Top Major Non-Conformances Highlighted Across CORE, Sentinel, and SWP
One such trend is with suppliers increasing their service offerings to the railway industry, which naturally requires further auditing across our modules to remove risk creeping into the railway environment.
Back in March 2023, we reported on the top major non-conformance areas within CDM during 2022, which coincided with our ‘Health and Safety on and Around the Tracks” Webinar featuring Scheme Manager Phil Smith and guests from Network Rail.
In this blog post we will delve into the major non-conformance areas during 2022 and provide an explanation for the reason they are ‘top of the league’. We will be covering this in more detail during our webinar – Staying Compliant in Changing World.
Top Line Summary – Major Non-Conformance in 2022
On average, there are approximately 420 suppliers each period that are not compliant, which means that they are not visible as part of that expression of interest within the RISQS portal. The RISQS team are continually reaching out to liaise with suppliers to keep their information up to date so that they remain visible to buyers.
Regarding risk, we have noted 389 major non-conformances were raised last year and that was spread across 154 organizations, which means that, we have prevented 154 organizations importing risk that could result in serious risk to the infrastructure individuals and the industry.
We will now delve into the top major non-conformance within Core, Sentinel, and Safe Work Planning modules.
Top Major non-conformance within CORE
- 8:0 - Monitoring
- 2:2 - Management of Legal and Other Requirements
- 7.3 - Alcohol and Drugs
8:0 Monitoring and Measuring is still the biggest risk caused by suppliers who are not closing out the minor conformances raised in previous audits. These minors have the potential to become majors in the future, and those suppliers that usually fail on this are those that treat this audit as a tick box.
The key lesson here is for suppliers to avoid this non-conformance is by treating their management systems as a living, breathing system that is used daily to support their activities.
It is a similar theme with the next major non-conformance 2:2 - Management of Legal and Other Requirements. Broadly speaking, suppliers are not keeping their legal documents, standards, and processes up to date.
We have noted there have been some major changes to fatigue, standard drug, and alcohol standard safe work planning, so the RISQS team are expecting suppliers to review their documents and make the required management system changes.
The 3rd major non-conformance within 7.3 - Alcohol and Drugs, where this is a growing concern for the RISQS team as the required testing limit is now increasing from 5% to 20%. Our findings note suppliers are not properly accounting for all staff when it comes to the testing percentage.
Alcohol and drugs have also been seen as a top-ranking major non-conformance within the Sentinel module.
Major Non-Conformance within Sentinel
- 2 - Contracts of Sponsorship
- 4 - Drug and Alcohol
The key concerns within the Sentinel module centre on gaps appearing within the required management of employees.
Our auditing data reveals suppliers are receiving major non-conformance due to either the correct contracts of sponsorship are not in place and/or the appropriate annual reviews are not taking place.
We need to make sure our workers are in a good place to perform the job competently and safely. In some cases, we have had pushback from suppliers who tell us they have hundreds of sponsored individuals, and it is impossible to meet with everyone once a year. In this situation, the supplier needs to expand the management team to ensure these annual reviews are taking place.
Auditors are examining 8, 10, and 12-hour timesheets, but these do not account for the following contributing activity:
- Travel to the site (including both as a driver and passenger)
- Intensity of work onsite
- Change from nightshift to dayshift (and vice-versa).
These factors do increase fatigue for safety critical employees, and we are expecting suppliers to be mindful of this when it comes to managing their team’s wellbeing.
Major Non-Conformance within SWP (Safe Work Packs)
- 3 Document Control
- 2 Monitoring Safe Work Packs
- 2 Ongoing Competence Arrangements
The top major non-conformances within Safe Work Planning have identified suppliers are importing risk onto sites through outdated and incomplete documents.
RISQS cannot stress the importance for suppliers to ensure their SWP documents are relevant to the site they are working on.
We have seen instances where work packs are being recycled from one job to the next. This may ‘save’ on costs at the time, but the working environment has changed. When we get safe work planning wrong, it does result in fatalities.
Our team do appreciate time pressures occur when jobs are secured at the last-minute, however due diligence is still required to ensure everyone goes home at the end of their shift.
Key takeaways from our findings:
There is unnecessary risk being imported into the railway working environment that can lead to near-misses, incidents, and fatalities.
We would therefore encourage suppliers to take on-board our key takeaways:
- Invest in use of your management systems, make sure you have the right knowledge and skills in your organisation
- Increase engagement with employees – build the behaviours and culture needed to be a safe company
- Remember to review your responsibilities
Phil Smith, Scheme Manager, provided the following comment:
“We want to stress that the auditing process and subsequent findings need to be viewed in a constructive manner with an opportunity to improve business practice. It is incumbent on everyone to ensure our colleagues go home to their loved ones at the end of their shift. Our communications to industry, attendance at events, and our webinar series will provide regular insights as we approach CP7.”
If you have any questions, please contact the RISQS team via email firstname.lastname@example.org