Top 3 Major Non-Conformance Areas CORE Module in 2022

External audits in the railway industry are important because they provide an objective and unbiased assessment of operations, procedures, and management systems. The RISQS auditing team will highlight areas of non-conformance and potential risks within the supply chain operations, providing valuable insight for suppliers, buyers and standard setters at RSSB and Network Rail to improve safety, efficiency, and overall safety performance.

By conducting regular audits, the railway industry supply chain will continue to maintain and improve standards, meet regulatory requirements, and provide a safe and reliable service to their customers.

The RISQS team monitor major and minor non-conformance trends within the railway industry supply chain every period. This provides valuable insights and intelligence where non-conformance arises, and the remedial action required by the supply chain to improve safety performance.

This insight has revealed there are 3 major non-conformance issues that regularly lead to suppliers failing their CORE module audit. These are as follows:

1st Major Non-Conformance: In section 8 - Monitoring

The most common major non-conformance within the CORE module is currently 8:0 – monitoring.

The data we’ve collated from auditor reports demonstrates that within module 8:0 – monitoring, railway industry suppliers are failing to effectively monitor their safety performance according to the requirements specified within the module.

The key trend is a failure to close-out minor non-conformance from previous audits (hence leading to a major non-conformance).

In other words, businesses are recognising there is a minor non-conformance, but corrective action has not been implemented to fix the issues logged in a previous audit.

2nd Major Non-Conformance: 2:2 - Management of Legal and Other Requirements

The second major CORE non-conformance covers module 2:2 – Management of Legal and Other Requirements.

This module refers to how organisations access legislation (including but not limited to safety, health and environmental, GDPR etc) and standards applicable to the rail sector appropriate to the scope of services provided.

Our findings have revealed that businesses are failing to provide evidence during the auditing process that key pieces of legislation have been documented within their normative documents log, and/or there is a failure to demonstrate a documented process to manage applicable standards (including Network Rail and other railway industry standards).

Auditor reports are therefore identifying businesses are at risk of work practices being carried out in a manner which may not be compliant of critical legislation or safety standards revision that have come into force.

3rd Major Non-Conformance: 7.3 - Alcohol and Drugs

The 3rd major non-conformance within the CORE module is 7.3 – Alcohol and Drugs.
This module requires all railway industry suppliers to demonstrate they carry out an unannounced 5% alcohol and drugs test on their in-scope employees during a specified period.

Businesses are failing to comply with this module because they are unable to provide evidence during the audit that the minimum 5% random testing level has been achieved.
The updated Network Rail Drugs and Alcohol standard (NR/L2/OHS/00120), which was published on 3 September 2022, will see an increase from 5% to 20% of all in scope employees and sub-contractors to be randomly selected for a D&A test each year.

The standard will also see the drugs Ketamine and Tramadol added to the substance testing panel, while Propoxyphene has been removed. For more information please visit Network Rail’s dedicated website page.

You can read about the work RISQS have been conducting in this area via this blog post - 'How RISQS helps suppliers to be at the forefront of new health and safety techniques in practical ways'.

When you are audited against this new standard, we will be looking to validate that your processes will achieve 20% of employees within the period, which can then be verified at a subsequent audit. Entities that can demonstrate that they have sufficient competence, capacity, and capability to deliver 20% and are already on a trajectory to do so will achieve a positive outcome.

What To Do Next?

Any supplier that has a major non-conformance is provided with a specified period to demonstrate compliance by revising or changing their processes. A re-audit is then scheduled within a 12-week period to ensure the processes have been embedded within the business.

There are some exceptions outlined in Scheme Rules 4.14.5. The following* are exempt from the 12-week re-audit requirement due to frequency of the requirement:

• Random D&A not undertaken
• No Contract for cause in place
• No Contract for HSE advice in place
• Policies reviewed

*in the above instances businesses will be informed of the next steps.

Audits are delivered for the purpose of creating a safer railway working environment for everyone. It’s in the interests of the entire railway supply chain for an audit to be examined in-depth and action taken to close off minor non-conformance in the first instance, before ensuring the business working practice conforms to the CORE module requirements.

The team have noticed a ‘rapid climber’ being Safe Work Planning – we are looking into what is happening initial insights are around the content of packs not covering the actual works and being far too generic in scope.

The RISQS team are busy analysing non-conformance trends that exist across the supplier chain. Further updates will be provided in due course.