Risk Assessment and Safe Integration May 2020
Risk Assessment and Safe Integration May 2020
402/2013)
for Fixed Installations and for their Safe Integration
Regulation
R&R CSM AB 2015/1136
CSM DT
Regulation [10-9 & 10-7 h-1]
RAC-TS [10-9 h-1] 402/2013
… to be used in combination with
Regulation
Regulation 1078/2012 on
352/2009
CSM for monitoring
(+ 2 existing More categories
applicable since 7th June 2013
Guides) of RAC-TS
Use of Regulation 402/2013 for fixed installations and for
their Safe integration, ANSF Workshop, 29 May 2020 Slide n° 4
Associated guides for application of CSM for risk assessment
Complementarities between Guides and Standards
Regulation 402/2013 on Reg. 2015/1136 on
WHAT shall
be done? CSM for risk assessment CSM Design Targets
(repeals Regulation 352/2009) (CSM DT)
Existing material
HOW to Application Guide on Reg. Explanatory Note
Roles & Resp. CSM Application Guide
comply with 352/2009 on CSM for
CSM? Assessment Body on CSM DT
risk assessment
Translated in all EU Languages
Examples on Collection of Examples of
HOW to apply risk assessment and Some
the CSM possible supporting tools
Safety Directive 2016/798 – Changes must also be safe (not only interoperable)
Sole compliance with TSIs does not ensure safety is fully covered. TSIs contain es-
sential requirements related to safety that are necessary to reach interoperability
4) Safe integration has a broader meaning and goes beyond single checks above
applies at different levels and to entire life cycle of design, operation, mainte-
nance and disposal/decommissioning of railway system and of its components
5) Consequences: different ways of demonstrating safe integration, in particular
different levels of completeness of safety demonstration result unavoidably in
difficulties to mutually recognise the results of safe integration across the EU
without requesting additional risk assessments and additional checks
Use of Regulation 402/2013 for fixed installations and for
their Safe integration, ANSF Workshop, 29 May 2020 Slide n° 10
Agency clarification note on safe integration
(available on the website) – Purposes of the document
1) Provide a common understanding of the concept of safe integration
2) Identify levels where safe integration is necessary in architecture of railways
3) Explain how to demonstrate safe integration with application of a systematic system
based and top-down approach structured around Regulation 402/2013
4) Lay down the basis for mutual recognition of demonstration of safe integration
5) Highlight big challenges and usual difficulties to overcome for a proper top-down risk
assessment, risk management and safe integration
6) Summarise in one document requirements from different European legal texts:
a) Main roles & responsibilities of RUs & IMs in top-down system engineering (system
requirement specification and allocation of relevant ones to suppliers & contractors)
b) Bottom-up process at levels of sub-system and service suppliers
c) Emphasise necessity for cooperation between RUs, IMs and all other actors who can
impact safe design, operation and maintenance of railway system
d) Roles of independent safety assessment by AsBos at all levels of architecture
7) Threats to a systematic & top-down approach to a systematic preventive risk
identification, risk control and risk management
Use of Regulation 402/2013 for fixed installations and for
their Safe integration, ANSF Workshop, 29 May 2020 Slide n° 11
Safe Integration takes place at every level of the Railway System
whenever a change is made somewhere
So, usually one single actor was in charge of safe design, implementation, authorisation
and safe management of railway operation, infrastructure and traffic management and
all maintenance activities (vehicles and network) it had the full knowledge and
responsibility for proper control of all railway risks
2) Now, after market opening: former integrated railway companies, and associated
responsibilities, are split into new railway actors: NSAs (usually safety authorisation
department of former state railway company), IM(s), RUs, ECMs, manufacturers, service
providers, contracting entities, etc.
Responsibility for safe operation and traffic management of former railway system, and
proper control of associated risks, does not rest any more on a single railway actor.
IM and all RUs operating on its network share, each one for its part of the system, the
responsibility of former integrated state railway company
Use of Regulation 402/2013 for fixed installations and for
their Safe integration, ANSF Workshop, 29 May 2020 Slide n° 14
Architecture of the Railway System
Responsibilities for Safe Integration
Concepts from
Figure 1 of
CENELEC
50126-2:2017
&
Figure A.2 of
CENELEC
50129-2:2018
At level of every
SUB-SYSTEM
SRACs
SRACs
SRACs
At level of every Sub-System (i.e. sub-contractor)
Sub-System Risk Assessment (jointly with
other sub-contractors for shared risks) To SYSTEM &
other sub-syst.
Requirements allocated to sub- To SYSTEM &
system from the SYSTEM level other sub-syst.
Requirements imported from other Safety Requirements To SYSTEM &
actors through shared interfaces for SUB-SYSTEM other sub-syst.
Internal requirements from own
sub-system risk assessment From From
Requirements exported to SYSTEM From other Internal
(SRACs) and to other sub-systems Proposer actors Risk
(/actors) through shared interfaces INTERFACES Analyses
Sub-System AsBo
Use of Regulation 402/2013 for fixed installations and for
their Safe integration, ANSF Workshop, 29 May 2020 Slide n° 17
Essential responsibility of IMs and RUs at the
level of the Railway System risk assessment and risk management
System risk assessment must take care of human operators & actions to identify:
1) the operational risks and the associated requirements for training;
2) the risks associated with the maintenance of the railway system and the
requirements for diagnostic functions and training of the maintenance staff;
3) in case of a stepwise migration from an existing system, depending on whether:
a) the new system replaces the existing one;
b) the new system is superimposed to the existing one;
c) the new system modifies the existing one;
identify the temporary risks that could arise during every migration step and the
necessary risk control measures such as any necessary design solution to handle
safely the transition, training requirements or specific protection measures
4) temporary risks must not be neglected; they can exist during weeks, months or
years until the next step of the migration is reached. They are usually different from
risks of the final system put into service once the migration is complete.
5) Usually, suppliers cannot identify and manage alone those risks without a
structured and top-down system approach under the RU/IM responsibility
Use of Regulation 402/2013 for fixed installations and for
their Safe integration, ANSF Workshop, 29 May 2020 Slide n° 18
Threats to a systematic top-down approach
where RUs & IMs are not capable to fulfil their Proposer’s role
Typical examples of changes not driven by an RU/IM, where a systematic and top-
down approach to SYSTEM risk identification and management is usually lacking
1) Financial consortium, or regional public authority, purchasing a fleet of vehicles or
trains without consulting/involving future operators (RUs/IMs)
2) Regional public authority, or Ministry, purchasing to a contractor construction of a
new, or extension of an existing, (regional) railway line without involving IM
To manage properly such changes, and improve proactive hazard identification and
preventive risk control, it is essential for the “Procurement Entity” either to:
3) apply itself a top-down and system-based approach right from tender stage &
beginning of project, involving future operators (RUs) and traffic manager (IM), or
4) sub-contract to future operators (RUs) & traffic manager (IM), proper management
of project, including proactive risk assessment and management with manufacturer
That permits to systematically identify early in project potential risks and to control
those risks through technical improvements of design instead of obliging the future
users to implement afterwards constraining operational and maintenance SRACs
Use of Regulation 402/2013 for fixed installations and for
their Safe integration, ANSF Workshop, 29 May 2020 Slide n° 19
Structuring of Development, Verification,
Validation and independent Conformity
Assessments activities
between the Proposer, NoBo, DeBo & AsBo
Regulation 402/2013
(CSM RA) ≡ EU law
(when making changes)
Independent
Conformity AsBo
Assessment
Compliance
is mandatory
BUT
Application of CSM RA shall
not lead to requirements
contrary to a TSI
otherwise
TSIs need to be revised or
MS shall ask for a derogation
DeBo
AsBo
National
TSIs Rules
CSM RA all risks identified and controlled
to an acceptable level
(Proposer’s Declaration – Art. 16)
demonstration of compliance
Applicant’s declaration of
Article 16 of the CSM RA;
( ) There is no NSA
Applicant’s “EC” Declaration *Authorisation
(* )
Agency checks (*) NSA Authorisation
ERTMS trackside for
interop compliance of verification of sub-system placing on market for placing in service
Technical compatibility and safe Technical compatibility and safe integration of Operation
Maintenance
integration within the vehicle vehicle in train composition and within the Route according to
according to
ECM System of
(Use of CSM for RA) (Use of CSM for RA) RU SMS
Maintenance
Conformity Conformity RA according Conformity with Conformity SMS update accor-
with TSI(s) with NNR to CSM RA infrastructure with NNR ding to CSM for RA Supervision Surveillance by
register (RINF) by NSA ECM Cert Body
Check by CSM
Check by Check by Assessment Check by Check by CSM
NoBo DeBo Body Check by NoBo DeBo Assessment Body Supervision by NSA [Art 16(2)(f)]
SRACs
SRACs
SRACs
At level of every Sub-System (i.e. sub-contractor)
Sub-System Risk Assessment (jointly with
other sub-contractors for shared risks) To SYSTEM &
other sub-syst.
Requirements allocated to sub- To SYSTEM &
system from the SYSTEM level other sub-syst.
Requirements imported from other Safety Requirements To SYSTEM &
actors through shared interfaces for SUB-SYSTEM other sub-syst.
Internal requirements from own
sub-system risk assessment From From
Requirements exported to SYSTEM From other Internal
(SRACs) and to other sub-systems Proposer actors Risk
(/actors) through shared interfaces INTERFACES Analyses
Sub-System AsBo
Use of Regulation 402/2013 for fixed installations and for
their Safe integration, ANSF Workshop, 29 May 2020 Slide n° 32
Example of a project
Maintenance
IXL&RBC Specific Application Safety
Existing products on the market: Cases & Sub-System Risk Assessments
RBC
IXL Generic Product Safety
Interlocking, Track Circuits, Axle Case & Risk Assessment
Counters
RBC Generic Product Safety
etc.
Case & Risk Assessment
Use of Regulation 402/2013 for fixed installations and for
their Safe integration, ANSF Workshop, 29 May 2020 Slide n° 33
CSM Assessment Bodies (AsBo) and
Independent Safety Assessment
System Architecture Independent assessment
System: new line to be fitted
with ERTMS – Structural and
functional sub-systems: Whole System
Risk Assessment (including
Energy sub-system requirement
SYSTEM Infrastructure specification)
AsBo Traffic operation management &
Maintenance Safe Integration
Trackside CCS matters
Sub-System reqmnt allocation
RBC Sub-
IXL Sub-aSBo
System Interlocking + RBC (Level 2) Specific Application Safety
System AsBo parametrisation (configuration) Cases & Risk Assessments