Office of Rail Transport Risk Management -

Statistics from the Railway Transport Authority show that in 2021, rail carriers and infrastructure managers assesed 1,474 changes to the rail system.

Significantly, the share of significant changes fell in 2021, amounting to only 1%. This is a sizable drop compared to 2020, when the share was 3%, while in 2019 it was 2%. At the same time, all changes assessed as significant were implemented by rail carriers - no significant change was recorded by infrastructure managers.

The data presented here confirm the thesis, which has been valid for several years, that rail market players invariably avoid recognizing changes as significant. Particularly glaring here is the example of infrastructure managers, who did not assess any change as significant in 2021. This is incomprehensible in the situation of many ongoing investments, often involving the upgrading of entire rail lines. The above raises reasonable doubts as to whether the entities are correctly classifying and assessing the changes being implemented.

Therefore, the President of UTK has developed a set of actions that he will undertake in supervising the application of risk assessment by market participants. A description of these activities is included in the "Action Plan for Improving the Risk-Based Approach to Safety Management." The aim of these activities is to improve risk management by those required to apply Regulation 402/2013 through active enforcement of the requirements of the common method and educational activities.

The Plan explains:

• how information will be obtained from entities to verify the comprehensive application of the change assessment process, 
• what is included in the unified change assessment checklist,
• how documentation of change assessment will be obtained,
• how the application of the risk-based approach will be enforced in the interventions undertaken by the President of UTK,
• what the verification of safe integration in the technical dimension looks like at the stage of authorizing the operation of fixed installation subsystems,
• what the verification of common risk management is.

The development of the Plan should also be an incentive for market players to better manage risks without waiting for UTK to act. Subsystem manufacturers, infrastructure managers, carriers and entities in chargé of maintenance (ECMs) should analyze, with the Action Plan in mind, the procedures they have in place and past practices to make sure they are properly and effectively assessing changes and managing their risks.

The team's activities are aimed at improving the approach of rail market operators to risk-based safety management. Particular emphasis will be placed on the Common Safety Method for risk evaluation and assessment, as set forth in the European Commission's implementing regulation known as the CSM-RA¹.

For more on the Common Safety Method for risk evaluation and assessment, see the following link: https://utk.gov.pl/pl/bezpieczenstwo-systemy/zarzadzanie-bezpieczen/wspolne-metody-bezpiecz/ocena-ryzyka/16431,Ocena-i-wycena-ryzyka.html (page in Polish).

In particular, the Team is tasked with coordinating the work set out in the action plan for improving the risk-based approach to safety management. The team will also conduct an assessment of the status of the action plan and initiate updates. Other tasks include the establishment of a unified approach by rail market participants and the development of best practices for the application of the CSM-RA and a common safety method for monitoring the CSM-M Regulation².

The team is to establish, through the publication of recommendations, a unified approach and develop best practices regarding the supervision of the application of the CSM-RA and CSM-M. The team will also be tasked with coordinating activities regarding CSM-RA and CSM-M undertaken by the Authority. The team is to promote information on the application of CSM-RA and CSM-M and their benefits, both within UTK and among railroad market participants. These activities are to be carried out through the organization of workshops, participation in conferences and the transmission of messages through electronic communications. The recommendations adopted by the team can be found below.

Below you will also find the Checklist for the Application of Regulation 402/2013, which will be used in all activities of the UTK President, such as inspections or proceedings for authorizations for subsystems.

However, we recommend its use for all rail market players. With its help, you can independently check whether the assessment of the significance of the change has been done correctly.

1 Commission Implementing Regulation (EU) No 402/2013 of 30 April 2013 on the common safety method for risk evaluation and assessment and repealing Regulation (EC) No 352/2009 (OJ L 121 3.5.2013, p. 8 recast)

2 Commission Regulation (EU) No 1078/2012 of 16 November 2012 on a common safety method for monitoring to be applied by railway undertakings, infrastructure managers after receiving a safety certificate or safety authorisation and by entities in charge of maintenance (OJ L 320, 17.11.2012, p. 8–13).