 Placing vehicles into service LUKL-OCC-209 Change Management for Significant Risks

7.5 Engineering Change 7.6 New or Substantially Altered Vehicles

Technical Director

Railway (Licensing of railway undertaking) regulations 2005

Provide the office of rail regulation with the power to grant licenses to railway undertakings

LORAM and National Safety Authority (ORR) interface and liaison arrangements

-

Railway safety regulations 1999 Provisions with respect to use of a train protection system

LUKL-OPS-405 Train Driver Competence Management System

8.3 Operational Risk and SPAD Management

Railways & other guided transport systems (safety) regulations 2006

A set of regulations developed to implement the EU railway safety directive dealing with safety certificates and safety authorisations (3-18); safety management systems (5;6); Risk Assessment (19); Annual Safety Reports (20); Cooperation (22;26); application of Safety Critical Work (23); Competence and fitness (24); Fatigue (25)

LUKL-OCC-001 Safety Management System Arrangements LUKL-OCC-002 Safety Certification Application ISO45001:2018 Certificated Management System LUKL-OCC-201 Risk Assessment LUKL-OCC-207 Safety Justification LUKL-OCC-208 Risk Register LUKL-MSP-002 Safe Management of Change LUKL-OCC-209 Change Management for Significant Risks LUKL-OCC-503 Determining Safety Critical Roles LUKL-OCC-504 Competence Management of Safety Critical Work LUKL-OCC-506 Sentinel Control Arrangements LUKL-OPS-463 Operational Staff Booking On Arrangements LUKL-OPS-464 Shift Working Lifestyle Guide LUKL-OCC-502 Safety Critical Working

SMSA Assurance Director

Train Driver Licenses and Certificates Regulations 2010

Sets requirements for any new driver post 29th Oct 2013 and existing drivers by 29th Oct 2018 who must have a train driver license and certificate to drive on the mainline railway. Doctors, psychometric assessors and training and examination centres who assess new train drivers must be recognised by ORR.

LUKL-OPS-407 Train Driver Licensing Certification

6.3 Recruitment and Selection

Professional Head of Operations

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Assurance

RIS 2700 Verification of Conformity of Engineering Change to Rail Vehicles

Application of document Evidence required for engineering acceptance, review, and revision

LUKL-ENG-002 Maintenance policy LUKL-ENG-004 – Rail Vehicle Maintenance and Overhaul Plans applies to T&RS including On-Track Machines LUKL-ENG-007 Management of Engineering Projects LUKL-ENG-008 Engineering Change LUKL-ENG-015 Engineering Design LUKL-MSP-004 Audit

7.1 Rolling Stock Supply and Maintenance 7.5 Engineering Change

Professional Head of Engineering

GM/RT2400 Engineering acceptance and design of on-track machines

Application of document LUKL-ENG-002 Maintenance policy LUKL-ENG-004 – Rail Vehicle Maintenance and Overhaul Plans applies to T&RS including On-Track Machines LUKL-PRO-003 Supplier Qualification LUKL-PRO-006 procurement -Safety Validation of Contracts. Applicable for engineering and management control arrangements for the supply chain for T&RS And OTM Fleet LUKL-MSP-004 Audit

7.1 Rolling Stock Supply and Maintenance

Professional Head of Engineering

RIS-2750-RST Supplier Assurance Qualified suppliers Responsibilities of LORUM Fleet services

Supplier Qualification for sourcing and supplier Governance and supplier licensing requirements Accreditation schemes RISAS & RISQS LUKL-PRO-003 Supplier LUKL-PRO-004 Supplier Assessment

3.4 Risks Associated with the Procurement of Goods and Services 16.2 Annual Management Review

Technical Director

Health &Safety at work act 1974 An act to make further provision for securing the health, safety and welfare of persons at work, for protecting others against risks to health or safety with activities of persons at work

LUKL-POL-Health & Safety Policy Safety Management System LUKL-HRP-006 Induction Policy LUKL-OCC-106 Visitor Safety LUKL-OCC-104 Safety Representatives Roles and Responsibilities LUKL-HRP-010 Employee Welfare Policy LUKL-OCC-306 PUWER

- Assurance Director / SMT

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Management of health and safety at work regulations 1999

Assess and control risks arising from hazards at work, to protect employees

Mainline operation risk assessment (HAZOP) Depot operation risk assessment (FTA) LUKL-OCC-201 Risk Assessment LUKL-OCC-207 Safety Justification LUKL-OCC-208 Risk Register LUKL-MSP-002 Safe Management of Change LUKL-OCC-209 Change Management for Significant Risks LUKL-OCC-202 Health Surveillance and Individual Health Risk Assessment LUKL-OCC-203 Control of Substances Hazardous to Health LUKL-OCC-204 Young Persons and Work Experience LUKL-OCC-314 First Aid LUKL-OCC-107 Emergency Planning Arrangements LUKL-MSP-006 Management Systems Communications

3 Identifying and Controlling Risk

Assurance Director

Employers Liability regulations 1998 The requirement for compulsory insurance for risks relating to employees

Business insurance certification - Assurance Director

Supply of machinery (Safety) regulations 2008 Machinery will not be supplied unless it satisfies the relevant essential health and safety requirements including the appropriate conformity assessment procedure is implemented

LUKL-PRO-002 Procurement LUKL-PRO-003 Supplier Qualification LUKL-PRO-005 Control of Non-Conforming Products LUKL-PRO-006 Safety Validation of Contracts LUKL-OCC-306 Provision and Use of WorkEquipment

3.4 Risks Associated with the Procurement of Goods and Services

Professional Head of Engineering

Train Maintenance

RIS-1700-PLT Safe use of plant for T&RS and OTM work

Requirements for use, approval and maintenance of plant Preparing a safe system of work for use of plant Safety requirements for use of infrastructure plant Competence and fitness

LUKL-ENG-001 Maintenance policy LUKL-OCC-504 Competence Management of Safety Critical Work LUKL-ENG-016 Engineering Technician Competence Management Standards for the Maintenance of Traction and Rolling Stock and On-track Machines

7 Train Integrity

Technical Director Professional Head of Engineering

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RIS-2004-RST Rail vehicle maintenance Principles Maintenance policy Accreditation of maintenance facilities and competency Maintenance plan

LUKL-ENG-001 Maintenance policy LUKL-ENG-004 – Rail Vehicle Maintenance and Overhaul Plans applies to T&RS including On-Track Machines LUKL-ENG-009 Calibration LUKL-OCC-504 Competence Management of Safety Critical Work LUKL-ENG-016 Engineering Technician Competence Management Standards for the Maintenance of Traction and Rolling Stock and On-track Machines LUKL-ENG-017 Grinder Technician Competence Management Standards for the Maintenance of Grinder On-track Machines LUKL-ENG-005 Control of Vehicle Examination Records LUKL-OCC-307 Facilities Management, Maintenance and Inspection (annual audit and Planned General Inspection)

7.1 Rolling Stock Supply and Maintenance 7.2 Maintenance Planning For Vehicles Where Loram UK are the Maintainer

Professional Head of Engineering

GM/GN2646 Guidance on Axle Bearing Maintenance

Guidance on maintenance of rail vehicle axle bearings, the training and competence of personnel who maintain or overhaul axle bearings relating to relevant requirements in GM/RT2004.

LUKL-ENG-004 – Rail Vehicle Maintenance and Overhaul Plans applies to T&RS including On-Track Machines

7.1 Rolling Stock Supply and Maintenance

Professional Head of Engineering

GM/RT 2466 Railway Wheelsets Sets out requirements for the design, manufacture and maintenance of wheelsets and their components

LUKL-ENG-004 – Rail Vehicle Maintenance and Overhaul Plans applies to T&RS including On-Track Machines LUKL-ENG-022 Handling and Storage of Wheelsets

7.1 Rolling Stock Supply and Maintenance

Professional Head of Engineering

Construction (design and management) regulations 2015

Impose requirements and prohibitions with respect to design and management aspects of construction work, on the implementation of minimum safety and health requirements at temporary of mobile construction Impose requirements with respect to health ,safety and welfare of persons at work carrying out construction work and of others who may be affected by the work

LUKL-OCC-105 Control of Contractors LUKL-OCC-201 Risk Assessment LUKL-OCC-103 Working Safely LUKL-HRP-010 Employee Welfare Policy includes minimum provision of welfare facilities.

- Assurance Director

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Workplace (Health, Safety and welfare) regulations 1992

Impose requirements with respect to health, safety and welfare of persons in a workplace, requirements are imposed upon employers, persons who have to any extent, control a workplace, and persons who are deemed to be the occupiers

LUKL-HRP-010 Employee Welfare Policy includes minimum provision of welfare facilities LUKL-HRP-006 Induction Policy LUKL-OCC-314 First Aid LUKL-OCC-107 Emergency Planning Arrangements LUKL-OCC-311 Fire Safety LUKL-OCC-106 Visitor Safety LUKL-OCC-105 Control of Contractors

Control of noise at work regulations 2005 Noise levels at which employers must control exposure to noise, including a exposure limit value above which employers are obligated to take immediate action to reduce exposure

LUKL-OCC-302 Noise Management

Control of substances Hazardous to Health Regulations 2002

Requires employers to control exposure to hazardous substances to prevent ill health, to protect both employees and others who may be exposed

LUKL-OCC-402 Control of Diesel Engine Exhaust Emissions LUKL-OCC-203 Control of Substances Hazardous to Health

Control of vibration at work regulations 2005 Duties on employers to protect employees who may be exposed to risks from either hand–arm and whole-body vibration at work, and any other persons who might be affected by work undertaken

LUKL-OCC-301 Hand Arm Vibration at Work

Confined spaces regulations 1997 Apply in premises and work situations in UK subject to HSW act, with the exception of driving operations and below ground in a mine

LUKL-OCC-308 Confined, Enclosed and Restricted Spaces details how confined spaces are determined and the action which must follow LORAM do not hold confined space entry competencies and will transfer entry to suitable contracting partner

Electrical equipment (safety) regulations 1994 Relate to electrical equipment designed for use with certain voltage limits, they required electrical equipment to be safe and constructed in accordance with excellent engineering practice

LUKL-OCC-307 Facilities Management, Maintenance and Inspection LUKL-OCC-306 Provision and Use of \Work Equipment

Electricity at work regulations 1989 Impose requirements with regard to the carrying out of Plant and Equipment work activities including the operation, use and maintenance of electrical systems and work near electrical systems

LUKL-OCC-310 Safe Use and Testing of Portable Appliances at Work LUKL-OCC-307 Facilities Management, Maintenance and Inspection LUKL-OCC-313 Working with Electricity

- Assurance Director

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Lifting operations and lifting equipment (LOLER) regulations

Imposes requirements with lifting equipment, with respect to strength and stability, the way the equipment is positioned and installed, the marking of machinery and accessories, the organisational of lifting operations, the thorough examination and inspection of lifting equipment

LUKL-OCC-315 Lifting Operations and Lifting Equipment sets out arrangements for planning and inspection for safe lifting operations

-

Control of Asbestos regulations 2012 The Regulations require the "duty holder" to manage the risk from asbestos in non-domestic premises and work.

LUKL-OCC-304 Control of asbestos in rail vehicles

-

Legionella regulations 2013 (L8) Duty to those in control of a premises to carrying out a risk assessment and take suitable precautions to prevent or control the risk of exposure of legionella bacteria in water systems.

LUKL-OCC-303 Control of Legionella in Train Water Systems LUKL-OCC-307 Facilities Management, Maintenance and Inspection

-

Pressure systems safety regulations 2000 Impose safety requirements with respect to pressure systems that are used or intended to be used at work

LUKL-OCC-307 Facilities Management, Maintenance and Inspection LUKL-OCC-105 Control of Contractors

-

Personal protective equipment at work regulations1992

Requires employers to provide suitable PPE to employees if necessary, PPE must be regarded as last resort and only used when risks cannot be adequately controlled by more effective measures

LUKL-OCC-303 Provision and Use of Work Equipment (PPE) includes suitable protections against general and specific work hazards including work wear.

-

Provision and use of work equipment regulations 1998

Mandate the minimum health & safety requirements for the use of work equipment by workers at work

LUKL-OCC-306 Provision and Use of Work Equipment includes risk assessment, installation, training and instruction for equipment, rail vehicles and plant LUKL-OCC-313 Working with Electricity includes working on dead systems and isolation, LOTO. LUKL-OCC-501 Depot Protection details vehicle isolation and access LUKL-OCC-319 Working on Rail Vehicles Safely includes vehicle, air and electrical system isolation and control

-

Manual Handling operations regulations 1992 Imposes requirements to reduce the risk of injury to those employees arising out of there undertaking any such manual handling operations to lowest level reasonably practicable.

LUKL-OCC-316 Manual Handling -

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Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 2013

LORAM has statutory reporting requirements under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations, including what and how to report particular accidents or dangerous occurrences Note: Withdrawn GE/GN8522 useful guidance for railway scenarios in Appendix remains applicable.

LUKL-OCC-102 Safety Incidents and Safety Opportunities Reporting and Investigation includes statutory reporting to HSE, ORR, EA, RAIB & other interested parties

11.3 Statutory Reporting

Work at height regulations 2006 Place duties on employers to make sure that all work at height is properly planned, supervised and carried out by people who are competent to do so

LUKL-OCC-316 Working at Height inventory and inspection Working at Height-Work Equipment

Train Operations

RIS-0707-CCS Management of sharing information about safety related failures of the control, command and signalling (CCS) system

Purpose and introduction Requirements for managing information about control, command and signaling system failures Each duty holder is responsibility for implementation of CCS systems for the equipment in their control Defect Recording Analysis and Corrective Action System (DRACAS) Appendix A Classification and risk of failure types Health and safety responsibilities

LUKL-ENG-001 Maintenance policy LUKL-OPS-433 Operations Control Manual Operations Control Instructions LUKL-ENG-006 Rail Vehicle Safety Related Defect Reporting, with the risk priority indicated LUKL-OPS-434 Operations Contingency Plan for Defective On Train Equipment GE/RT8000 Rule Book states conditions under which reporting is required

8.4 Loram UK Operations Control

Professional Head of Operations

RIS-2273-RST Post incident and post-accident examination and testing of rail vehicles section 1.3 part 3 3.2

Health and safety responsibilities Requirements for examination and testing Specific requirements for derailments and collisions

LUKL-ENG-014 Post Incident and Accident Vehicle Inpsection LUKL-OPS-433 Operations Control Manual Operations Control Instructions

RIS-3751 Rail industry standard for train driving selection Part 1).2.1-2.5; Appendix A & Appendix B

Requirements and guidance on selection criteria and process for train driver candidates who will drive on the GB mainline network Driver selection criteria & psychometric tests, Visual acuity, colour perception and hearing, Transfer of safety critical information (applicant with previous experience as a train driver) Review of selection process Audit of selection process

LUKL-HRP-002 Recruitment Policy LUKL-OCC-205 Recruitment, Selection and Medical Fitness Standards for Safety Critical Roles LUKL-OPS-401 Management of Train Drivers LUKL-OPS405 Train Driver Competence Management Standards

6.3 Recruitment and Selection 6.3 Recruitment and Selection 6.4 Provision of Training 6.5 Competence Assessment and Monitoring

Operations Standards Manager

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RIS-3451-TOM Train Drivers – Suitability and Medical Fitness Requirements

Sets out suitability and medical fitness requirements for train drivers – Specific requirements set out in Annex A, Visual acuity, colour perception and hearing Registered Medical Practitioner Health & safety responsibilities

LUKL-OCC-205 Recruitment, Selection and Medical Fitness Standards for Safety Critical Roles LUKL-OPS-401 Management of Train Drivers LUKL-OPS405 Train Driver Competence Management Standards

RS 100 Good Practice Guide on Competence Development

Development of train driver competence Consideration Course content Consideration of learner requirements Training structure Evaluation of training Assessment cycle Monitoring & review

LUKL-OPS-404 Train Driver Training LUKL-OPS-405 Train Driver Competence Management Standards

RS 232 Good practice guide on cognitive and individual risk factors

Human factors & system safety The human operator- last line of defence Concentration & attention, fatigue, stress, trauma Understanding the difference between human error and violations Risk mitigation techniques

LUKL-OPS-404 Train Driver competence Management Standards

Operations Standards Manager

RIS-3119-TOM Accident & Investigation Responsibilities of the lead organisation for formal investigations Responsibilities of the lead organisation for local investigations Responsibilities or railway undertakings Application railway undertakings Health & safety responsibilities Decision criteria – formal investigations

Reporting GSI’s, incidents, Close calls, near misses and contact guidance on the RIDDOR Regulations LUKL-OPS-416 Operational Accident and Incident Investigation LUKL-OCC-102 Safety Incidents and Safety Opportunities Reporting and Investigation LUKL-OPS-433 Operations Control Manual Operations Control Instructions

11.3 Statutory Reporting

Operations Standards Manager Assurance Director

GO/RT 3350 Communication of urgent operating advise

Professional head review & action as necessary LUKL-OPS-433 Operations Control Manual Operations Control Instructions

8.6 Urgent Operating Advices

Professional Head of Operations Professional Head of Engineering

RIS-3437-TOM Defective On Train Equipment Purpose and introduction Responsibilities of infrastructure managers Responsibilities of railway undertakings Application Railway undertakings Health & Safety responsibilities

Defective on train equipment LUKL-OPS-434 Operational Contingency Plan LUKL-OPS-433 Operations Control Manual Operations Control Instruction

7.4 Defect Reporting 12.1 Emergency Planning

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RIS-3119-TOM Accident incident investigation Immediate action requirements from LORUM Emergency procedure LUKL-OCC-102 Safety Incidents and Safety Opportunities Reporting and Investigation LUKL-OPS-443 Operational Accident and Incident Investigation

11.2 Safety Incidents and Safety Opportunities Investigation

Technical Director

RIS-8250-RST ( High risk defects) High risk defects Action when high risk defect is identified Administration NR-online Availability of NIR on-line Application railway undertakings Health & safety responsibilities Application of NIR –online to other rail vehicles, equipment and plant machinery Flow chart –Urgent safety related defects Safety related defect monitoring

Reporting of defects, incidents and accidents Handling of urgent advice LUKL-ENG-006 Safety Related Defect Reporting advice LUKL-OPS-433 Operations Control Manual Operations Control Instruction

7.4 Defect Reporting 12.1 Emergency Planning

Professional Head of Engineering

Reporting of injuries, diseases and dangerous occurrences regulations 1995

The requirements to notify, and subsequently send a report to the relevant authority (ORR) or local authority of fatal and non-fatal accidents arising out of or in connection with work or certain specified disease and dangerous occurrences

Reporting of GSI, accidents, near miss, close calls procedure LUKL-OCC-102 Safety Incidents and Safety Opportunities Reporting and Investigation

11.2 Safety Incidents and Safety Opportunities Investigation 11.3 Statutory Reporting

Assurance Director

Accident / Incident management

RIS-8047-TOM Reporting of safety related information

Requirements for reporting safety related information Responsibilities of infrastructure managers and railway undertakings for reporting safety related information Application of the document to railway undertakings Health & Safety responsibilities Events to be reported Accidents resulting in death or injury to people

Reporting of GSI, accidents, near miss, close calls procedure

11.1 Safety Incident and Safety Opportunity Reporting

Assurance Director

Safety Critical Work

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Competence Management for safety critical work System Requirements Competence management ORR Guidance LUKL-OCC-504 Competence Management of Safety Critical Work LUKL-OPS-402 Train Driver Training, LUKL-OPS-404 Traction Training, Assessment and Refresh LUKL-OPS-404 Train Driver Route Learning LUKL-OPS-411 Depot Driver Training LUKL-OPS-421 Shunter Training LUKL-ENG-002 Maintenance Policy

6 Training and Competency

Operations Standards Manager (PH)

Competence standards Selection & recruitment policy LUKL-OPS-405 Train Driver Competence Management Standards LUKL-OPS-432 Duty Control Manager Competence Management Standards LUKL-OPS-412 Depot Driver Competence Management Standards LUKL-OPS-422 Shunter Competence Management Standards LUKL-ENG-016 Engineering Technician Competence Management Standards LUKL-ENG-017 Grinder Technician Competence Management Standards

6.3 Recruitment and Selection

General fitness LUKL-OCC-507 Fatigue Management LUKL-OCC-502 Safety Critical Working Hours LUKL-POL-004 Drugs and Alcohol Policy LUKL-OPS-463 Operational Staff Booking On/off Arrangements LUKL-OPS-464 Shift Working Lifestyle guide

9 Occupational Health and Safety

Medical fitness Medical Fitness LUKL-OCC-205 Medical Standards for Safety Critical Duties

6.3 Recruitment and Selection 6.5 Competence Assessment and Monitoring

Assurance Director

Monitor & review

Occupational Health & Safety

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RIS-8070-TOM Testing Railway Safety Critical Workers for Drugs and Alcohol

Purpose & Introduction Drugs & Alcohol Policy LUKL-POL-004 Drugs & Alcohol Policy

13.2 Health, Safety and Environment Monitoring

Assurance Director

Positive Result See ‘For cause’ below.

Laboratories for drugs & Alcohol testing Supplier Requirements for the Approval of Medical Assessments & Drug & Alcohol Screening & Certification

For cause drugs & Alcohol testing D&A testing of staff for unannounced screening Pre-employment, Pre-appointment & Periodic Testing for Drugs & Alcohol Random Testing for Drugs and Alcohol ‘For Cause’ Testing for Drugs and Alcohol

Changes in working hours-safety critical work Risk assessment of change Control & monitoring of Excessive working hours LUKL-OCC-507 Fatigue Management

6.5 Competence Assessment and Monitoring

Assurance Director

Control measures Change

Hours for Employees Undertaking Safety Critical Work LUKL-OCC-502 Safety Critical Working Hours LUKL-OCC-507 Fatigue Management

Fire safety order 2005 Ensure so far as reasonably practicable the safety of employees; general duty in relation to non-employees to take such fire precautions as may reasonably be required in the circumstances to ensure premises are safe

Fire Safety LUKL-OCC-311 Fire Safety

• Fire Workplace • Fire risk assessment • Fire Extinguishers • Fire Log Book

12.3 First Aid Arrangements 12.4 Training and Competency 13.2 Health, Safety and Environment Monitoring

Assurance Director

Communications

Safety representatives & safety committees’ regulations 1997

Provide for the appointment of safety representatives and prescribe there function in relation to employees they represent in the work place

LORUM trade union agreements LUKL-OCC-104 Safety Representatives Roles and Responsibilities

2.9 Employee Involvement

Assurance Director

Health & Safety information for employees regulations 1989

Require information relating to health, safety and welfare to be communicated to employees, including the name and address of the enforcing authority; The address of the employment medical advisory service

LUKL-MSP-006 Management System Communications

10.3 Internal Communic’tion

Assurance Director

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Safety Management System Arrangements LUKL-OCC-001 Issue 8

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Health & Safety (Safety signs and signals) regulations 1995

Impose requirements in relation to the provision and use of safety signs and signals including the minimum requirements for the provision of safety and or health signs at work

LUKL-OCC-312 Safety Signs and Signals - Assurance Director

Health & Safety (consultation with employees) regulations 1996

Require employers to consult either that employees directly or representatives elected by their employees where there are employees not represented by safety representatives appointed by trade unions under the 1997 regulations

Collective bargaining 2.9 Employee Involvement

Assurance Director