Information Technology Reference
In-Depth Information
responsibility of the proposer to decide if, based on its experience, the change
is significant and would also have the effect that every time when a change
is not published on the list, a Europe-wide solution of this problem will need
to be sought. Further questions exist, on:
- is the development of such a list feasible;
- how can such a list take into account the different operators' expertise;
- would not it affect the cost of risk assessments for those railway actors
who could have decided that the change is not significant;
- is it going to influence positively or negatively the process for answering
to the question of the significance of a change and the demonstration of
CSM compliance?
During the work on the development of the CSM Regulation, the solution
to support the decision by the predefined criteria referred to above has been
put in place. This seems to be a good compromise between setting up a too
restrictive and inflexible framework or setting a question with a too wide
spectrum of answers, without any further guidance on how to proceed with
its answer. In the scope of the CSM dissemination workshops, with the help
of the pre-workshop questionnaire, it has been confirmed that the criteria
are used already nowadays by the railway actors in order to define whether
a change, which they would like to introduce, is significant. Already before
the CSM Regulation has come into force, the actors are answering to such
questions, in order to define the way how to analyse their changes and the
resulting hazards, in the scope of their safety management systems. They are
used to applying this practice in their everyday work and are confident in
knowing well its effectiveness level.
2.3
Hazard Record
The CSM Regulation requires that the proposer in charge of the risk manage-
ment process maintains a hazard record. The hazard record is the document
in which identified hazards, their related measures, their origin and the ref-
erence to the organisation, which has to manage them, are recorded and
referenced.
It is clear that the hazard record is an important part of the hazard
management process. It helps to document and support the decision making
process, by providing transparency and consistency. Due its traceability, on
one hand it allows corrective actions to be taken promptly and quickly, and
on the other hand, it supports the exchange of information between the dif-
ferent actors. It gives them the possibility to contribute to the evidence of
a continuous compliance with the relevant requirements. It does not need to
be complicated, because it is mainly targeted on the key issues.
Whereas these advantages of the hazard records are obvious and clear
for most of the railway actors, among them there are also such, who admit
that they are not yet experienced in its usage. Therefore, advice on different
questions often seems to be needed.
