WCRC - the ongoing battle with ORR.

[adb968008]

1 hour ago, black and decker boy said:

I think there would be great challenges with seatbelts on trains:

 

no enforcement. Getting a ticket check is random enough without the same staff member having to convince up to 1000 passengers to continually wear a seat belt. zero enforcement on DOO.

 

 

seatbelt enforcement doesnt need to be mandatory.

it isnt on airlines, except during take off and landing (and predicted turbulance).

 

 

1 hour ago, black and decker boy said:

our trains are not compulsory seating  so there will always be standing passengers

but does that excuse / negate need to make seated passengers safer ?

 

Using cdl as an example, it only keeps those opening a door safer, those seated in the saloon it adds no value either.

 

 

1 hour ago, black and decker boy said:

 

the joy of trains is the ability to move around: buffet / shops, toilets, general

leg stretch.
 

No chance of early warning of an incident like on a plane with the fasten seatbelt signs  (plane radar often predicts turbulence)

 

Turbulance is most often unexpected.

For that reason airlines always reccomend having it loosely fastened….

 

1 hour ago, black and decker boy said:

 

our suburban trains with 3+2 seats are so cramped in peak rush hour that adding seatbelts wound serious discourage travel and probably not be feasible with the current seat structure

 

 

suburban trains dont always go 100mph … the need on a slow train is low… but longer distance intercity….. does.

 

1 hour ago, black and decker boy said:

are our rolling stock structures (floor pans etc) strong enough to hold the weight of the seat plus fully occupied passenger weights (currently only has to restrain the seat structure)

 

but passengers will involuntarily move… I know because I did.

 

1 hour ago, black and decker boy said:

 

there is still going to be loose and therefore airborne luggage as no plane style lockers and often no seat or space under seat for bags.

 

TPWS and ETCS should (and are intended) to reduce the risk of head on collisions. Heavy deceleration due to other incidents (LUMO at Peterborough, the 195s at Grange) resulted in walking wounded but no fatalities AFAIK.

walking wounded, whom with an airline style lap belt may not have been wounded.

 

1 hour ago, ruggedpeak said:

 

 

Trains

 

"It has been shown that there is no net safety benefit for passengers who choose to wear 3-point restraints on passenger-carrying rail vehicles. Generally, passengers who choose not to wear restraints in a vehicle modified to accept 3-point restraints receive marginally more severe injuries."[127]

 

https://en.wikipedia.org/wiki/Seat_belt#cite_note-127

Airlines use a lap belt.

A car style seatbelt would imo get a lot of resistance from use and i’m not sure the benefit… most train passengers, like airline and coach passengers have the rear of an airline seat to face.. car passengers have a front window and nothing stable to grab.

 

All i’m saying is my own experience…. I know an airline lap belt would have stopped me going flying across a coach, and it needed it. Had the train derailed.. I wouldnt be here going against the establishment grain that I am 100% confident on. Chances are my body would have taken another passenger out with me, as i’ve not got my own wings and Ive learned I fly like a piano.

it sounds like it maybe worth a revisit if the last study was based on Ford seat belts from the 1990’s… The world has moved on a bit, even long distance coaches in the 1990’s didnt have seatbelts back then, and have since adopted it.

 

 

 

Edited April 9 by adb968008

[Morello Cherry]

4 hours ago, Wheatley said:

Tim Farron isn't exactly a stranger to   WCRC:

 

https://www.railadvent.co.uk/2018/06/train-services-return-to-the-lake-district-thanks-to-tim-farron-and-west-coast-railways.html

 

Fairly sure i never saw Her Maj open her own door. 

 

 

I am reminded of a friend of mine who worked for the EU in reforming the administration of the borders in the former Communist states of Eastern Europe. She described border policy like this:

 

"Under Communism the aim of the border was to keep everyone in, in post-Communism the aim at the border is to keep everyone out'.

 

I tend to see the aim on public trains as being to keep everyone inside the train, and on the royal train to keep everyone out of the train.

 

TBF I don't recall seeing many shots of her Maj window hanging or Charlie bellowing out of the window because there is some good clag.

 

[jjb1970]

More airlines seem to be fitting three point seat belts in business class at least. Personally I like the reverse herringbone configuration because in most likely impact scenarios the seat would absorb the impact forces rather than a belt.

[ruggedpeak]

8 minutes ago, Reorte said:

If trains had seatbelts and you had to wear them that might well be the final straw that puts me off using them for good. I already travel by train less than I used to because I find it an increasingly unpleasant experience anyway. I'd rather have the risk (TBH as I've said earlier I'd rather have the risk of things like straightforward doors too, not that that means I'm defending WCRC in this, since as I've said it's their job to follow the rules whatever they think of them).

the fundamental issue is often even getting a seat, so belts are irrelevant unless like a plane TOC's are guaranteeing a seat for every passenger, which leads to.....

 

3 minutes ago, rodent279 said:

Seatbelts on trains would completely change the economics of railway operation.

as has been said earlier, every train service would effectively be a Pullman, VSOE service then. Not sure that will go down well with the travelling public....

 

Of course you could make everyone lie in a small protected cocoon chamber and stack them into an upgraded freight wagon (get loads more people in then..) or replace the seats with rollercoaster style seating and restraint systems, would improve things dramatically......

[Michael Hodgson]

21 minutes ago, ruggedpeak said:

Would a press junket in a train that does not meet current passenger safety requirements be allowed under a competent risk assessment?

 

If WCRC want another lesson on how to shoot yourself in the foot, they should look what happened when BR had a press junket on the APT!

 

 

[adb968008]

7 minutes ago, Morello Cherry said:

 

TBF I don't recall seeing many shots of her Maj window hanging or Charlie bellowing out of the window because there is some good clag.

 

He didnt need to… he goes right up front for the action, and has an altogether different set of regulators red penned in his book.

Edited April 9 by adb968008

[Michael Hodgson]

Just now, ruggedpeak said:

Of course you could make everyone lie in a small protected cocoon chamber and stack them into an upgraded freight wagon (get loads more people in then..) or replace the seats with rollercoaster style seating and restraint systems, would improve things dramatically......

 

Ah, but would they still be self-loading cargo?

What would that do to dwell times at commuter stations?

[ruggedpeak]

4 minutes ago, jjb1970 said:

More airlines seem to be fitting three point seat belts in business class at least. Personally I like the reverse herringbone configuration because in most likely impact scenarios the seat would absorb the impact forces rather than a belt.

All the seats in RAF passenger aircraft face rearwards for safety (as per adb's experience) but the passengers are not paying for the ride and have to do as they are told without question. Flying backwards is not conducive to relaxing.

[Michael Hodgson]

12 minutes ago, rodent279 said:

Hmmm.......a train full of MPs.....faulty doors........photo opportunities......I sincerely hope nothing goes wrong there.......

could save the taxpayer the cost of a general election?

[ruggedpeak]

Just now, Michael Hodgson said:

 

Ah, but would they still be self-loading cargo?

What would that do to dwell times at commuter stations?

a few practical issues to sort out, perhaps slide into the cocoon and then some robotised stacking system on platform. The concourse can become a sorting area bit like airport baggage handling system. Could reduce injuries/deaths in a train crash but might have to concede some loss through robot malfunction etc.

[Michael Hodgson]

2 minutes ago, ruggedpeak said:

Flying backwards is not conducive to relaxing.

 

Not even the RAF has many aircraft that can do that!

It was one thing to tell WW2 pilots to eat carrots so they could see in the dark, now they've got to have eyes in the back of their heads!

[adb968008]

11 minutes ago, ruggedpeak said:

All the seats in RAF passenger aircraft face rearwards for safety (as per adb's experience) but the passengers are not paying for the ride and have to do as they are told without question. Flying backwards is not conducive to relaxing.

Southwest airlines 737s used to do this on row 1.

its quite a different take off experience, plus playing footsie with those in row 2 facing you.

 

On a separate note but MDs also give throwing forward sensation on landing, as the reverse thrust is on the engines mounted at the rear of the fuselage… Tupolevs would also give you a bit of a thrill…

 

Edited April 9 by adb968008

[jjb1970]

4 minutes ago, ruggedpeak said:

All the seats in RAF passenger aircraft face rearwards for safety (as per adb's experience) but the passengers are not paying for the ride and have to do as they are told without question. Flying backwards is not conducive to relaxing.

 

It depends on the aircraft. They faced backwards in the VC-10 but not the L1011 Tristar. I am not sure about the A330MRTT but standard fit seems to be conventional forward facing seats.

[Michael Hodgson]

3 minutes ago, ruggedpeak said:

a few practical issues to sort out, perhaps slide into the cocoon and then some robotised stacking system on platform.

The Royal Navy has already developed that technique ....

 

[jjb1970]

I have never found any issues facing backwards when flying. Quite a a few airlines have some rear facing seats and reverse herringbone is reasonably widely used (or was).

[Stevebr]

12 hours ago, rodent279 said:

I think that if you did survive, you'd be lucky to get away without life changing injuries. A mk2 or 3 would have fared better.

I think it's true that a Mk2 or Mk3 would have done better but the deceleration from 90 mph to 0mph in around 125 feet would have been > 2g average and 5g peak which would have thrown passengers around Mk2 and Mk3 vehicles would have been pretty awful as well.  (Emergency braking is around 0.09g)

[adb968008]

8 minutes ago, jjb1970 said:

I have never found any issues facing backwards when flying. Quite a a few airlines have some rear facing seats and reverse herringbone is reasonably widely used (or was).

I like Herringbone on ANZ…

 

Enjoyed an electric candle lit dinner, face to face with my other half on a flight to Auckland like that… then sat at the bar afterwards at 40k ft for a cocktail.

 

Afterwards, I returned to my seat, loosely fastened my lap belt, as I never fly with it unbuckled…life experience as the unexpected has a habit of being unexpected, even lying down on a plane.. the lapbelt is loosely fastened.

 

Edited April 9 by adb968008

[ruggedpeak]

3 minutes ago, jjb1970 said:

 

It depends on the aircraft. They faced backwards in the VC-10 but not the L1011 Tristar. I am not sure about the A330MRTT but standard fit seems to be conventional forward facing seats.

It was a very long time ago, I was in an RAF Tristar with rear facing seats, but don't recall the details. Looks like it was an earlier version to the L1011, so stand corrected. Didn't like it though, preferred a seat with a rocket attached to it!

[H2O]

1 hour ago, rodent279 said:

Hmmm.......a train full of MPs.....faulty doors........photo opportunities......I sincerely hope nothing goes wrong there.......

Already tried this in 1830^.  It didn't end well.  If only they'd had central door locking Huskisson may have seen the day out...

 

https://en.m.wikipedia.org/wiki/Opening_of_the_Liverpool_and_Manchester_Railway

 

^ OK no photo opportunities, Fox Talbot's invention was about 10 years later.

Edited April 9 by H2O
Added link.

[Jeremy Cumberland]

37 minutes ago, ruggedpeak said:

Would a press junket in a train that does not meet current passenger safety requirements be allowed under a competent risk assessment?

An interesting question. I was looking at things merely from the regulatory point of view. I wonder what other train operators have done, whether they have modified their support coaches in the same way as their passenger coaches, even though this is not needed to comply with the law.

[adb968008]

47 minutes ago, Stevebr said:

I think it's true that a Mk2 or Mk3 would have done better but the deceleration from 90 mph to 0mph in around 125 feet would have been > 2g average and 5g peak which would have thrown passengers around Mk2 and Mk3 vehicles would have been pretty awful as well.  (Emergency braking is around 0.09g)

I was thrown from a seat at c90mph in around c500metres+ (google maps puts it at 380m  from impact to stop), but we felt the brake / horn before the impact… that was enough to see standing passengers fly past me like ghosts floating down the landing, lots of colourful language, and kids fall off seats and big ones like me lift up, bags on floor, spilled drinks etc. Sadly the truck driver lost his life.

 

i posted details of it, with pictures here…

 

Fortunately everyone got themselves back on their feet, but to experience it was a bit more surprising as it was much more than I ever expected, especially as the inertia takes time for the train to slow down…thats what moved me ultimately as there was no recoil...once I was moving there was nothing pushing me back, In a car emergency stop, you jerk forwards, recoil and its over quite fast… i can only guess  what a high impact crash would be like.

 

By comparison, I have experienced a flying scotsman style buffering up at a preserved railway, and simply had the shove.., which just puts you a foot or two down the corridor from where you were previously standing, but your still standing, then laughing.

 

 

 

 

 

 

Edited April 9 by adb968008

[ruggedpeak]

42 minutes ago, Jeremy Cumberland said:

An interesting question. I was looking at things merely from the regulatory point of view. I wonder what other train operators have done, whether they have modified their support coaches in the same way as their passenger coaches, even though this is not needed to comply with the law.

Yes, perhaps someone experienced in railway PR work can advise.

 

In relation to your regulation question, the regs you previously linked to https://www.orr.gov.uk/sites/default/files/2023-03/rsr-1999-guide-to-operation-of-mark-one-type-and-hinged-door-rolling-stock.pdf are clear IMHO under this section:

 

What is meant by ‘a person operating a train or rolling stock’?

1.8 Regulation 2(3) makes it clear that regulations 3 and 4 apply to persons who
operate trains or rolling stock in the course of a business or other undertaking,
whether or not for profit. This definition includes a company and in this document
the term ‘train operator’ is used to describe someone with obligations under
regulation 2(3).

1.9 The regulation includes operations which are run on a voluntary basis, where there
is no employment or self-employment and it also makes it clear that a self-employed
train driver is not an 'operator'

 

This means the regs apply to anyone operating a train or rolling stock' (i.e. WCRC),  'whether or not for profit' and where there is 'no employment or self-employment'. WCRC Mk1's full of journos is a train comprising rolling stock, being operated for profit or not (you can debate the profit issue either way, PR stunts are to generate profits ultimately, but the issue is irrelevant here since the regs apply irrespective of whether there is a profit motive). So my reading is that to operate Mk1 stock for a PR junket requires full regulatory compliance, so either Mk1's have CDL or an exemption in order to be used for a press trip. There is no leeway under the regs from CDL if someone is using Mk1's as 'rolling stock', which stuffing them full of journos is. If I have missed another clause that provides an exemption do let me know!

 

More interesting is this bit at the end (page 11 & 12) which clarifies the position very clearly for those who think WCRC are being hard done by:

 

4.5 ORR expects any such application to demonstrate the requirements set out in ORR document (Railway Safety Regulations 1999, Assessment and Guidance Manual for
Exemption Applications3) are met by either:

(a) Setting out how the means of controlling risks associated with the operation of hinged doors other than the use of CDL as required under regulation 5:

I. are in line with the hierarchy of controls within the Management of Health and Safety at Work Regulations 1999;

II. provide an alternative engineering solution not relying on individual human action to lock each door, that ensures doors are secondarily locked in position at all times the carriage is in the course of its journey;

and

III. is supported by a quantified risk assessment to demonstrate as a
minimum, equivalence to CDL as a means of risk control;

or:

where fitment of a form of CDL to rolling stock with hinged doors is not achievable by the 31 March 2023 date; that a time bound programme of work is in hand for such fitment.
In such cases a limited period of exemption may be considered to allow the programme to be completed, so long as other methods of secondary door locking are in place and being operated effectively in the meantime.

 

Anyone who has read the various documents and utterances from WCRC and MP's will be aware of how WCRC has not entirely achieved the requirements clearly set out by the ORR and why therefore ORR would be in breach of its own guidance and policy to issue exemptions. We don't need to revisit those.

If people want to disagree with ORR guidance documents, based upon statutory regulations, that is probably best done somewhere else by those with the necessary expertise and competence. There are very few on here who have those pre-requisites. It is irrelevant to the main issue of operating a compliant train service. It is just a distraction and howling at the moon.

 

The critical issue is that WCRC have not complied with the documented requirements of the ORR and rather than do this they are trying various routes to not do so. CDL has been known about for 18 years, this guidance was issued in 2021. CDL is affordable and it is technically feasible, a Judge has confirmed so as has the real world experience of other operators.

 

 

Edited April 9 by ruggedpeak

[Reorte]

1 hour ago, ruggedpeak said:

... or replace the seats with rollercoaster style seating and restraint systems, would improve things dramatically......

That sounds suitable for some of the track on my local line:

[APOLLO]

Be careful what you wish for.

 

 

Brit15

 

 

[rodent279]

3 hours ago, Jeremy Cumberland said:

None is needed for it, as I posted earlier, not unless their majesties pay for their tickets:

 

Yes they do. I think we are all agreed that Mk1s were a vast improvement over much of the coaching stock that came before, but now, in the 2020s, they fall quite some way behind current expectations of crashworthiness. There are plenty of accident reports where fatalities occurred because of the inability of Mk1 stock to withstand impact.

 

RSR99 Regulation 4 bans Mk1 coaches from main line passenger use. Exemptions have been granted where coaches have been modified to improve crashworthiness. ORR carried out further consultation in 2020, following which it published a new guidance document (https://www.orr.gov.uk/sites/default/files/2023-03/rsr-1999-guide-to-operation-of-mark-one-type-and-hinged-door-rolling-stock.pdf). This broadly states that ORR will continue to issue Regulation 4 exemptions for use of Mk1 rolling stock where modifications have been made to improve crashworthiness, but that after March 2023 it proposed issuing Regulation 5 exemptions for central door locking "only in exceptional circumstances".

I stand corrected then. I was under the impression that the dispute between WCRC & ORR was purely about CDL.

 

Does this mean that:-

1-even if a fully compliant CDL system is fitted, there is no guarantee that WCRC can continue to use Mk1's?

2-Are ORR placing other requirements on WCRC in respect of crash worthiness improvements before granting continued exemption to run Mk1's?

Edited April 9 by rodent279