The importance of managing change

13 August 2019

The lack of robust management of change (MoC) procedures may result in the introduction of unidentified and uncontrolled risks that compromise the operation of a safe railway.

Therefore, it is important when change is implemented, defined MoC procedures are followed.

For Rail Transport Operators (RTOs), the legal requirements to have MoC procedures in place are provided in Clause 11 of Schedule 2 of the Rail Safety (Local Operations) (Accreditation and Safety) Regulations 2018 (Vic) (Regulations).

Clause 11 requires an RTO’s safety management system (SMS) to contain MoC procedures which ensure changes which may affect the safety of railway operations are identified and managed so far as is reasonably practicable.

Six key steps are outlined in Clause 11 which MoC procedures must address:

  1. Establish the context of change
  2. Consult stakeholders or parties affected by the change
  3. Conduct a risk assessment
  4. Review the SMS
  5. Manage the implementation
  6. Monitor and review the change outcome.

This article provides brief guidance on these six key steps. The introduction of plastic railway sleepers into a rail transport operator’s network provides a practical example of a change.

Step 1: Establish the context of change

When considering the introduction of plastic railway sleepers, it is important that the change is defined within the context of the accredited organisation’s existing rail operations. It is suggested that specific questions be considered and answered.

  1. What is the scope of work?
  2. Which stakeholders are affected by the proposed change?
  3. What are the project’s major stages?
  4. What are the benefits associated with this change?
  5. What are the legislative and safety management system compliance requirements?

RTOs should consider whether to:

  • conduct a trial of plastic sleepers on a short section of track with a volume of rail traffic
  • install plastic sleepers in a section of track in conjunction with existing sleepers, for example, replace one sleeper in every three
  • replace all existing sleepers with plastic sleepers in a section of track.

It is important to consider what impact this proposed change will have on the RTO’s existing operations, inspection and maintenance requirements.

Step 2: Consult stakeholders or parties affected by the change

It is a legal requirement under the Regulations to consult all the affected parties. Consultation provides the opportunity for organisations and individuals are be affected by this proposed change to consider the introduction of plastic railway sleepers from their perspective. This engagement may result in the identification of additional risks to safety that need to be considered by the RTO.

It is suggested that the following questions be considered and answered:

  • which functional areas of the organisation will be affected by the change.
  • how will the change impact staff roles and responsibilities.
  • how will the change impact staff training requirements.
  • are there any external stakeholders (such as asset owners or funding providers) who need to be consulted regarding this proposed change?

Staff responsible for track inspection and maintenance will be affected by this proposed change; their feedback will be particularly important for the RTO to consider.

Step 3: Conduct a risk assessment

There are risks to safety associated with the introduction of plastic railway sleepers.

  • Changes in structural integrity and stability of the track (for example, under load, hot/cold conditions) over time. This may include the risk of gauge widening.
  • Changes in plastic railway sleeper performance following a bush fire.
  • Change in fire risk – are plastic railway sleepers combustible?
  • Material degradation due to exposure to sunlight (UV radiation), oil or other chemical substances.
  • OH&S manual handling risks associated with the weight of plastic railway sleepers.

RTOs should assess and consider how these risks differ from the risks associated with timber sleepers. To provide a balanced argument, it is suggested they should also consider the risks associated with not introducing plastic railway sleepers.

The risk assessment should include consideration of varying controls to manage the risks to safety associated with the introduction of plastic railway sleepers.

These controls may include:

  • Comparing the specifications for plastic sleepers with those for timber sleepers. Do plastic railway sleepers offer better or worse performance characteristics?
  • Support decision making with experience gained in other railway networks where plastic sleepers are approved for use.
  • Considering development work and the results of testing undertaken by the Institute of Rail Technology at Monash University. This work may validate the performance characteristics of the plastic railway sleepers.
  • Ensuring changes to track inspection and maintenance regimes for sleeper performance are more closely monitored.
  • Trialling, or progressively introducing, plastic railway sleepers to build up knowledge and experience with this product.
  • Reviewing and updating the sleeper installation procedure which may include mechanical insertion techniques.
  • Training of track maintenance staff.
  • Adverse environmental effects.

It is suggested that the following questions be considered and answered:

  1. Have hazards been identified for all stages of the asset life, that is, acquisition, construction, operation, maintenance and decommissioning of the plastic railway sleepers?
  2. Have hazards associated with environment, heritage, planning and hazardous materials been incorporated into the risk assessment?

Step 4: Review the safety management system

The RTO’s SMS may need to be reviewed as part of the introduction of plastic railway sleepers. This would include documenting any of the risk controls that have been identified in step 3 and agreeing to the details of the implementation.

For example, if the sleeper installation procedure requires updating or the track inspection regime is to be modified, these changes should be documented and integrated into the SMS.

It is suggested that the following questions be considered and answered:

  1. Have changes to staff roles and responsibilities been captured by updating staff position descriptions?
  2. Do emergency and contingency plans need to be updated?

Step 5: Manage the implementation

A formal project management process can help to ensure the successful introduction of plastic railway sleepers. A project management plan should define the objective of the project and consider the:

  • implementation schedule
  • methodology for delivering the project
  • financial and material resources required
  • standards/quality to be achieved
  • risk management (including OH&S risks)
  • contingencies.

These dimensions of the project management plan are interactive – a change in one dimension may affect others.

Step 6: Monitor and review the change outcome

Once the change has been successfully implemented, the safety performance of the plastic railway sleepers should be monitored and periodically assessed. The RTO should be closely monitoring compliance with the track inspection and maintenance procedures which may have been updated as part of managing this change. Other risk controls identified during the risk assessment process should be monitored and assessed for effectiveness. Additionally, feedback from the end users should be incorporated within the periodic assessments.

As the rail industry implements innovative ideas or new technologies that can improve efficiency and safety, it is important the industry demonstrates how it is managing risk with any change. Change is fundamental for continuous improvement.

Three planners discuss change