Top 3 Major Non-Conformance Areas CORE Module in 2022
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 three major non-conformance issues that regularly lead to suppliers failing their CORE module audit. These are as follows:
First 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.
Second 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.
We found that during the audit businesses are failing to provide evidence that key pieces of legislation have been documented within their normative documents log. Additionally, there may be a failure to demonstrate a documented process to manage applicable standards (including Network Rail and other railway industry standards).
Therefore, auditor reports are identifying businesses are at risk of practices which may not be compliant of critical legislation or safety standards revision that have come into force.
Third Major Non-Conformance: 7.3 - Alcohol and Drugs
The third major non-conformance within the CORE module is 7.3 – Alcohol and Drugs.
This module requires railway industry suppliers to demonstrate that they perform unannounced 5% drugs and alcohol (D&A) 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), published on 3 September 2022, will see the random testing level increase from 5% to 20% of all in scope employees and sub-contractors 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 web 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 auditing against this new standard, we look to validate that there are processes in place to achieve 20% of employees within the period, and that these can then be verified at a subsequent audit. Entities that can demonstrate 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.