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For example, for some actors it is not very obvious to know when the
hazard record has to be updated. This is usually done whenever:
- a new hazard is discovered or a new safety measure is identified during
the design phase;
- a new hazard is identified during the operation and maintenance of the
system after its commissioning, so that the hazard can be assessed in
compliance with the CSM as to whether it represents a significant change;
- it could be necessary to take into account accident and incident data;
- there are changes to the safety requirements or the assumptions about
the system;
Additionally, it is good that a difference is made between the hazard records,
which are mainly meant to be used in the preventive part of the railway safety,
and the statistics from railway accidents and incidents, which every company
is maintaining and is a typical reflection of the reactive part of the railway
safety. Although, the prevention and the reaction are interconnected with
each other, still, typically the hazard record is structured and maintained in a
different way from the event statistics of the railway companies. Nevertheless,
it is normal that it receives input for its updates, whenever such unwanted
events occur, which lead to the recognition of new hazards, or to the change
of some of the existing ones.
Another topic of particular interest is the maintenance of the hazard
record in the typical situation when there are a number of actors involved in
a certain significant change, each of whom has to have responsibility for his
part of the system under assessment. In such cases, it is normal that each
of the involved parties keeps a record of the hazards for their part of the
assessed change or project. Usually there is one overall actor (proposer) who
has responsibility for the main record. This main record covers all the neces-
sary elements of the system under assessment. It does not have to contain all
the information from the other actors, but it needs to keep the links and key
safety related issues. The exchange of information gains more importance, if
the hazard cannot be controlled by one actor alone.
The practice has shown that when classifying the hazards in the hazard
records, every company is having its own logic. Even though, at the very be-
ginning it might be a bit challenging to set up such a logic, which is adjusted
to the company needs and is able to reflect its existing safety profile, once it
has been set, it becomes a powerful support for the creation and the main-
tenance of the hazard records. Sometimes it might be hard to figure out the
necessary level of detail for the documentation of the hazards. Nevertheless,
by gaining more practice in the usage of the hazard record, the companies
are gradually learning, which level of detail is most proper for their situation
too.
Currently, there is no requirement in the CSM Regulation on the question
how long to maintain the data from the hazard records. Therefore, also this
decision lies in the responsibility range of the proposers.
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