Guidance Note: Heritage Railway Association

Ref No: HGR-A0012
Issue No: 05
Issue Date: July 2016
HERITAGE RAILWAY ASSOCIATION
GUIDANCE NOTE
MANAGEMENT of SAFETY CRITICAL WORK

Including Drugs and Alcohol Policy
Purpose
This document describes good practice in relation to its subject to be followed by Heritage Railways,
Tramways and similar bodies to whom this document applies.
Endorsement
This document has been developed with, and is fully endorsed by, Her Majesty’s Railway Inspectorate
(HMRI), a directorate of the Office of Rail Regulation (ORR).
Disclaimer
The Heritage Railway Association has used its best endeavours to ensure that the content of this document
is accurate, complete and suitable for its stated purpose. However it makes no warranties, express or
implied, that compliance with the contents of this document shall be sufficient to ensure safe systems of work
or operation. Accordingly the Heritage Railway Association will not be liable for its content or any
subsequent use to which this document may be put.
Supply
This document is published by the Heritage Railway Association (HRA).
Copies are available electronically via its website www.hra.uk.com
Issue 05 page 1 of 10 © Heritage Railway Association 2016

The Heritage Railway Association, Limited by Guarantee, is Registered in England and Wales No. 2226245
Registered office: 2 Littlestone Road, New Romney, Kent, TN28 8PL
HGR-A0012-Is05 _____________________ Management of Safety Critical Work
Users of this Guidance Note should check the HRA website, www.hra.uk.com , to ensure that they have the
latest version.
Table of Contents
1. Introduction ........................................................................................................................................... 3
2. Recommendations ................................................................................................................................ 3
3. Definitions specific to this Guidance Note ............................................................................................ 3
4. Meaning of “Safety Critical Work” ......................................................................................................... 4
5. Competence Management including Assessment ............................................................................... 5
6. Fitness .................................................................................................................................................. 5
7. Control of Fatigue ................................................................................................................................. 5
8. Age Limits for Safety Critical Work ....................................................................................................... 6
9. Contractors ........................................................................................................................................... 6
10. Records ................................................................................................................................................ 6
11. Drugs and Alcohol Policy ...................................................................................................................... 6
12. References ........................................................................................................................................... 9
Appendix A: Suggested form of Drugs and Alcohol Notice .......................................................................... 10

1. Introduction
A. This Guidance has been provided to assist the duty holder of heritage railways and tramways in
complying with Part 4 of the Railways and Other Guided Transport Systems (Safety) Regulations 2006
(ROGS), as amended by the Railways and Other Guided Transport Systems (Safety) (Amendment)
Regulations 2011.
B. The section on Drugs and Alcohol has been provided to assist the duty holder of heritage railways and
tramways in complying with Sections 27 and 28 of the Transport and Works Act 1992.
C. Duty holders will be aware that they have a legal obligation to passengers, contractors, other visitors
and staff under the Health and Safety at Work etc Act, 1974.
D. The term ‘man’ or ‘men’ in this Guidance note should be read as applying equally to men and women
and ‘he’, ‘him’ and ‘his’ should be similarly interpreted.
E. The term ‘staff’ in this Guidance note should be taken to include unpaid volunteer workers as well as
paid staff.
F. The term ‘railway’ should be taken to include heritage tramways and similar bodies where appropriate.
2. Recommendations
A. This guidance note is issued as recommendations to duty holders.
B. Many railways are already operating systems, which, in some cases, are to a higher standard than
those set out in this guidance note. This highlights the fact that it is the responsibility of the duty
holder, having undertaken the necessary risk assessments, to implement controls that are applicable
and necessary relative to the operating conditions on their railway.
C. Where railways decide to take actions that are not in conformity with these recommendations,
following appropriate risk assessments or for other reasons, it is recommended that those decisions
are reviewed by the senior management body of the organisation and a formal minute is recorded of
both the decision reached and the reasons for reaching it.
3. Definitions specific to this Guidance Note

“Safety Critical Work” Work that if incorrectly carried out can give rise to a failure, accident or incident;
see also Section 4.
“Assessor” Means any person who is deemed competent to make an objective assessment
of another person’s competence or fitness to carry out safety critical work.
“Fitness” Means physical and mental fitness.
“Maintenance” Includes the installation, examination or testing of components and includes
repair work, reconditioning or alteration.
“Components” Includes all parts of locomotives, rolling stock, permanent way, structures and
signalling that are related to the safe operation of the railway / tramway. This
can include whole items and associated sub-systems, from boilers to fish plates.
SMS Safety Management System.
Drugs Includes: “Recreational Drugs”, Drugs of Abuse, and Medications (both
prescribed and “over the counter”) that can affect an individual’s ability to perform
their duties normally.
SPAD A Signal Passed at Danger (SPAD) is where the signalling equipment was
working properly, but the train passed the signal even though there was
adequate opportunity for it to stop.

4. Meaning of “Safety Critical Work”
A. The ORR “Guide to ROGS” states that there are a dozen broad areas of work that ROGS define as
‘safety-critical tasks’. The regulations apply to how organisations manage all employees who perform
these tasks where they could have a significant effect on the health and safety of people working on or
using the transport system.
1. The first group of tasks must only be performed by someone who has been assessed as
competent and fit to carry them out. They are as follows:
i. Driving and train dispatch;
ii. Operating signalling equipment including signals, points and level crossings, and
related communication;
iii. Coupling or uncoupling vehicles;
iv. Controlling the power supply connected to track and vehicles;
v. Checking vehicles are working properly and, if loaded, loaded correctly; and
vi. Protecting the safety of people working on or near to the track.
2. The work involved in supervising and checking a second group of tasks is also classed as safety-
critical work under ROGS. The important thing here is that these tasks are at least supervised, or
the work checked, by someone who has been assessed as competent and fit to do so before the
work has the opportunity to affect the health and safety of people working or travelling on the
transport system. These tasks are as follows:
i. Installing vehicle parts;
ii. Maintaining vehicles that are being used (and their parts);
iii. Installing or maintaining any part of the infrastructure;
iv. Installing or maintaining the power supply;
v. Installing, maintaining or operating the communications systems used to control
vehicle movements or call the emergency services; and
3. Training – or supervising training – in any of the above tasks where the training involves carrying
out the actual task.
B. Practical Applicability:
1. The following jobs / tasks on Heritage Railways are safety critical:
i. Driver (Steam, Diesel and Electric Locomotives, railcars, trams, etc.), plus driver of
“On Track” equipment (other than within an Engineering Possession);
ii. Fireman / Second Man / Driver’s Assistant;
iii. Guard;
iv. Pilotman;
v. Signalman / Crossing Keeper;
vi. Controller of the Railway / Tramway or equivalent title;
vii. All those involved with train dispatch;
viii. Shunter;
ix. Person In Charge Of Possession (PICOP);
x. Anyone involved in the supply of electricity for traction purposes; and
xi. Anyone involved in training for the above tasks where the training involves carrying
out the actual task.

2. A “fitter” is Safety Critical if he is responsible for the final confirmation that an item of equipment is
fit for use after installation or maintenance.
3. In respect of Permanent Way and Structures, routine patrolling (including Lookouts) is Safety
Critical.
4. “Fitness to Run”: A person is Safety Critical if he is responsible for the final confirmation that a
locomotive or items of rolling stock is / are fit to run on the operational railway, following
construction, rebuild or repair, or before the start of a day’s operation.
5. Where a person is checking that any components are fit for use, a full record must be maintained
detailing any outstanding faults or other comment, together with date, time and signature.
6. The above lists are not exhaustive.
C. Specification of Safety Critical Tasks:
All Duty Holders should identify the Safety Critical tasks in their own organisation and specify these
as part of their Safety Management System (SMS).
5. Competence Management including Assessment

A. A comprehensive process must be in place to ensure that all Safety Critical staff are fit and competent
to undertake the task allocated to them.
B. Guidance on appropriate Competence Management Systems is given in the HRA guidance note:
“HGR-A0050 - Competence Management Systems.”
C. NOTE: No person undertaking Safety Critical Work is to be exempted from assessment, however
senior he is in the organisation.
6. Fitness
A. Guidance on medical fitness assessment is given in the HRA guidance note: “HGR-A0015 - Fitness
Assessment for Safety Critical Workers”.
B. Though workers may be fit, consideration must be given to their working environment. For example
when temperatures are unusually low or high, or humidity is high, normal expectations on capacity and
concentration may not apply. Workers and managers should be realistic about what can be achieved
in these conditions, and changes to working patterns and facilities may be required at times to ensure
that staff remain fit for work. Particular consideration should be given to locomotive footplate staff in
hot and humid weather as they may be subject to heat stress in these conditions and this can lead to
loss of concentration, fainting and nausea as well as more serious conditions in extreme cases.
7. Control of Fatigue
A. This section should be read in conjunction with the ORR “Managing Fatigue in Safety Critical Work”
and the signing on declaration in section 11 which refers to rested and fit for duty.
B. Arrangements need to be in place to ensure that staff do not take up duty when fatigued, and do not
work excessive hours. In assessing hours worked, due allowance must be made for Safety Critical
work undertaken for other operators. In this context, it is important that duty holders co-operate with
other employers to ensure that individuals are not fatigued when carrying out Safety Critical Work on
successive days (or within the same day) for different undertakings.
C. In considering the effects of fatigue, allowance must be made where staff travel long distances to work
on the Railway.
D. As a general guideline, it is recommended that:
1. “shifts” do not exceed twelve hours in length;
2. there is a minimum break between shifts of twelve hours;
3. a maximum of seventy two hours are worked in a week; and
4. no more than 13 consecutive days are worked without a day off.

E. Details of Maximum shift length and minimum rest periods should be specified in the SMS.
F. Where appropriate, risk assessment of the levels of fatigue should be undertaken taking into account
the nature of the duties involved.
G. Records of hours worked by Safety Critical staff should be maintained.
H. A process should be in place to mitigate against staff working when fatigued – this can be by way of:
1. Monitoring at “Booking-On” points; and / or
2. Random checks.
I. Where an individual is known to undertake Safety Critical Work for any other employer, there is a duty
to liaise with that organisation to ensure that fatigue is properly controlled.
8. Age Limits for Safety Critical Work

A. ROGS sets no minimum or maximum age for staff engaged in safety Safety Critical Work. However,
the following are nationally recognised norms and it is recommended that these be followed.
B. No person (other than a Trainee - see next paragraph) should undertake Safety Critical Work until they
attain the age of 18. No person may perform the duty of driver of a railway train (other than as a
Trainee) under the age of 21.
C. Staff may train for Safety Critical tasks once they are 16 (18 for drivers). They must not be allowed to
undertake such work unless properly supervised by a fully competent and qualified person.
D. There is no upper age limit for staff undertaking Safety Critical Work. To bar an individual from Safety
Critical Work on grounds of age alone may be in contravention of the Equality Act 2010.
9. Contractors
A. If Contractors are employed to undertake or be involved with Safety Critical Work or Tasks, the Duty
Holder’s Policy must ensure that checks are carried out to ensure the contractor’s competence.
10. Records
A. Complete records of the competences of all staff who undertake any Safety Critical Work should be
maintained.
B. The records should include the task assessed and the date when the person is due to be re-assessed.
C. The records should be available for inspection by all appropriate supervisors.
D. Records should be retained for as long as a person is employed or is an active volunteer, and for at
least six years afterwards.
11. Drugs and Alcohol Policy

A. Duty holders must ensure that they meet the legal requirements, specifically compliance with Sections
27 and 28 of the Transport and Works Act 1992 which are given below:
Section 27 - Offences involving drink or drugs on transport systems

(1) If a person works on a transport system to which this Chapter applies:
(a) as a driver, guard, conductor or signalman or in any other capacity in which he can
control or affect the movement of a vehicle, or
(b) in a maintenance capacity or as a supervisor of, or look-out for, persons working in a
maintenance capacity,
when he is unfit to carry out that work through drink or drugs, he shall be guilty of an offence.

(2) If a person works on a transport system to which this Chapter applies:
(a) as a driver, guard, conductor or signalman or in any other capacity in which he can
control or affect the movement of a vehicle, or
(b) in a maintenance capacity or as a supervisor of, or look-out for, persons working in a
maintenance capacity,
after consuming so much alcohol that the proportion of it in his breath, blood or urine exceeds the
prescribed limit, he shall be guilty of an offence.
(3) For the purposes of this section, a person works on a transport system in a maintenance capacity if
his work on the system involves maintenance, repair or alteration of:
(a) the permanent way or other means of guiding or supporting vehicles,
(b) signals or any other means of controlling the movement of vehicles, or
(c) any means of supplying electricity to vehicles or to the means of guiding or supporting vehicles,
or involves coupling or uncoupling vehicles or checking that they are working properly before they
are used on any occasion.
(4) For the purposes of subsection (1) above, a person shall be taken to be unfit to carry out any work if
his ability to carry out that work properly is for the time being impaired
Section 28 - Offences by operators of transport systems

(1) If a person commits an offence under section 27 above, the responsible operator shall also be guilty
of an offence.
(2) In this section “the responsible operator” means:
(a) in a case where the transport system on which the offence under section 27 above is committed
has only one operator, that operator;
(b) in a case where the transport system on which the offence under section 27 above is committed
has more than one operator, whichever of them is responsible for the work giving rise to the
offence.
(3) No offence is committed under subsection (1) above if the responsible operator has exercised all
due diligence to prevent the commission on the transport system of any offence under section 27
above.
(4) If a person commits an offence under section 27 above in the course of his employment with a
person other than the responsible operator, his employer shall (without prejudice to any liability of
that operator under subsection (1) above) also be guilty of an offence.
(5) No offence is committed under subsection (4) above if the employer has exercised all due diligence
to prevent the commission on the transport system by any of his employees of any offence under
section 27 above.
B. Practical Application
1. It is essential that all staff undertaking Safety Critical roles are made aware of the requirements of
the Act. This should be achieved:
i. At induction and during other suitable training;
ii. By a clear statement in the Railway’s Rule Book;
iii. By statements in other internal publications;

iv. By Notices prominently displayed in locations where staff sign on for duty and / or
where work takes place, such as:
1. Signal boxes;
2. Locomotive Sheds;
3. Depots; and
4. Other areas where staff congregate.
2. It must be made clear that no member of staff may:
i. Report for duty under the influence of alcohol;
ii. Report for duty under the influence of drugs*;
iii. Consume alcohol on duty; or
iv. Consume drugs* on duty.
3. * Medicinal drugs may be consumed if they do not impair performance. Members of staff should be
advised to ascertain from their doctor or pharmacist if the product is safe to use when undertaking
safety critical duties. If their own GP is unsure they may need to consult the HRA medical advisor.
For practical purposes, products bearing the inscription “May cause drowsiness” or “Do not
consume if driving or operating machinery” are not compatible with Safety Critical Work.
4. It is recommended that staff undertaking SCW should sign on at the beginning of every turn of duty
or work. The “Signing On” sheets should have a declaration in the heading. A suggested form of
words is:
“I confirm that I am adequately rested and refreshed, and that I will only
undertake work for which I am either currently qualified or training under
supervision, fit for duty and not under the influence of alcohol, drugs or
medication that impairs my ability to work safely. I do not have a medical
condition that makes it unsafe for me to carry out my duties.”
5. The following limits are currently prescribed in relation to alcohol (Transport and Works Act, 1992),
No more than:
i. 35 microgrammes of alcohol in 100 millilitres of breath,
ii. 80 milligrammes of alcohol in 100 millilitres of blood, or
iii. 107 milligrammes of alcohol in 100 millilitres of urine,
6. Railways should consider adopting the stricter Railway Group Standard levels, particularly where
they have mainline connections and interworking.
7. A suggested form of Drugs and Alcohol Notice is given in Appendix A.
C. Compliance with Section 28
Due Diligence
1. It is essential that “Due Diligence” is applied to ensure, in so far as is reasonably practicable, that
all members of staff comply with Section 27 of the Act.
2. This can be achieved by:
i. Ensuring that all staff are aware of the requirements of the Act (see above); and
ii. Regularly monitoring staff compliance.
3. Monitoring can be achieved by:
i. Observing and talking to staff when they commence duty; and
ii. Periodic checks early in the working day.

Random Testing
4. It is recommended that a process be adopted to randomly test a sample of safety critical staff for
the presence of drugs and alcohol.
“For Cause” Testing
5. Following an accident or incident all relevant staff should be tested for both alcohol and drugs if
there is any suspicion that their performance may have been impaired. The Management of the
Railway should ensure that suitable arrangements to achieve this are in place and that the rules
about who is tested are unambiguous and available to all staff.
6. Examples of circumstances which will normally require individuals to be tested include:
i. SPAD;
ii. Serious irregularities in block working or misuse of token (entering section without a
token);
iii. Any collision or derailment requiring report under RIDDOR and / or to RAIB;
iv. Any incident involving a third party where damage or injury has occurred.
The SMS
7. Details of the Railway’s Drugs and Alcohol Policy, and how compliance with this is achieved,
should appear in the SMS.
12. References
A. The Railways and Other Guided Transport Systems (Safety) Regulations 2006 (ROGS)
B. The Railways and Other Guided Transport Systems (Safety) (Amendment) Regulations 2011.
C. The Transport and Works Act 1992.
D. Documents from the Office of Rail Regulation:
1. RSP 004: Safety critical tasks - Clarification of ROGS Regulations requirements
E. HRA Guidance Notes:
1. HGR-A0015 - Fitness Assessment for Safety Critical Workers
2. HGR-A0050 - Competence Management Systems
F. “Heat Stress in the Workplace” available free from http://www.hse.gov.uk/pubns/indg451.pdf
G. Railway Group Standards’ from Rail Safety and Standards Board:
1. GE/RT9070: Drugs and Alcohol
2. GE/GN 8070: Guidance on the Management of Drugs and Alcohol
______________________________________ end of main document ______________________________________

Appendix A: Suggested form of Drugs and Alcohol Notice
“Name of Railway or Tramway”

DRUGS AND ALCOHOL
All staff (both employees and volunteers) are reminded that they must not:
 Report for duty under the influence of alcohol

 Report for duty under the influence of drugs
 Consume alcohol on duty
 Consume drugs on duty
The term “Drugs” includes medication (both prescribed and bought “over the
counter”) that can affect performance. Such products are often marked:
“May cause drowsiness”
or
“Do not drive or operate machinery …..”
“Influence” means:
a) The presence of drugs for which there is no legitimate medical need

for either their use or the quantity of their use
b) More than:
 35 micrograms of alcohol in 100 millilitres of breath, or
 80 milligrams of alcohol in 100 millilitres of blood, or
 107 milligrams of alcohol in 100 millilitres of urine
If you are taking medication, you must consult your Manager or Supervisor for
advice.
If you consider that you may have an addiction to alcohol or drugs, you MUST
volunteer this information to your manager.
Staff in “Safety Critical” posts are further reminded that it is a CRIMINAL

OFFENCE under Section 27 of the Transport and Works Act 1992 for any such
person to report for duty under the influence of alcohol or drugs.
You are reminded the Company may carry out random testing for alcohol and
drugs.
Signed on behalf of the company: ................
________________________________________ end of appendix ________________________________________


Guidance Note: Heritage Railway Association

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Ref No: HGR-A0012

HERITAGE RAILWAY ASSOCIATION

MANAGEMENT of SAFETY CRITICAL WORK

Issue 05 page 1 of 10 © Heritage Railway Association 2016

Issue 05 page 2 of 10 © Heritage Railway Association 2016

3. Definitions specific to this Guidance Note

Issue 05 page 3 of 10 © Heritage Railway Association 2016

Issue 05 page 4 of 10 © Heritage Railway Association 2016

5. Competence Management including Assessment

Issue 05 page 5 of 10 © Heritage Railway Association 2016

8. Age Limits for Safety Critical Work

11. Drugs and Alcohol Policy

Section 27 - Offences involving drink or drugs on transport systems

Issue 05 page 6 of 10 © Heritage Railway Association 2016

Section 28 - Offences by operators of transport systems

Issue 05 page 7 of 10 © Heritage Railway Association 2016

Issue 05 page 8 of 10 © Heritage Railway Association 2016

Issue 05 page 9 of 10 © Heritage Railway Association 2016

Appendix A: Suggested form of Drugs and Alcohol Notice

“Name of Railway or Tramway”

 Report for duty under the influence of alcohol

a) The presence of drugs for which there is no legitimate medical need

Staff in “Safety Critical” posts are further reminded that it is a CRIMINAL

Signed on behalf of the company: ................

________________________________________ end of appendix ________________________________________

Issue 05 page 10 of 10 © Heritage Railway Association 2016

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