Impact Assessment for Changes to Railway Group Standards

Impact Assessment for Changes to Railway Group Standards Version: Date: 03 September 2010 1 Relevant Railway Group Standard Standard to be issued Title: Requirements for Rail Vehicles Structures Number: GM/RT2100 Issue: Four Synopsis: This document mandates requirements for the design and integrity of rail vehicles structures for both primary and secondary structures, including interior crashworthiness. 2 Initiators of change The purpose of proposal 05/068, Review and Rationalisation of Standards Relating to Vehicle Structures, is to apply the Strategy for Standards Management to the following standards (a copy of the Strategy for Standards Management can be found on the Railway Group Standards website at www.rgsonline.co.uk): GM/RT2100, issue 3, Structural Requirements for Railway Vehicles GM/RT2101, issue 1 Requirements for the Design, Construction, Test and Use of the Tanks of Rail Tank Vehicles GM/RT2260, issue 2, Design for Recovery of Rail Vehicles GM/RT2456, issue 2, Structural Requirements for Windscreens and Windows on Railway Vehicles GM/RT2463 issue 1, Design and Operation of Wheelskates GM/RT2457, issue 1, Structural Requirements for Doors and Gangways on Railway Vehicles AV/ST9001, issue 1, Vehicle Interior Crashworthiness Using the scope criteria set out in the Railway Group Standards Code, the mandatory requirements held in these standards that are the sole responsibility of railway undertakings, and not required for cooperation, are withdrawn. The requirements that remain mandatory are transferred to a revised standard, GM/RT2100 issue 4, Requirements for Rail Vehicles Structures. GM/RT2100 issue 4 also incorporates a number of new requirements. Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 1 of 47

As part of this project, the Strategy for Standards Management has also been applied to another standard, GM/RT2162 issue 1, Traincrew Access to and Egress from Railway Vehicles. This issue is dealt with in a separate impact assessment. One requirement (Pressure pulse inside railway vehicles) currently held in GM/RT2160 issue 3, Environment inside Railway vehicles is transferred to GM/RT2100 issue 4. As part of this project, the Strategy for Standards Management has also been applied to another standard, GM/RT2190 issue 2, Requirements for Rail Vehicles Mechanical and Electrical Coupling Systems. This issue is dealt with in a separate impact assessment. 3 Summary of changed controls and implications for industry 3.1 Review of existing Railway Group Standards 3.1.1 Summary of changes to Railway Group Standards The tables at Annex A (A1 to A8) state for each standard listed in section 2: The requirements that are retained are identified as in the Way forward column of the Annex A tables. The requirements that are withdrawn as mandatory measures and transferred to the supporting Guidance Notes are identified in the Way Forward column as as mandatory. The requirements that are withdrawn and not to be transferred to the Guidance Notes are identified as. The tables also identify the decision criteria and associated reasons for retention or withdrawal. One requirement (Pressure pulse inside railway vehicles) currently held in GM/RT2160 issue 3, Environment inside Railway vehicles is transferred to GM/RT2100 issue 4. A number of requirements currently held in GM/RT2162 issue 1, Traincrew Access to and Egress from Railway Vehicles have also been transferred to GM/RT2100 issue 4 (see Annex B for details). A number of requirements currently held in GM/RT2190 issue 2, Requirements for Rail Vehicles Mechanical and Electrical Coupling Systems have also been transferred to GM/RT2100 issue 4 (see Annex C for details). 3.1.2 Other specific changes relating to the scope GM/RT2100 issue 3 The majority of the requirements held in GM/RT2100 issue 3 are retained as mandatory and carried forward in the new standard, GM/RT2100 issue 4 as they are required as NNTR to fill open points in the unpublished CR and four declared open points in the HS RS TSI. One requirement is transferred from GM/RT2100 issue 3 to GM/RT2004 issue 3, Requirements for Rail Vehicle Maintenance (clause 4.3, vehicle structural requirement over full range of variations in conditions ) and is not carried forward in issue 4. A new requirement, Body to bogie connection is included in GM/RT2100 issue 4, in order Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 2 of 47

to address Potters Bar derailment formal inquiry recommendation 25. Parts of clause 6.1.4, Longitudinal load cases, of GM/RT2100 issue 3 which related to ontrack machines, are transferred to the ontrack machines Railway Group Standard, GM/RT2400, currently titled Engineering Acceptance and Design of OnTrack Machines. Some of the mandatory requirements currently held in GM/RT2100 issue 3 are covered by EN 12663 (static strength), EN 15663 (vehicle masses) and EN 15227 (crashworthiness). In order to harmonise with the European requirements, GM/RT2100 issue 4 mandates the compliance with those Euronorms where appropriate. The adoption of these Euronorms raises some issues that have been brought to the Rolling Stock Standards Committee attention in January 2008 and May 2008. The Committee approved in principle the adoption of the Euronorms. The adoption of EN 15227 raises some specific issues. Annex D sets out the impacts of adopting EN 15227 in place of the RGS requirements relating to crashworthiness. Three new appendices have been included relating to the derivation of load cases from test or service data and bodyside window testing (small missile protection and pressure pulse). Appendix A reflects current good practice. Appendices B and D are based on the previous British Rail documents (as referenced in B2.3 of GM/RT2456) and are used by industry as good practice. Another new Appendix (Appendix C) relating to bodyside window containment testing is one of the outputs from research project T424, Requirements for train windows in passengers rail vehicles. Following industry consultation, two new requirements have been introduced: a) In dedicated sleeper vehicles provision for escape from windows b) Loadcase for transverse seats wholly or partially attached to the vehicle floor 3.1.3 Other specific changes relating to the scope GM/RT2101 issue 1 Requirements for the Design, Construction Test and Use of the Tanks of Rail Tank Wagons The large majority of the requirements held in GM/RT2101 issue 1 duplicate other mandatory requirements held in the RID governing the carriage of dangerous goods. They are therefore withdrawn. One requirement controls the risk arising from an activity that is no longer permitted (clause 10.2.2, Additional protection for tanks of rail tank wagons conveying hydrogen cyanide ) and is therefore withdrawn. 3.1.4 Other specific changes relating to the scope GM/RT2260 issue 2 Design for Recovery of Rail Vehicles The majority of the requirements are retained as mandatory and carried forward in the new standard, GM/RT2100 issue 4 as they are required as NNTR to fill open points in the unpublished CR and one declared open point in the HS RS TSI. 3.1.5 Other specific changes relating to the scope GM/RT2456 issue 2 Structural Requirements for Windscreens and Windows on Railway Vehicles The majority of the requirements held in GM/RT2456 issue 2 are retained as mandatory and carried forward in the new standard, GM/RT2100 issue 4 as they are required as NNTR to fill open points in the unpublished CR and one declared open point in the HS RS TSI. Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 3 of 47

One requirement ( Bodyside window strength ) is retained as mandatory but revised in order to incorporate the conclusion of research project T424, Requirements for train windows in passengers rail vehicles. This project identified a significant decrease in potential fatalities during an accident by the removal of breakable emergency egress windows. Following extensive testing of design for laminated windows, a revised specification for testing now forms part of the new standard, GM/RT2100 issue 4. Annex E states the main conclusion of the research project. With the withdrawal of emergency egress windows, emergency access requirements which were implicitly included in the toughened glass egress window requirements have been explicitly included from the T424 research. Two requirements are withdrawn: Compliance with one requirement is not reasonably practicable (first sentence of clause C3.3, Emergency egress windows ) as concluded in research project T424. The withdrawal of the requirement in clause 3.9, Restriction for droplight windows, has no impact on overall safety as a noncompliance pending standard change (04/125/NC) has already been approved against it by Rolling Stock Standards Committee in 2004. Additionally, this requirement is outside the scope of Railway Group Standards and therefore has not been transferred to GM/RT2100 issue 4. 3.1.6 Other specific changes relating to the scope GM/RT2457 issue 1 Structural Requirements for Doors and Gangways on Railway Vehicles The majority of retained measures are required as NNTR to fill open points in the unpublished CR and one declared open point in the HS RS TSI. 3.1.7 Other specific changes relating to the scope GM/RT2463 issue 1 Design and Operation of Wheelskates Three mandatory requirements relating to operational and maintenance matters are withdrawn as they are out of scope, being a single duty holder responsibility. One mandatory requirement relating to the maximum speed of a vehicle fitted with a wheelskate is withdrawn as it duplicates the Rule Book. Two requirements relating to the acceptance process are withdrawn because they conflict with the Railways and Other Guided Transport Systems (Safety) Regulations (Statutory Instrument 2006 No 599). 3.2 Review of ATOC Vehicles Standard AV/ST9001 Vehicle Interior Crashworthiness The scope of Railway Group Standards is now extended to the rail vehicles interiors (see Annex F of the Railway Group Standards Code). As a consequence, the requirements currently held in the ATOC Vehicle Standard AV/ST9001 issue 1 are now within the scope of Railway Group Standards and therefore some have been introduced into GM/RT2100 issue 4. The majority of the requirements held in AV/ST9001 issue 1 are furthermore required as NNTRs to address the declared open point in the HS RST TSI. The CR, as voted on by RISC, includes, in clause 7.5.2.1, reference to requirements applicable to interior passive safety. It includes the ability to notify applicable technical rules and such notification was approved by Rolling Stock Standards Committee. ATOC Vehicle Standard AV/ST 9001 issue 1 was a nonmandatory standard. The table at Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 4 of 47

Annex A7 in this Impact Assessment specifies in detail, for each requirement of AV/ST9001issue 1, the requirements that are in scope of Railway Group Standards, introduced into Railway Group Standards and transferred to GM/RT2100 issue 4. In addition, the table details the decision criteria and associated reason. In including previous nonmandatory requirements, detailed consideration has been given to developing clear assessable measures. During the review of AV/ST9001, a missing requirement has been identified. As a consequence a new requirement mandating the fitment of a secondary means of retention to access panels in areas normally occupied by passengers has been introduced in GM/RT2100 issue 4 in order to control the risk to passengers and staff from access panels opening unexpectedly. Guidance on this requirement has also been provided in GM/GN2687, Guidance for Rail Vehicle Structure and Secondary Structural Elements. This has been further revised in light of the high speed derailment of a train at Grayrigg on 23 February 2007. 4 Impacts 4.1 Safety impacts 4.1.1 New requirements Requirements previously held in ATOC Vehicles Standards Transferring requirements currently held in ATOC Vehicle Standards in Railway Group Standards are likely to have a small but positive impact on safety as the railway undertakings manage the risk related to rail vehicles interior crashworthiness by complying with the requirements mandated in GM/RT2100 issue 4. Body to bogie connection Following the derailment of a train at Potters Bar on 10 May 2002, seven people died and many other people were injured. One of the Potters Bar formal inquiry recommendations (recommendation 25) is the following: Standards that prescribe strength requirements for bodytobogie connections in vehicles should require that the potential modes of failure are determined at the design stage, and that action be taken to ensure that the integrity of the vehicle body structure is not compromised if the connection it overloaded. Objective: to reduce the risk of harm to passengers and staff from loss of integrity of vehicle structure in violent accidents. This recommendation has been accepted by the Railway Group Members and as a consequence, RSSB has been asked to introduce a corresponding requirement in Railway Group Standards. In order to address this recommendation, a new requirement has been introduced in GM/RT2100 issue 4 as another control for the risk related to the body to bogie connection. It is intended to close out recommendation 25, the aim of which is to reduce the risk of harm to passengers and staff from loss of integrity of vehicle structure in violent accidents. EN 15227 requirements Adopting the Euronorm is unlikely to have any detrimental impact on safety (see Annex E for details). Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 5 of 47

Access panels Following the high speed derailment of a train at Grayrigg on 23 February 2007, one person died and many other people were injured. One of the RAIB Grayrigg investigation report recommendations (recommendation 23) is the following: RSSB should consider, and where appropriate, make a proposal in accordance with the Railway Group Standards Code to implement a requirement in the relevant design standard to provide sufficient means of retention for internal panels assessed as capable of causing serious injury in the event of complete detachment. The new requirement mandating the fitment of a secondary means of retention to access panels controls the risk to passengers and staff from the panels opening unexpectedly if the primary retention device fails. Loadcase for transverse seats wholly or partially attached to the vehicle floor Following the high speed derailment of a train at Grayrigg on 23 February 2007, one person died and many other people were injured. One of the RAIB Grayrigg investigation report recommendations (recommendation 22) is the following: RSSB should make a proposal in accordance with the Railway Group Standards code to introduce a specific requirement in the relevant interiors design standard, that future seats designs, including those that may be fitted at refurbishment, should demonstrate a ductile deformation characteristic, when overloaded in the vertical, lateral or longitudinal directions, in order to minimise the risk of complete detachment in accidents. The new requirement mandating a specific transverse loadcase and reinforces and reemphasises existing measures intended to ensure that seat assemblies behave in a ductile manner and absorb energy when overloaded to control the risk to passengers from detached or partially detached seats in the event of an accident. Sleeper car windows from industry consultation The new requirement controls the risk associated with passenger entrapment for existing vehicles by permitting the continued use of breakable windows as a means of escape in the event of an accident. This is justified on the basis of the low risk of ejection due to the relationship between the windows and the berths and the need to satisfy the escape and evacuation requirements of GM/RT2130. The risk from loss of containment for this specific type of vehicle therefore remains unchanged. Test procedures and load case development New appendices have been included relating to the derivation of load cases from test or service data and bodyside window testing (small missile protection, containment and pressure pulse). Appendix A reflects current good practice. Appendices B and D are based on the previous British Rail documents (as referenced in B2.3 of GM/RT2456) and are used by industry as good practice. Appendix C relating to bodyside window containment testing is one of the outputs from research project T424, Requirements for train windows in passengers rail vehicles. Inclusion as requirements ensures the risk associated with inconsistent application of performance requirements is controlled. Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 6 of 47

4.1.2 Revised requirements Containment requirements for bodyside windows and the elimination of emergency escape windows The window requirement is revised and now mandates that breakable toughened glass emergency escape windows are no longer to be fitted and that laminated glass windows are to be now fitted in all positions. In addition the current requirements for laminated glass windows have been revised to include specific tests for containment performance to improve the safety of passengers and onboard staff. During an accident, fatalities have occurred due to people being ejected from the train through windows. Research project T424 concluded that the use of laminated glass windows instead of toughened only glass would significantly reduce that risk by containing people inside the vehicle (see http://www.rssb.co.uk/research/allsearch.asp for research reports and summarised in Annex E). Emergency access requirements have also been included from this research to ensure that after an accident the emergency services can cut laminated windows out if required in an acceptable time. Longitudinal loads Equipment and their mountings are currently required in Great Britain to withstand as proof load a longitudinal acceleration of 5g (see Table 4 of GM/RT2100 issue 3) while other European countries are only required to withstand a 3g acceleration. EN 12663 specifies typically a 3g longitudinal acceleration. This is a harmonised European requirement. EN 12663 which is referenced in the Rolling Stock TSIs will be mandatory over Europe when the TSIs come into force (October 2008 for the High Speed and 2012 for the Conventional Rail). Vehicle structure requirements The adoption of the Euronorms in place of the requirements currently held in GM/RT2100 issue 3 mandates equivalent means of controlling the risks related to vehicle structures. These Euronorms are harmonised European requirements. The Euronorms are referenced in the Rolling Stock TSIs and will be mandatory over Europe when the TSIs come into force (October 2008 for the High Speed and 2012 for the Conventional Rail). 4.1.3 Requirements to be withdrawn Requirements that are the sole responsibility of railway undertakings The withdrawal from Railway Group Standards of the requirements that are the sole responsibility of railway undertakings will have no impact on safety. Railway undertakings will continue to manage the risk that could arise from vehicles structures by the application of their Safety Management Systems and their internal standards and procedures. In addition, the Railway Group Standards relevant to this document (see Part 2 for details), even though withdrawn, will still be available on the RSSB website, with the proviso that no further development of the standards will be undertaken. Requirements that duplicate legislation The withdrawal from Railway Group Standards of the requirements that duplicate legislation will have no impact on safety. Railway undertakings will continue to manage the risk that could arise from vehicles structures by complying with legislation. Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 7 of 47

Requirements that can be withdrawn without impacting on overall safety The withdrawal from Railway Group Standards of the requirements controlling the risk that could arise from conveying hydrogen cyanide in tanks of rail tank wagon will have no impact on safety as the law prohibits the transport of this substance by train. Requirements that conflict with legislation The withdrawal of the requirements that conflict with legislation improves safety by decreasing the probability of railway undertakings applying acceptance processes that are not consistent. 4.2 Non safety impacts 4.2.1 New requirements Requirements previously held in ATOC Vehicles Standards Transferring requirements currently held in ATOC Vehicle Standards to Railway Group Standards is unlikely to have any impact on costs, as set out in Annex F Business Case for Rail Vehicle Interior Protection) of this paper, as the transfer of these requirements from one standard to another will not alter the way duty holders manage the risk related to rail vehicles interior crashworthiness. Setting out clear assessment criteria should enable costs to be optimised. Body to bogie connection The new requirement introduced in Railway Group Standards in order to further control the risk related to bogie detachment will yield an increase in design costs. The cost of implementing this requirement is expected to be relatively low in relation to total vehicle costs and will be at least partly offset by the value of risk reduction. EN 15227 requirements Adopting the Euronorm could save the GB rail industry the extra cost of developing GB specific rolling stock (see Annex D for details). Access panels The new requirement mandating the fitment of a secondary means of retention to access panels will have a negligible impact on costs. Loadcase for transverse seats wholly or partially attached to the vehicle floor The new requirement mandating a lateral ultimate load case will have a negligible impact on costs. Sleeper car windows From industry consultation The new requirement will have no impact on costs. 4.2.2 Revised requirements Containment requirements for bodyside windows and the elimination of emergency escape windows The replacement of toughened only glass windows by laminated ones will yield an increase in testing costs at the early stages because the use of these new windows will necessitate the development of new testing procedures. However both window types costs are similar. Therefore replacing a damaged window by a laminated glass window instead of a toughened one is not expected to affect the global replacement costs. Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 8 of 47

Longitudinal loads The revision from 5g to 3g longitudinal acceleration will yield either no impact on costs or a potential reduction in costs to the industry. The vehicles currently produced comply with the revised requirement and there is a potential saving from standardised design over Europe. Vehicle structure requirements The adoption of Euronorms in place of the vehicle structure requirements held in GM/RT2100 issue 3 will yield either no impact on costs or a potential reduction in costs to the industry. The industry may achieve lower costs by adopting standardised vehicle design over Europe and avoid the unnecessary cost of developing new rolling stock that will be rolled out under the TSI specifications. 4.2.3 Requirements to be withdrawn The withdrawal of requirements from Railway Group Standards that are the sole responsibility of railway undertakings, that duplicate legislation and that can be withdrawn without impacting on overall safety, is unlikely to have a material impact on costs. This is because the withdrawal does not, of itself, cause the railway undertakings to alter the way they manage the control of risk. The small initial document management cost associated with the withdrawal of those requirements will be offset by future reductions in document management costs. The withdrawal of the requirements that conflict with legislation is likely to save the rail industry the cost of applying acceptance processes that are not longer valid. 5 Relevant strategies and decision criteria This project has been developed under issue 2 of the Railway Group Standards Code (the Code). Subsequently, issue 3 of the Code has come into force. However, issue 2 of the Code has continued to be used for the purposes of this impact assessment, in accordance with the transitional arrangements set out in section 8.1 of issue 3 of the Code.' 5.1 Relevant Strategies The Railway Group Standards Code defines Relevant Strategies as strategies relevant to Standards Change and Deviations developed by the RSSB, Strategic Rail Authority, Standards Strategy Group or any other relevant committee or person. The Strategy for Standards Management is a Relevant Strategy. Section 1.4.4 (a) of the Railway Group Standards Code requires that Decisions which are made under the Code regarding Standards shall be made by applying the Criteria and taking into account any Relevant Strategies. The Strategy for Standards Management established the principle that only those parameters or processes that directly govern the ability of two (or more) duty holders to interface / cooperate with each other to the extent that harmonisation is required to deliver safety in the most economical way should be given the status of mandatory measures. Those requirements held in the Standards relevant to this document (see Part 2 for details) that do not relate to parameters or processes that directly govern the ability of two (or more) duty holders to interface / cooperate with each other have therefore been withdrawn as out of scope of RGS (see section 5.2.2). Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 9 of 47

5.2 Decision Criteria 5.2.1 Decision criteria for new or revised measures A decision criteria for the introduction of new or revised measures set out in Annex G of the Railway Group Standards Code issue 2 (on which this Impact Assessment is based) is as follows: 1.1 Subject to paragraph 1.3, a new or revised measure shall be introduced if it is within Scope (see Annex F); and (a) (b) improves safety (for example, by applying Relevant Good Practice); or is assessed to be reasonably practicable (taking into account any relevant Guidance) and then only if it: (ii) is a more practicable or cost effective means of achieving the same or better Risk control than the measure it replaces The new or revised requirements that are introduced satisfy both the Geographical and Risk Scope Tests. The scope of the Railway Group Standards Code has been extended to the rail vehicles interiors and duty holders must cooperate or perform the same activity in order to control the risk. The introduction of the new requirements in order to control the risk to body to bogie connection and panel access unexpected opening, as well as the introduction of a revised requirement mandating the use of laminated glass windows is assessed to be reasonably practicable and to improve safety. Therefore these requirements meet the criteria for new requirements as set out in Annex G, clause 1.1b) i) of the Railway Group Standards Code. Transferring requirements currently held in ATOC Vehicle Standards to Railway Group Standards is a more practicable means of achieving the same risk control, as these requirements are now within the scope of Railway Group Standards. They meet the criteria for new requirements as set out in Annex G, clause 1.1b) ii) of the Railway Group Standards Code. The adoption of the Euronorms is assessed to be a more practicable means of achieving the same Risk control than the measures they replace. Therefore these requirements meet the criteria for revised requirements as set out in Annex G, clause 1.1b)i) of the Railway Group Standards Code. 5.2.2 Decision criteria for the withdrawal of measures Requirements that can be withdrawn without impacting on overall safety A decision criterion for withdrawal set out in Annex G of the Railway Group Standards Code is as follows: 2.1 A Measure shall be withdrawn: (a) when the withdrawal has no detrimental impact on overall safety (see examples given in paragraph 2.2) 2.2 Circumstances in which the withdrawal has no detrimental impact on overall safety may include where: (a) (b) control of Risk is provided by ; or the activity or asset giving rise to the Risk is no longer used. Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 10 of 47

The requirements that duplicate other legislation are listed in the Appendix, specified as risk controlled by in the Decision criteria column of the table. The control of risk is provided by requirements to be retained in other mandatory documents and the withdrawal of these requirements has no impact on overall safety. Therefore they meet the Railway Group Standards Code criteria for withdrawal. Conveying hydrogen cyanide by train is now prohibited. The activity giving risk to the risk is therefore no longer used. Therefore requirement mandating additional protection for tanks of rail tank wagons conveying hydrogen cyanide meets the Railway Group Standards Code criteria for withdrawal. Requirements that conflict with legislation Another decision criterion for withdrawal set out in Annex G of the Railway Group Standards Code is as follows: 2.1 A Measure shall be withdrawn: (b) it conflicts with legislation The requirements that conflict with legislation meet the decision criteria for withdrawal set out in the Railway Group Standards Code. Requirements that are out of scope of Railway Group Standards Another decision criterion for withdrawal set out in Annex G of the Railway Group Standards Code is as follows: 2.1 A Measure shall be withdrawn: (c) if it is not within scope The scope of Railway Group Standards is set out in Annex F of the Railway Group Standards Code. It states that for a measure to be in scope it must satisfy both the Geographical Scope Test and the Risk Scope Test. The Geographical Scope Test states that: 3.1 A Measure is only within the Scope if it is the control of a Railway Group Member Railway Group Members are defined by the Railway Group Standard Code as all persons falling within the following definitions: (a) Network Rail; (b) all Train or Station Operators holding a Railway Safety case in respect of any Railway Infrastructure to which the Network Licence applies; (c) (d) any other Infrastructure Controller which is an RSSB Member; all Train or Station Operators holding a Railway Safety Case in respect of any Railway Infrastructure controlled by any person within paragraph (c) above. Rail Safety and Standards Board (RSSB) does not fall in any of these categories and thus is not a Railway Group Member. The requirement that mandates action on RSSB is out scope and therefore meets the Railway Group Standards Code criteria for withdrawal. It is specified as Out of scope in the Decision criteria column of Annex A tables. Other measures considered for withdrawal satisfy the Geographical Scope Test, however, the Risk Scope Test states that: Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 11 of 47

4.1 Subject to paragraphs 4.2 and 4.3, Measures are only within the Scope if they address the control of Risk to passengers, railway workers and members of the public arising from railway specific hazards associated with: (a) Infrastructure operations and train operations. 4.2 A Measure controlling Risk arising from a railway specific hazard is only within Scope in the following circumstances: (a) The control of Risk necessitates cooperation between Railway Group Members in two or more Industry Categories; and (b) All Railway Group Members within a single Industry Category must cooperate or perform the same activity in order to control the Risk. Those requirements for which the railway undertakings have sole responsibility and do not have to cooperate are out of scope and meet the Railway Group Standards Code criteria for withdrawal. They are specified as Out of scope in the Decision criteria column of Annex A tables. 6 Conclusions Following the application of the Strategy for Standards Management to the standards specified in Part 2, a number of requirements and part of one have been withdrawn as they meet the criteria set out in the Railway Group Standards Code for withdrawal. A number of requirements have been retained as mandatory. They have been transferred to a new Railway Group Standard, GM/RT2100 issue 4 and one to a new issue of GM/RT2400. A number of retained measures have been revised as stated in section 3. In addition, the new requirements from AV/ST9001 issue 1 meet the Railway Group Standards Code criteria for introduction of new requirements in Railway Group Standards. They have been introduced in GM/RT2100 issue 4. Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 12 of 47

ANNEXES Annexes contents Annex A: Tables... 14 Table A1: GM/RT2100 issue 3, Structural Requirements for Railway Vehicles... 14 Table A2: GM/RT2101 issue 1, Requirements for the design, construction, test and use of the tanks of rail tank wagons... 17 Table A3: GM//RT2260 issue 2, Design for Recovery of Rail Vehicles... 24 Table A4: GM/RT2456 issue 2, Structural Requirements for Windscreens and Windows on Rail Vehicles... 25 Table A5: GM/RT2457 issue 1, Structural Requirements for Doors and Gangways on Rail Vehicles... 26 Table A6: GM/RT2463 issue 1, Design and Operation of Wheelskates... 27 Table A7: AV/ST9001 issue 1, Vehicle Interior Crashworthiness... 28 Annex B: Requirements transferred from GM/RT2162 issue 1 to GM/RT2100 issue 4... 310 Annex C: Requirements transferred from GM/RT2190 issue 2 to GM/RT2100 issue 4... 31 Annex D: Comparison of UK and European crashworthiness standards... 32 Annex E: Replacement of toughened glass windows by laminated ones... 37 Annex F Business Case for Rail Vehicle Interior Protection 42 Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 13 of 47

Annex A: Tables Table A1: GM/RT2100 clause(s) 4.1 4.2 4.3 4.4 4.5 4.6, 10.1 5.1 5.3 6.1.1 6.1.3 6.1.4 6.2 7 8.1 8.4; 9.1 9.4 10.1 GM/RT2100 issue 3, Structural Requirements for Railway Vehicles Requirement name or content Purpose of structural requirements for railway vehicles Vehicle structural requirements over full range of variations in conditions Vehicle maintenance to retain structural design integrity Vehicle structural integrity repairs Assessment code for fatigue strength of bolted, riveted, welded aluminium or steel structures for rail vehicles Structural integrity of equipment mounted on rail vehicles Prescribed load factors when assessing vehicle structures by calculation Longitudinal proof loads for vehicle structures Vehicle structures longitudinal load cases Vehicle structures vertical load cases Vehicle body fatigue load requirements Requirements for structural collapse of vehicle bodies in a collision Structural integrity of equipment mounted on rail vehicles Decision Criteria (Annex G of the Railway Group Standard Code) Reason Cooperation Proposed way forward Revise and retain in RGS Cooperation Cooperation and transfer to GM/RT2004 Cooperation Cooperation Cooperation covered by EN12663 clause 3.6 covered by EN 12663 clause 4.5 Cooperation Cooperation Cooperation Cooperation Cooperation Cooperation Revise and retain in RGS Covered by EN 15227 and EN 12663 partially covered by EN 15227 and EN 12663 clause 4 parts related to ontrack machines (OTM) are transferred to the OTM RGS Revise and retain in RGS covered by EN 12663 clause 4.3 and pren15663 covered by EN 12663 clause 4.6 covered by EN 15227 See 4.6 Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 14 of 47

GM/RT2100 clause(s) 10.2, 10.3, table 4 10.4, 15.3 11.1 11.3 12.1 12.5 13.1 13.2 13.3 13.4 14.1, 14.2 14.3 14.5 14.6 15.1 15.4 15.1 15.3 15.3 16.1 16.3 16.4, 16.5 16.6 & 16.7; 17.1 17.3 19 Requirement name or content Proof load cases of equipment and mountings Fatigue loading of equipment and mountings Protection of vehicle occupants from missiles Structural requirements for obstacle deflectors on rail vehicles General requirements for strength and calculation of proof loads for jacking and lifting points. Nominal vehicle weights to be used in the calculations for jacking and lifting points Magnitude of load factor for proof design load of jacking and lifting points. Calculation of ultimate design loads of jacking and lifting points. Structural requirements of bogies in normal conditions Resistance of bogie structures to fatigue loading Structural requirements for rail vehicle body bogie attachments Requirements for structural integrity of equipment attached to bogie frames Resistance to failure of equipment and their mountings Equipment and their mountings withstanding extreme vehicle body accelerations Fatigue loading of equipment and mountings Requirements for the structural performance of lifeguards Requirements for structural integrity of equipment attached to bogie frames Requirements for structural integrity of equipment attached to axleboxes Generation of and resistance to pressure pulses Decision Criteria (Annex G of the Railway Group Standard Code) Reason Cooperation Cooperation Proposed way forward Revise and retain in RGS clause 10.3 is covered by EN 12663 clause 4.5 which mandates a 3g longitudinal load for passenger and personnel vehicles covered by EN 12663 clause 4.7 Cooperation Cooperation Revise and retain in RGS covered by EN 15227 Cooperation. Cooperation Cooperation Cooperation Cooperation Cooperation Cooperation Cooperation Cooperation Cooperation See 10.4 See 15.3 See 15.1 Cooperation Cooperation Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 15 of 47

GM/RT2100 clause(s) 20 Requirement name or content Verification of compliance of equipment and mountings capability to withstand the prescribed loads Decision Criteria (Annex G of the Railway Group Standard Code) Reason Proposed way forward Cooperation Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 16 of 47

Table A2: GM/RT2101 issue 1, Requirements for the design, construction, test and use of the tanks of rail tank wagons GM/RT2101 clause(s) 3.2 Requirement name or content Definition of calculation pressure for tanks of rail tank wagons 3.2, 3 rd End thickness of tanks of sentence rail tank wagons 3.6 3.12 4.1 Definition of design pressure for tanks of rail tank wagons Definition of maximum allowable working pressure for tanks of rail tank wagons Existing tanks of rail tank wagons subject to engineering change nd Approved carriage list of 4.3, 2 substances carried in rail sentence tank wagons 4.4 5.1 5.1.1 5.1.1 & 12.2.1 5.5.1, 13.1 & 13.2.1 5.1.2 5.1.3 5.1.4 5.1.5 Detail design of the tank of rail tank wagons Construction and inspection requirements for all tank wagons Design pressure basis of the tanks of rail tank wagons Design pressure for tanks of rail tank wagons conveying Class 8 substances Design pressure of tanks for rail tank wagons conveying Class 9 substances Materials for tanks of rail tank wagons Protective linings for tanks of rail tank wagons Thickness of tanks of rail tank wagons to compensate for corrosion Design to prevent loss of contents for tanks of rail tank wagons Decision Criteria (Annex G of the Railway Group Standard Code) Reason Duplicates Regulations governing International carriage of Dangerous goods (RID ) (clause 6.8.2.1.16) (clauses 6.8.2.1.13 & 6.8.2.1.22) (clauses 6.8 & 6.7.2.1) (clause 6.7.2.1) Duplicates legislation on Use of transportable pressure equipment 2004" (clause 3.2 & 2.1.1.1) (clause 6.8.2.1.4) (clauses 6.8.2.1.4 & 6.8.2.4) (clauses 6.8.2.1.13 & 6.8.2.1.22) (clause 3.2.1, column 12) (clause 3.2.1, column 12) (clause 6.8.2.1.9) (clause 6.8.1.24) (clause 6.8.2.1.9) (clauses 6.8.2.1.1 & 6.8.2.1.2) Proposed way forward Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 17 of 47

GM/RT2101 clause(s) 5.1.6 5.1.7 & Attachment 2 5.1.8 5.1.9 5.1.10 5.1.11 5.1.12 5.1.13 5.2.1 paragraph 1 5.2.1 paragraph 2 5.2.2 paragraph 1 5.2.2 paragraphs 2 & 3 5.2.2 paragraph 4 5.2.2 paragraph 6 5.2.3 & Appendix F 5.2.4 5.2.5 &, Appendix A, Attachment 5 Requirement name or content Thickness of shell and ends of tanks of rail tank wagons Additional protection for dangerous goods of tanks of rail tank wagons Bonding of tanks of rail tank wagons Minimum thicknesses of tanks of rail tank wagons Manufacturers qualifications and tests for performing welding on tanks of rail tank wagons Internal negative pressure on tanks of rail tank wagons Thermal insulation and external cladding on tanks of rail tank wagons Support brackets on tanks of rail tank wagons Items of tank equipment of rail tank wagons Gaskets on tanks of rail tank wagon Shutoff devices for bottomdischarge tanks of rail tank wagon Primary valves on tank of rail tank wagons Secondary valves on tanks of rail tank wagons Filling and discharge devices on tanks of rail tank wagons Inspection openings on tanks of rail tank wagons Cleaning apertures on tanks of rail tanks wagons Pressure relief valve system on tanks of rail tank wagons Decision Criteria (Annex G of the Railway Group Standard Code) Reason (clauses 6.8.2.13 & 6.8.2.1.22) Proposed way forward GB interworking Out of scope Duplicates (clause 6.8.2.1.27) (clause 6.8.2.1.18) (clause 6.8.2.1.23) (clause 6.8.2.1.7) (clause 6.8.2.1.25) Single duty holder responsibility (clause 6.8.2.2.1 paragraph 2) (clause 6.8.2.2.1 paragraph 4) (clause 6.8.2.2.2 paragraph 1) (clause 6.8.2.2.2) (clause 6.8.2.2.2 paragraphs 1 & 2) (clause 6.8.2.2.2 paragraph 4) (clause 6.8.2.2.4) (clause 6.8.2.2.2 paragraph 8) (clause 6.8.3.2.8) Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 18 of 47

GM/RT2101 clause(s) 5.2.6 5.2.7 paragraph 1 Requirement name or content Carriage of flammable liquids flash point equal to or below 55 C in tanks of rail tank wagons Carriage of flammable liquids flash point equal to or below 21 C in tanks of rail tank wagons Decision Criteria (Annex G of the Railway Group Standard Code) Reason (clause 6.8.2.2.9) Proposed way forward 5.2.7 paragraph 2 5.3.1 paragraph 2 5.4.1 & Appendix B 5.4.2 5.5.1 5.6.1 5.6.2 5.6.3 & Attachment 3 5.6.4 5.6.5 5.6.6 5.6.7 5.6.8 5.6.9 5.6.10 5.6.11 & Appendix C 5.6.12 & Appendix G Carriage of toxic gases and hydrogen cyanide in tanks of rail tank wagons Design scrutiny to tanks on rail tank wagons Initial inspection and testing of tanks of rail tank wagons NDT of welds for tanks intended for dangerous goods (except Class 2 as detailed in 6.5) Marking requirements applicable to all rail tank wagons Plate thickness wasting on tanks of rail tank wagons Carriage of non approved substances in tanks of rail tanks wagons Overfilling of tanks on rail tank wagons Heated substances in tanks of rail tank wagons Hot substances in tanks of rail tank wagons Leakage from tanks of rail tank wagons Closure systems in series of tanks of rail tank wagons Dangerous residue in tanks of rail tanks wagons Discharged tanks of rail tank wagons Connecting pipes of tanks on rail tank wagons Periodic inspections & testing of tanks in rail tank wagons Certification prior to work or testing on tanks of rail tank wagons Activity or asset giving rise to the risk is no longer in use Hydrogen cyanide is no longer allowed to be conveyed by train (clause 6.8.2.3.1) (clause 6.8.2.4.1) (clause 6.8.2.1.23) (clause6.8.2.5) (clause 4.3.2.3.1) (clause 4.3.2.1.5) (clause 4.3.2.2.3) (clause 4.3.4.2) (clause 4.3.2.3.3) (clause 4.3.2.3.4) (clauses 4.3.2.3.5 & 4.3.2.4.1) (clause 4.3.2.4.2) (clause 4.3.4.2.2) (clause 6.8.2.4.2) Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 19 of 47

GM/RT2101 clause(s) 5.6.13 6.1 & 6.2.1 6.2.2 6.2.3 6.2.4 6.3.1 6.3.2 6.3.3 & Appendix A 6.3.4 6.3.6 6.3.7 6.5 6.7.1 & Attachment 3 6.7.2 7.2.1 7.3.1 & Appendix A Requirement name or content Leakage testing following removal of foot valve or secondary closure on tanks of rail tank wagons Design pressure using vapour pressure and deceleration factor for tanks of rail tank wagons Additional side protection for carriage of Class 2 substances in tanks of rail tank wagons Unstable substances in tanks of rail tank wagons Special application to certification body for transport of deeply refrigerated gases in tanks of rail tank wagons Equipment gauges, thermometers and manometers on tanks of rail tank wagons Tanks on rail tank wagons for class 2 substances no openings below level of liquid Pressure relief valve system (except for non flammable toxic gases) in tanks of rail tank wagons Pressure relief valve system on tanks of rail tank wagons for flammable toxic gases Filling and discharge systems of tanks of rail tank wagons conveying class 2 substances Second external closing device on tanks of rail tank wagons conveying class 2 substances Weld tests for tanks of rail tank wagons conveying class 2 substances Overfilling of tanks of rail tank wagons with any gas Precautions for successive carriage of different liquefied gases in tanks of rail tank wagons Special pressure for class 3: flammable liquids tanks or rail tank wagons Pressure relief devices for class 3 substances in tanks of rail tank wagons Decision Criteria (Annex G of the Railway Group Standard Code) Reason (clause 6.8.2.4.3) (clause 6.8.2.1.14) (wagon construction) (clauses 2.22.41.2.1, 4.2.2.8.2.1, 2.2.61.2.1, 2.2.51.2.1) (clause 6.8.3.2.6) (clauses 3.2.1 & 4.3.3.1.1) (clauses 6.8.3.2.9, 10,.11,.12 & 13) (clause 6.8.3.2.11) (6.8.2.2.2) (clause 6.8.2.2.2) (clause 6.8.3.4.5) (clause 4.3.3.4.3) (clause 4.3.3.3.1) (clause 6.8.2.1.14) (clause 6.8.4 TE1) Proposed way forward Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 20 of 47

GM/RT2101 clause(s) 7.3.2 8.2 8.3.1 8.3.2 8.3.3 8.3.4 8.7.1 8.7.2 8.7.3 8.7.4 8.7.5 9.2.1 9.2.2 9.2.3 9.2.4 9.3.1 Requirement name or content Requirements for openings in class 3 tanks of rail tank wagons with calculation pressure of 10 bar + Design pressure for class 4 substances in tanks of rail tank wagons Thermal insulation for class 4 substances of tanks of rail tank wagons Additional requirements for tanks of rail tank wagons intended for white phosphorous Additional requirements for tanks of rail tank wagons conveying substances for class 4.2 and 4.3 Additional requirements for tanks of rail tank wagons for class 4.3 packing group I Additional requirement for tanks of rail tank wagons conveying sulphur and naphthalene Additional requirements for protective agents with white phosphorus in tanks of rail tank wagons Discharged requirements of tanks of rail tank wagons which have contained white phosphorous Degree of filling of tanks of rail tank wagons for trichlorosilane Degree of filling of tanks of rail tank wagons for organometallic compounds Design pressure for tanks of rail tank wagons containing class 5 substances Additional requirements for tank of rail tank wagons containing hydrogen peroxide and solutions Requirements for tanks of rail tank wagons containing hot aqueous solutions of ammonium nitrate Additional requirement for tank wagons containing organic peroxide Equipment for tanks of rail tank wagon conveying hydrogen peroxide tanks Decision Criteria (Annex G of the Railway Group Standard Code) Reason (tank construction) (clause 6.8.2.1.14) (tank code and chapter 3.2, clause 6.8.4, table A columns 1& 13) (clause 6.8.4) (clause 3.2) (clauses 6.8.4 TE2, 4.3.5 TE21 & TU14) (clause 4.3.2.2) (TU12) (clause 6.8.4 TU16) (clause 4.3.5 TU25) (clause 4.3.5 TU22) (clause 6.8.2.1.14) (clause 6.8.4 TC2) (clause 6.8.4 TC3) (clause 3.2.1) Proposed way forward Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 21 of 47

GM/RT2101 clause(s) 9.3.2 9.3.3 9.3.4 9.7.1 9.7.2 9.7.3 & 9.7.4 10.2.1 10.2.2 10.3.1 10.3.2 10.3.3 11.2.1 11.2.2 11.3 11.7 12.2.1 12.2.2 Requirement name or content Connections for tanks for hydrogen peroxide Protection devices for hydrogen peroxide / hot aqueous solutions of ammonium nitrate on tanks of rail tank wagons Thermal insulating material for hot aqueous solutions of ammonium nitrate on tanks of rail tank wagons Use of cleanliness of tanks for class 5 substances Filling of substances in packing group 1 of class 5 in tanks of rail wagons Additional requirements for use of tanks for ammonium nitrate Design pressure for Class 6 substances for tanks of rail tank wagons Additional protection for tanks of rail tank wagons conveying hydrogen cyanide Equipment for tanks of rail tank wagons conveying substances of Class 6 Bottom discharge for tanks of rail tank wagons conveying substances in 10.1.3 of GM/RT2101 Tanks of rail tank wagons for Class 6.1 with flammable subsidiary hazard Tank pressure of rail tank wagons for Class 7 substances Design of tanks of rail tank wagons for Class 7 substances Equipment for tanks of rail wagons for conveying Class 7 substances Degree of filling for Class 7 substances Design pressure for tanks of rail tank wagons conveying Class 8 substances Lead or equivalent lining for tanks of rail tank wagons conveying bromine Decision Criteria (Annex G of the Railway Group Standard Code) Activity or asset giving rise to the risk is no longer in use Reason (clause 6.8.4 TC2) (clause 6.8.4 TE9) (clause 6.8.4 TE10) (clause 6.8.4 TU3) (clause 4.3.5 TU28) (clause 4.3.5 TU29) (clause 6.8.2.1.14) Hydrogen cyanide is no longer allowed to be conveyed by train (clause 3.2.1, column 12) (clause 3.2.1, column 12) (clause6.8.4 TE1) Duplicate Rid (clause 4.3.4.1.3g) (clause 3.2.1, column 12) (clause 3.2.1, column 12) (clause 4.3.5 TU36) Proposed way forward See 5.1.1 (clause 6.8.4) Rail Safety & Standards Board Impact Assessment for GM/RT2100 issue 4 Page 22 of 47