ORR consults on the continued operation of Mark 1 coaches and stock without central door locking

A Mark 1 coach typical of the type still used for enthusiast specials and rail tours on the main line railway.

The Office of Rail and Road (ORR) has launched an industry consultation on the application of the Railway Safety Regulations 1999 (RSR 99) to Mark 1-type and hinged-door rolling stock when operated on railway infrastructure where line speed exceeds 40km/h.

This will mostly affect heritage railways and operators of historic trains on main lines.

RSR 99 required the installation of a form of train protection on the railway, and also required the staged withdrawal of Mark I rolling stock and of rolling stock with hinged doors without central locking. RSR 99 was introduced to deal with safety risks highlighted by a series of accidents from trains passing signals at danger and collisions involving Mark 1 rolling stock.

Under RSR 99:

  • A train operator must not operate a train without installing a train protection system for that train;
  • An infrastructure manager must not permit the operation of any train without a train protection system for the relevant railway;
  • A train operator must not operate Mark I or hinged-door vehicles on the railway and the infrastructure manager must not permit the operation of such vehicles on the railway unless these vehicles have been modified to prevent the underframes of vehicles overriding.

The latter requirement was clarified in guidance note 45:

The term Mark I rolling stock is used in the railway industry to describe a series of vehicle types, including both electric and diesel multiple units and locomotive-hauled vehicles, built mainly in the 1960s and 1970s, which share certain characteristics.

There is a relatively weak body shell, mounted on a strong structural steel underframe in which most of the vehicle’s structural strength is concentrated.

This type of rolling stock does not have the crashworthiness of trains built to modern standards and is likely to suffer far more damage in a collision. There are no safeguards to reduce the likelihood of ‘overriding’ – where the underframe of one vehicle rides over the underframe of another and may penetrate the passenger space of the other vehicle – and the consequences of overriding are particularly serious in this type of vehicle because of the weakness of the bodyshell.

Typical slam-door stock in use post-privatisation.

Hinged doors

Regulation 5 prohibited hinged doors:

(1) No person shall operate, and no infrastructure controller shall permit the operation of any rolling stock on a railway, if the rolling stock has hinged doors for use by passengers for boarding and alighting from the train (other than doors which have a means of centrally locking them in a closed position).

(2) Paragraph (1) shall not apply to rolling stock which, at the relevant time, is being exclusively operated other than for the carriage of fare-paying passengers.

Guidance notes 53-55 clarified this regulation:

53 – Regulation 5(1) prohibits the operation of rolling stock which has hinged doors without central locking (sometimes known as ‘slam door’ stock) on a ‘railway’ – see the Schedule for the meaning of ‘railway’ in these Regulations.

The prohibition applies from 1 January 2005 (regulation 1), and is placed on both train operators and infrastructure controllers. Under regulation 5(2), the prohibition does not apply to rolling stock when it is carrying no fare-paying passengers.

54 – Most rolling stock which has hinged doors without central locking falls within the definition of Mark I rolling stock, which is required by regulation 4 to be withdrawn or rebodied by 1 January 2005. However, there are a number of non-Mark I vehicles which have these doors. These vehicles will have to be withdrawn, rebodied, or to have central locking installed before 1 January 2005 if they are to continue to operate on a ‘railway’ (see paragraph 55).

55 – The provisions on hinged-door rolling stock apply only to stock which is operated on a ‘railway’ as defined in these Regulations (see the Schedule). They do not apply, for example, to rolling stock which is operated on a railway which has a line speed of 25 mph of less. This excludes most heritage railways.

It was recognised that, for hinged door rolling stock, it was impossible for the range of heritage stock primarily operating on the mainline railway to immediately comply with the requirements of the regulations, most notably for central door locking (CDL).

As a result, RSR 99 permitted the use of exemptions until rolling stock was progressively retrofitted with CDL or equally effective systems.

Now, 21 years on from the introduction of the regulations, the ORR is of the opinion that sufficient time has passed for relevant stock to be fitted with CDL. The withdrawal from service and dismantling of more modern mainline hinged door carriages fitted with CDL means that serviceable second-hand components for CDL are available that can be retrofitted to hinged door stock at reasonable cost.

The ORR therefore believes there is no practical basis for justifying continuing non-compliance with the requirement to fit CDL and for further generic exemptions to be issued for hinged door rolling stock operating on infrastructure where line speed exceeds 40km/h.

With regard to Mark 1 type rolling stock exemptions, ORR is proposing the following future requirements:

  • Where Mark 1 type carriages are used, there is a clear inspection and maintenance regime, with appropriate accompanying records, to demonstrate that structural crash pillars are maintained to an acceptable standard, and
  • That the remainder of the vehicle underframe and body shell are also maintained in a state of good repair.

Where such evidence, as indicated above, is available, ORR would normally expect to continue to issue exemptions against RSR 99 Regulation 4 (Prohibition of Mark 1 rolling stock).

Details of the consultation, which closes on 11 December 2020, are available on the ORR website, as is a full copy of RSR 99, complete with original guidance.

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