1. Presented by Vaibhav Puri Head of Standards Policy
Autonomous systems, railway regulation and standards – In the pursuit of good questions?
Presented by
Vaibhav Puri
Head of Standards Policy
Feb 2016

2. About RSSB
RSSB is an expert body that delivers programmes of work on behalf of the rail industry across technical functions that cross rail interfaces in the areas of:
Health and Safety
Research
Standards
Sustainability
Through research, the understanding of risk, and analysis, we provide an evidence base to support industry decisions and collaboration.
RSSB’s membership includes infrastructure companies, train/freight operators, rolling stock owners and suppliers. It is non-profit-making and independent of any single interest.

3. Contents 1. The key principles of legal framework
2. The scope of legislation
3. The role of standards
4. Challenges for autonomous systems

4. Infrastructure Manager
Regulatory complexity that confronts a railway company
TSI
ROGS 2006
RIR
2011
MHSWR
1998
CSM-RA
HASAWA
1974
Infrastructure Manager
Project Entity
Proposer
Transport Operator
Railway Undertaking
ASBO
DEBO
NOBO
Change

5. Key fundamentals of the regulatory framework
The law places obligations on legal entities responsible for performing a function in a certain context/scenario
The obligations can be on parties responsible for
Designing, manufacturing and selling assets
Operating and maintaining the assets and performing related functions/activities
For regulating, supervising, enforcing and authorisation/approvals to be able to perform the functions or sell the assets

6. Objectives of legislation governing the railways
Facilitate cross-border train operations
Market opening for rail products and services
Harmonise Technical and Safety requirements
Market opening for rail products and services.
Harmonise approval process for authorisations and certifications + Harmonise Technical and Safety requirements – simply tools to achieve market opening
Facilitate cross-border train operations, only of secondary concern to GB
Harmonise approval process for authorisations and certifications

7. Obligations as a project
Scope of legal responsibilities
NOT railway specific
Duty as
Corporate entity
Example:
Occupiers’
Liabilities
Acts ‘57 & ‘87
Corporate reputation
Duty as
Employer
NOT railway specific
Example:
Health & Safety at Work etc Act 1974
Example: Railway Interoperability
Regulations
2011
Duty as
Transport Operator
Railway specific
Obligations as a project
RGSs
(National Rules)
Welcome to the decision making universe.
It is quite important that we understand where decisions are made in the industry and the different responsibilities that one company can have when considering change

8. Scope of the Legislation
CHALLENGE NO. 1: Does the description and boundaries of subsystems in law hinder progress towards autonomous systems?
Railway Safety Directive 2004/49/EC
Railway Interoperability Directive 2008/57/EC
Railway system
Railway Undertakings part of the system
Infrastructure Maintainers part of the system
Combined Subsystems
Management System, including SMS
Vehicles
Combined Subsystems
Network
Management System, including SMS
Telematics applications
Maintenance
Operations & traffic mgt
Subsystems
Subsystems
Rolling stock
On-board
CCS
On-board energy
Trackside Energy
Trackside CCS
Infrastructure
Subsystems
Operations & traffic mgt
Maintenance
Telematics applications
Subsystems
CCS: All equipment necessary to ensure safety and to command and control movements of trains authorised to travel on the network IC IC
Functional areas
Structural areas
Functional areas

9. What is expected of the rail system?
Railway Safety Directive 2004/49/EC
Railway Interoperability Directive 2008/57/EC
Article 4(1) of the Interoperability Directive states that: The rail system, subsystems and interoperability constituents shall meet the relevant essential requirements.
‘Essential requirements’ means all the conditions set out in Annex III which must be met by the rail system……..
Annex III sets out the Essential Requirements:
CHALLENGE NO. 2: Do the essential requirements hinder an autonomous system performing a function?
The electricity/thermal energy supply systems used must:
Enable trains to achieve the specific performance levels,
In the case of electricity energy supply, be compatible with the collection devices fitted to the trains
Safety
Technical Compatibility
Reliability & Availability
Health
Env. Protection
Accessibility

10. Beyond high level obligations – where do standards sit?
The obligations are given greater granularity via
European target system specifications (TSIs) and State imposed National Rules
…but the above only address obligations to the extent necessary
Additional measures are required to fully meet obligations:
Robust Risk Assessment and Management
Rule Based approaches via standards
Other acceptance principles
Parties have other commercial and business obligations and objectives
CHALLENGE NO. 3: Do the various specifications hinder progress towards autonomous systems?

11. CHALLENGE NO. 4: Specify functions and not who/what does it
ETCS transmits the information in the form of data but the train driver is still the one who controls the speed of the train based on the available information (albeit with ATP supervision)
Currently, the information is codified in the form of signal lights.
ATP removes the train driver but the train driving function is still the same
How the trackside CCS system contributes to the information needed by the train to control its speed

12. The scope and force and standards
EC Regulations inc. CSMs & TSIs
Imposed by law
UK Legislation –
Acts and Regulations
Imposed by licence and law
Railway Group
Standards (RGS)
National Safety Rules
National Technical Rules
SMS or contract
Rail Industry
Standards (RIS)
Company
standards
standards
Project
Legal force
European standards (EN) non-harmonised
European standards (EN) harmonised
Grant ‘presumption of conformity’
Rail Industry Approved
Code of Practice (RACOP)
Voluntary observation
British
Standards (BS)
Guidance Notes (GN)
Guidance
Project
Company
GB Network
European
Scope of Standards

13. The scope and force and standards

14. The scope and force and standards
Essential Requirements in the Railway Interoperability Directive 2008
Mandatory Rules - TSIs and NTRs (RGS)
Standards directly quoted in TSIs
RIS
RACOP
Guidance Notes
BS, EN
Company/Project
Mandatory
Specified in TSIs / NTRs
Voluntary
Applicant chooses own specification
CHALLENGE NO. 5: Standards can be developed which specify characteristics for autonomous to integrate or meet the essential requirements
Company/
Project Standards
Level of detail

15. Functional
Operator/use
Individual system
Human operated
Human assisted
Human delegated
Human Supervised
Mixed initiative
Fully autonomous
Structural
Manufacturer/design
System for systems

16. Approvals/verification focus Coordination/ Integration/ Supervision
Manufacturer/ design
Operator/ use
A system for systems
1 Designers may assume that humans should not be included in systems because they are unreliable and inefficient. But many operating problems come from designer errors.
2 Automated systems are implemented because they can perform better than the operator, yet the operator is expected to monitor their progress.
3 The operator is reduced mostly to monitoring, leading to fatigue and ineffectiveness.
4 In the long term, automation reduces physical and mental skills of workers, yet these skills are still required when automation fails. In fact, the skills may be in more demand than usual when automation fails, because there is likely to be something wrong, requiring, takeover, diagnosis and recovery. De-skilling also affects workers’ attitudes and health adversely.
 So in summary when we are designing these new systems – these are the HF issues we need to grapple with and consider early – it isn’t as simple as saying no humans NO problem – we just move the potential for human error back into the design stage!…..
Structural
Coordination/ Integration/ Supervision
Nature of the system
Functional
Individual system

17. Is there a shift/change in Obligations Functions
Improved understanding of what introduction of an autonomous system does
Is there a shift/change in
Obligations
Functions
Impact in terms of scope or scale
The boundary of the change may be wider than the component or the function
CHALLENGE NO. 6: Understand the system wide impact of autonomous systems

18. Ability to monitor, supervise and intervene
Is our operation sufficiently safe, or do we need to make a change?
We have decided to change something affecting our operation; is the change sufficiently safe?
CHALLENGE NO. 7: Can the party on which obligations are placed in the new railway system made up of autonomous parts, REASONABLY ANSWER THESE QUESTIONS?

19. The seven challenges
Does the description and boundaries of subsystems in law hinder progress towards autonomous systems?
Do the essential requirements hinder an autonomous system performing a function?
Do the various specifications hinder progress towards autonomous systems?
Do standards functions and not who/what does it?
Are standards being developed which specify characteristics needed in autonomous systems to meet the essential requirements?
Is there a full understanding the system wide impact of autonomous systems?
Can parties reasonably fulfil their monitoring & risk assessment obligations?

20. Thank you