An irrational ORR must be challenged

Scottish electrification: in preparation for the introduction of Class 385 EMUs, various stations between Edinburgh and Glasgow via Falkirk High have had their platforms lengthened. Linlithgow is one of them: No 170477 calls on 1 July 2017 with the 11.28 from Dunblane to Edinburgh Waverley, with recentlyinstalled wires evident. Ian Lothian

You can always rely on the Railway Division of the Institution of Mechanical Engineers to get the timing spot on when it comes to organising conferences. And the events team pulled it off again on 6 June with its electrification seminar.

Of course, running a seminar is one thing, getting together a panel of authoritative speakers is another. And despite the Department for Transport having to pull its contribution because of pre-election purdah, the presentations were topical and challenging, in the true sense of the word.

‘Challenging’ was perhaps too mild a description for the opening paper. ‘The cost of electrification – adequate or perfect’, by British Rail electrification veteran Peter Dearman was more a call to the barricades. Mr Dearman was Network Rail’s Head of Network Electrification in 2011 when the Great Western Electrification Programme (GWEP) was in its infancy.

In an interview at the time he said ‘For the Great Western scheme, the overhead line system will be new. It will be new for a number of reasons. One is that over the years we’ve learnt quite a lot from the equipment that we’ve got and we know some of the reliability issues that it throws up.

‘And it would be foolhardy to build more of the same when we know that we can improve on some of these reliability issues.’

He was also an early advocate of the High Output Plant System (HOPS), describing it as having ‘massive implications’ for productivity. ‘I anticipate that as we move forward into full production and once the guys on the train become familiar with all the kit, we should be getting two wire runs a night…at tension’, he prophesied.

Peter Dearman’s last role at Network Rail was Head of Energy, responsible for defining the engineering content and strategic development of the network electrification programme. But in 2013, like so many other experienced engineers, he left for the world of railway consultancy and is now advising Bechtel on… GWEP.


Along the way he has had a Pauline conversion, and as the title of his paper indicated, has become the apostle of the adequate – the philosophy he followed in his BR years, culminating in the East Coast main line. For example, in an aside he pointed out that the tension struts on the GWEP overhead line equipment (OHLE) masts have a similar cross-section to the OHLE masts used on the original Great Eastern Shenfield electrification!

However, his primary concern was the change in the regulations applying to electrical clearances – covered in detail in the December 2016 ‘Informed Sources’. Most of the change in the UK has been driven by the Office of Rail & Road’s interpretation of the relevant European Technical Specification for Interoperability. In Peter Dearman’s view, not only are the TSI numbers derived from Continental European loading gauges, the TSI is ‘dominated’ by the thinking around the new-build high-speed networks.

As a result, ‘blind adoption of those clearances is at best irrational’. I do like that ‘at best’.

Obviously increased clearances will be safer. But Mr Dearman argues that it is a ‘grotesque over-simplification to conclude automatically that the increased safety is significant or economically justified’. At which point it is worth noting that the transfer of Her Majesty’s Railway Inspectorate to the Office of Rail & Road was intended to bring economic and safety regulation together.


‘We are sleep walking towards nailing down the coffin lid on rail electrification. Unless we actively and passionately address cost reduction that will be the result.’ - Peter Dearman, 6 June 2017


At the heart of the clearance issue is the increase in the minimum distance between the platform and the live equipment from 2.75m to 3.5m. But, as Mr Dearman pointed out, in the 60 years during which the standard UK clearance has been 2.75m, an estimated 15 billion passengers have used the stations on the electrified network without a recorded incident involving electric shock.

This record is reflected in the Rail Safety & Standards Board’s (RSSB) safety risk model, which concludes that the passenger risk of 25kV electric shock fatality at a station is once every 300 years. Put another way, this represents 0.008% of all risks to passengers.

ORR’s insistence on 3.5m clearances is increasing cost and ‘diminishing the case for electrification’. In addition, ‘money spent on this is obviously then not available to address risks of much more significance’, Mr Dearman pointed out.


As the grey-haired veteran left the podium a much younger electrification engineer took his place. But the message remained unchanged.

For Network Rail’s Professional Head of Contact Systems, Philip Doughty, the top challenge in achieving cost-effective electrification was legislation and the application of the Energy TSI in the form of electrical clearances and separation at public locations. These changes, in conjunction with ORR’s greater focus on the application of Regulation 7 of the electricity at work regulations (EAWR), have ‘resulted in confusion across the industry which in turn has led to cost escalation and delay for new electrification schemes’.

Note the reference to Regulation 7 of the EAWR. I’ve republished it here and when you have read it you will understand Philip Doughty’s aside, ‘We have had many debates with ORR on what Regulation 7 means’.


Mr Doughty, who is at the sharp end of the clearances debate, added a further complication, pointing out that when a train is standing at a platform, the reference points for standing clearances move from the contact wire to the pantograph horns. ORR has already suggested that train suppliers and operators should work with Network Rail on a ‘whole industry’ solution to this risk.

So, even with a clearance to the contact wire of 3.5m or more, a risk assessment could still be required to allow for the reduced clearance to the pantograph. Rolling stock design already includes minimum clearances between the live parts of the pantograph and the vehicle body and speakers from the floor were unhappy at this suggestion that platform clearances could be added to these requirements.

Philip Doughty was unrepentant. ‘The rolling stock community is about to feel our pain’ he replied.


Network Rail has produced a new standard covering electrical clearances at public areas (NR/L2/ ELP/27715). This covers ‘reasonably foreseeable’ system level hazards and operating conditions, specifies the process for measuring the clearances and provides a method for clearance assessment, including when and where location-specific assessment is required.


‘We would like to reiterate very clearly that the ORR view is not that the highest possible standard be met irrespective of cost. We will consider risk assessments of difficult cases on their merits.’

Ian Prosser, HM Chief Inspector of Railways, 5 April 2016

This raises the question of how you define what constitutes a ‘reasonably foreseeable hazard’. Network Rail is meeting with ORR in pursuit of a ruling.

Meanwhile, following publication of the new standard, colleagues have been sending Philip Doughty photographs of people potentially at risk on platforms. One photograph showed a man carrying a 9ft curtain pole. ‘Reasonably foreseeable or stupidity?’ Mr Doughty asked.


In retrospect, the opportunity to challenge ORR’s approach to the 3.5m clearance standard was missed with the Edinburgh Glasgow Improvement Programme (EGIP), which had already started when the new specification came into force. Network Rail attempted to keep costs down by seeking derogations based on risk assessments. However, the ScotRail Alliance concluded that continuing this argument would have delayed the programme with no certainty that ORR would sign off completed work.

So in March 2016, then Chief Executive Phil Verster instructed the EGIP Project team ‘Stop the debate and move to the new standard. The railway will have hundreds of years of life into the future, so fix this now’. In retrospect, that was a mistake and the pass was sold.

To date, ORR has taken a firm line on the justification for risk assessments where 3.5m clearances cannot be provided economically. Philip Doughty believes this attitude may be changing, arguing that the cost of any intervention must be proportionate to the risk.

That may be so, but I believe the only way to bring common sense to this issue is to take on ORR with a high profile test case. There are a couple of bridges on upcoming Scottish electrification schemes where 2.75m can be provided but 3.5m requires a highly disruptive rebuild, with massive inconvenience to the local population. Time to make a stand.



7. All conductors in a system which may give rise to danger shall either:

a) Be suitably covered with insulating material and as necessary protected so as to prevent as far as is reasonably practicable danger; or

b) Have such precautions taken in respect of them (including, where appropriate, their being suitably placed) as will prevent, so far as is reasonably practicable, danger.

Adequate or perfect? Installing overhead cables between Didcot and Reading in June last year.