HST's are insufficiently safe (apparently)

[Wolfie]

Given that rail isn't an island, there is an argument that says that not pursuing the Nth degree of supersafety and instead spending that money on either road safety or lower fares may actually save more lives. HSTs will need replacing anyway, but e.g. the obsessive closure of level crossings for instance may represent poor value over other road safety improvements.

I wish any rail company good luck in advancing that argument in Court in the event of civil (or indeed criminal) litigation arising from an accident.

 

[bramling]

Given that rail isn't an island, there is an argument that says that not pursuing the Nth degree of supersafety and instead spending that money on either road safety or lower fares may actually save more lives. HSTs will need replacing anyway, but e.g. the obsessive closure of level crossings for instance may represent poor value over other road safety improvements.

The problem is that the powers that be have dropped a bit of a bollock on this one.

HST cab performance was floated in the Ladbroke Grove report, it didn’t gain focus at the time probably because the report acknowledged that it made no difference to the outcome of that accident. It was also relevant at Ufton, and in retrospect it’s surprising there wasn’t more focus here.

No one seems to have considered the issue when selecting the ScotRail solution, and then unfortunately something has happened which has resulted in the issue gaining a raised profile — not too dissimilar to the issue with sharp curves on tramways, where with the great benefit of hindsight it’s possible to say “why didn’t anyone think of that before?”.

Yes the point about overall risk is well made, but that doesn’t really help if you’re a ScotRail HST driver, or someone responsible for their safety.

In that sense it is fortunate that the likes of the 175s and 222s seem likely to be spare in relatively short order. It’s something which is just going to have to be sucked up I think.

 

[Bluejays]

Yes, and it's the 'other factors' that are at play here. It's one of the many examples of 'safetyism' - something which has a very, very minimal impact or none at all in the real world, but those advocating it push really hard for it. And it's definitely the case that Covidianism has increased it in all areas of life - nearly all the Covid "safety" theatre was extreme safetyism, and it's led to a further increase in the idea that all risk has to be banished, no matter how small that risk is in reality.

Couldn't disagree more. I'm going to resist the attempts to link this to covid, I think that's a bit of a cheap shot, and certainly a topic that could derail the thread (no pun intended).

The accident report highlighted a potential problem. Because of that, interested stakeholders are asking questions.
The reality of course, is that it's going to be extremely unlikely that the hst has suddenly become inherently unsafe. But it may well be the case that some modifications could be identified to improve safety, either structural or procedural.

If the hst's had been withdrawn from service, or if aslef had instructed their drivers to refuse to work hst's then I would be more inclined to understand this sabre rattling. The reality of course is that they continue to work, with legitimate questions being asked.

One out of three. The job of writers in rail magazines is not to make rail safer - it's to write stuff that sells magazines. Likewise, rail unions are there to represent their members (well, in theory); it's not primarily about making rail safer.

Agree about the writers, poorly worded. I meant to say the rail writers job is to be interested in rail rather than all transport. Disagree about the unions, one of their primary focuses is improving the safety at work of their membership.

 

[yorksrob]

To put it another way, would you be comfortable as a duty-holder signing off a risk assessment on HST power cars, specifically could you honestly say that keeping HSTs running (especially if other stock is available) is reducing risk to as low as reasonably practicable?

Don't get me wrong, I enjoy travelling in HSTs, and completely agree with your views relating to comfort of Mk3s in relation to newer fleets, including in relation to seats. I just don't think ignoring the issue of cab crashworthiness would stand up to scrutiny if push came to shove.

In essence, I think politically the ScotRail HSTs will find themselves being replaced by Voyagers or Meridians in due course, and the GWR ones with 158s or via a reshuffle of IETs. The latter already seems to be a partly done deal anyway. It's a shame, but if anyone's to "blame" then it's those who specified and designed the GRP cab structures, rather than present-day ASLEF.

Or to put it another way, If I owned a business with a fleet of road vehicles of varying ages, I would expect the newer ones to have more safety features than the oldest models. Would I see this as a reason to withdraw the oldest models by itself ? No.

I’m afraid the above paragraph reveals that you don’t really understand what a trade union is, or the function it is supposed to perform.

ASLEF are a train drivers’ union. As such they represent train drivers and their (very specific and narrow) range of interests *when they’re at work*. They aren’t a transport pressure group, they don’t represent passengers, so why on earth would they concern themselves with the relative risks of other forms or transport, future investment in the railway, or even what their own members get up to outside of work?!

I can think of a very good reason why train drivers should be concerned with the overall sustainability of the rail industry.

Another question would be how viable it might be to simply replace the power cars with something else. No doubt a significant amount of work would be required, but how much?

A logo with the greater Anglia mk3's (which were very high quality internally) and loco might have neutralised the issue.

I don't think they shouldn't have an issue with it. I just think like the Mk1 fleet replacement, a sensible deadline should be put in place to allow for something genuinely suitable to be ordered, tested and delivered, rather than just going on the hunt for whatever junk old DMUs they can find, of which 175s are probably the best but aren't *great*.

GWR is a bit different as they're just acting as stand-in double 158s - replacing them with 5-car 80x will be a reasonable upgrade, the GWR ones are quite tatty and all Standard with the high density interior so not even that nice!

XC, well, that needs more sorting out than just a couple of HSTs, the whole operation is awful from start to finish, there is pretty much nothing good about any of it.

Well, at least with the mk1's, they did actually have a replacement fleet.

With this you just know it's going to be, "well, we don't want to build any more diesels, and we can't afford to electrify, so well just scrape together a few units here and there, until there's a proper solution sometime/never"

It'll be Midland mainline HST withdrawal all over again.

 

[43301]

A logo with the greater Anglia mk3's (which were very high quality internally) and loco might have neutralised the issue.

Not enough suitable locos available. The stock would also have needed power doors and at least some of the seats replacing.

Are DVTs any better than power cars when it comes to safety? They are certainly lighter which could make them more prone to derailing.

 

[yorksrob]

The problem is, that it's hard to argue that the risk associated with HST cabs is as low as reasonably practicable. A fleet retained well past its book life, a specific weakness which is real not hypothetical, and - soon at least - suitable replacement rolling stock going spare.

So probably unreasonable to demand withdrawal *now* (which no one is seriously calling for), but hard to justify retaining them beyond the short term.

I'd say it's a reasonable bet they'll be gone as soon as something else becomes available, if that means underfloor diesel engines then it will have to be. For those who enjoy HSTs, make the most of them while they last.

I would say it's not "reasonably practical" to replace HST's until there is something adequate to replace them.

In the case of the Midland Mainline, the HST's have been removed before there was adequate stock to replace them, precisely because an arbitrary deadline was put in place.

Not enough suitable locos available. The stock would also have needed power doors and at least some of the seats replacing.

Are DVTs any better than power cars when it comes to safety? They are certainly lighter which could make them more prone to derailing.

Good point, I should imagine the DVT might be easier than a 43.

 

[Bletchleyite]

I would say it's not "reasonably practical" to replace HST's until there is something adequate to replace them.

This is my line, really. Nothing that's about to be available is particularly great as a replacement - it's basically 175s, 222s, or existing 158s and price people off. The latter would not be good at all, and if you pick one of the former they'll end up chucking out filth for far longer than is desirable - there really is a very good case for bi-modes to support the progressive electrification programme as they did so well on GWR, and once it's done you can just conver them to EMUs by removing the engines.

As per the MML I'd not be disastrously opposed to getting an order in for new and temporarily using double 175s or 5/6-car 222 formations if the Unions must; you could do some cheap improvements to both that would bring them up the HST quality bar a bit more engine noise, e.g. in the case of the 222s putting the seats in a Voyager "Coach D" style low density layout and adding large luggage racks. But not long term.

So my view is to put out a tender now but the HSTs stay until that is delivered. Plus the railway should learn from the mistakes of literally none of the "repurpose old junk" projects having really been successful (and there's still time for the last one, the 458s, to go bad! ).

Good point, I should imagine the DVT might be easier than a 43.

I'd imagine a more crashworthy replacement cab could be designed and fitted to an HST, but with them having only between 5-10 years left anyway that's not going to be economic.

 

[bramling]

Or to put it another way, If I owned a business with a fleet of road vehicles of varying ages, I would expect the newer ones to have more safety features than the oldest models. Would I see this as a reason to withdraw the oldest models by itself ?

The thing is, you’re unlikely to be operating a fleet of road vehicles which date back to the 1970s, and not only were designed with essentially zero crashworthiness provision for the driver, but contain a known design weakness which has been known for at least two decades. At the very least, such an undertaking might struggle with recruitment!

Well, at least with the mk1's, they did actually have a replacement fleet.

With this you just know it's going to be, "well, we don't want to build any more diesels, and we can't afford to electrify, so well just scrape together a few units here and there, until there's a proper solution sometime/never"

It'll be Midland mainline HST withdrawal all over again.

Unfortunately you may well be right. The MML HST situation was inexcusable, as there was plenty of time to make provisions for 2020, so one of a number of DFT messes. But there’s no reason why they can’t be on to this one now, there will almost certainly be diesel units available within a matter of months, so it needn’t be a debacle. Sadly based on past history I suspect it will be, but that’s another matter!

 

[yorksrob]

This is my line, really. Nothing that's about to be available is particularly great as a replacement - it's basically 175s, 222s, or existing 158s and price people off. The latter would not be good at all, and if you pick one of the former they'll end up chucking out filth for far longer than is desirable - there really is a very good case for bi-modes to support the progressive electrification programme as they did so well on GWR, and once it's done you can just conver them to EMUs by removing the engines.

As per the MML I'd not be disastrously opposed to getting an order in for new and temporarily using double 175s or 5/6-car 222 formations if the Unions must; you could do some cheap improvements to both that would bring them up the HST quality bar a bit more engine noise, e.g. in the case of the 222s putting the seats in a Voyager "Coach D" style low density layout and adding large luggage racks. But not long term.

So my view is to put out a tender now but the HSTs stay until that is delivered. Plus the railway should learn from the mistakes of literally none of the "repurpose old junk" projects having really been successful (and there's still time for the last one, the 458s, to go bad! ).



I'd imagine a more crashworthy replacement cab could be designed and fitted to an HST, but with them having only between 5-10 years left anyway that's not going to be economic.

The thing is, you’re unlikely to be operating a fleet of road vehicles which date back to the 1970s, and not only were designed with essentially zero crashworthiness provision for the driver, but contain a known design weakness which has been known for at least two decades. At the very least, such an undertaking might struggle with recruitment!




Unfortunately you may well be right. The MML HST situation was inexcusable, as there was plenty of time to make provisions for 2020, so one of a number of DFT messes. But there’s no reason why they can’t be on to this one now, there will almost certainly be diesel units available within a matter of months, so it needn’t be a debacle. Sadly based on past history I suspect it will be, but that’s another matter!

I suppose something like a Meridian or a double 158 might be adequate for replacing the short sets in Cornwall/Scotland. For XC, maybe logo hauling the carriages might be the best option.

 

[Wolfie]

I suppose something like a Meridian or a double 158 might be adequate for replacing the short sets in Cornwall/Scotland. For XC, maybe logo hauling the carriages might be the best option.

Far more likely that XC gets the 221s.

 

[yorksrob]

Far more likely that XC gets the 221s.

As long as there's something to do the North Wales runs in their place.

 

[Bletchleyite]

As long as there's something to do the North Wales runs in their place.

There are 5-car 80x on order for exactly that purpose.

 

[yorksrob]

As long as there's something to do the North Wales runs in their place.

There are 5-car 80x on order for exactly that purpose.

And there's have to be enough to replicate the capacity of the XC fleet being replaced.

 

[hexagon789]

And there's have to be enough to replicate the capacity of the XC fleet being replaced.

Ten 5-car Avanti 221s
Five 7-car CrossCountry HSTs

 

[yorksrob]

Ten 5-car Avanti 221s
Five 7-car CrossCountry HSTs

That's something then.

 

[Nicholas Lewis]

The problem is that the powers that be have dropped a bit of a bollock on this one.

HST cab performance was floated in the Ladbroke Grove report, it didn’t gain focus at the time probably because the report acknowledged that it made no difference to the outcome of that accident. It was also relevant at Ufton, and in retrospect it’s surprising there wasn’t more focus here.

No one seems to have considered the issue when selecting the ScotRail solution, and then unfortunately something has happened which has resulted in the issue gaining a raised profile — not too dissimilar to the issue with sharp curves on tramways, where with the great benefit of hindsight it’s possible to say “why didn’t anyone think of that before?”.

Yes the point about overall risk is well made, but that doesn’t really help if you’re a ScotRail HST driver, or someone responsible for their safety.

In that sense it is fortunate that the likes of the 175s and 222s seem likely to be spare in relatively short order. It’s something which is just going to have to be sucked up I think.

Whilst im supportive of ASLEF over their concerns one wonders what their views were at the time from the previous incidents where the cabs got badly damaged and whether they raised it at safety councils.

They also ought to pushing to get the 777's into use rather than leaving their drivers in 44 year old trains.

 

[43066]

One out of three. The job of writers in rail magazines is not to make rail safer - it's to write stuff that sells magazines. Likewise, rail unions are there to represent their members (well, in theory); it's not primarily about making rail safer.

That’s telling, and perhaps puts things into perspective.

 

[irish_rail]

Funnily enough of every GWR HST driver I've spoken to lately (myself included), not one wants to see HSTs withdrawn. Aslef need to listen to its membership for a change.....

 

[cjmillsnun]

Funnily enough of every GWR HST driver I've spoken to lately (myself included), not one wants to see HSTs withdrawn. Aslef need to listen to its membership for a change.....

Sometimes if it is in the interests of Health and Safety, then it is the responsibility of the union to help push it through, even if unpopular with members.

I'm not sure I even agree with this, it's about proportionality, a word which is being forgotten these days.....
As my signature says exactly how much safer will getting rid of HSTs make train drivers, and how much will that cost ?
Driving a train is a very safe occupation, some people on here appear to be implying that no matter how many millions it costs it may be worth replacing all HSTs if it might save one train drivers life in, say, 10 years. I say that is totally disproportionate. How many of these train drivers are quite happy to drive on the roads where they are many many times more likely to die ? The minute risk of dying in a train crash would not put me off becoming a train driver, esp considering the massive amount of money they get paid.
What we need is some education about risk probability (which is exactly what was missing in the Covid pandemic....) :

Below is a list which was originally printed in the Royal Statistical Society News (Oct 1998) as part of an article by Frank Duckworth. Frank is one half of the pair who invented the Duckworth Lewis scoring system in cricket. The list is an attempt to quantify risk by giving it a “risk number” equating to the probability of death.
These risk numbers vary by an order of magnitude and therefore are a logarithmic scale (e.g. for a risk number of 4 you would be 10 x more likely to die than a risk number of 3). The figures refer to the UK and are for a lifetime's exposure unless a specific time period is given.

0.3 = 100 mile rail journey
1.6 = Destructive asteroid impact (new born male)
1.7 = 1000 mile flight
1.9 = 100 mile car journey (sober middle aged driver)
4.2 = Rock climbing (one session)
4.6 = Homicide (new born male)
5.5 = Lifetime of car travel (new born male)
5.5 = Accidental falls (new born male)
6.3 = Rock climbing (over 20 years)
6.4 = Deep sea fishing (40 year career)
6.7 = Continuing smoking cigarettes (male aged 35: 10 per day)
7.1 = Continuing smoking cigarettes (male aged 35: 40 per day)
7.2 = Russian roulette (one game)
8.0 = Suicide (successful attempt ! )

Yes it's about proportionality.

How much does it cost to maintain 46 year old rolling stock? How is parts availability? How badly has the tin worm affected it? Is a flimsy fibreglass cab suitable?

Is there any existing rolling stock coming available soon that could take over?

It turns out that the 222s will be leaving EMR soon. What's that? Mid life stock? 125MPH capable. Built to modern safety standards? Well why are we keeping these clapped out HSTs then?

 

[skyhigh]

Funnily enough of every GWR HST driver I've spoken to lately (myself included), not one wants to see HSTs withdrawn. Aslef need to listen to its membership for a change.....

I don't know, but I wouldn't be surprised if it was the complete opposite for Scotrail drivers.

 

[irish_rail]

I don't know, but I wouldn't be surprised if it was the complete opposite for Scotrail drivers.

Fine let them have new trains with no doubt poorer legroom and poor visibility from the front, and we will keep the HSTs down here. Dont forget GWR have also lost colleagues to rail crashes, but I don't remember a clamour to remove the HSTs from traffic after those.

 

[Wyrleybart]

Whilst im supportive of ASLEF over their concerns one wonders what their views were at the time from the previous incidents where the cabs got badly damaged and whether they raised it at safety councils.

They also ought to pushing to get the 777's into use rather than leaving their drivers in 44 year old trains.

It would be interesting to hear results of the following surveys :

You are a GWR driver in a train which derails and plunges off a bridge into a ravine.
Would you prefer to be in the cab of
a) HST
b) 150/2
c) 158
d) 166

You are a Scotrail driver in a train which derails and plunges off a bridge into a ravine.
Would you prefer to be in the cab of
a) HST
b) 170
c) 158

 

[Ken H]

It would be interesting to hear results of the following surveys :

You are a GWR driver in a train which derails and plunges off a bridge into a ravine.
Would you prefer to be in the cab of
a) HST
b) 150/2
c) 158
d) 166

You are a Scotrail driver in a train which derails and plunges off a bridge into a ravine.
Would you prefer to be in the cab of
a) HST
b) 170
c) 158

Plunging off a bridge into a ravine is fairly rare.* And will almost always end badly for the driver whatever the train.
Maybe their comfort and day to day work experience is more important to them? I dont know.

*Maybe plunging into ravines would not be an issue if the driver had been instructed to limit speed due to the weather.

 

[the sniper]

Fine let them have new trains with no doubt poorer legroom and poor visibility from the front, and we will keep the HSTs down here.

Are 222s/Voyagers that much worse/different?

 

[Taunton]

I wish any rail company good luck in advancing that argument in Court in the event of civil (or indeed criminal) litigation arising from an accident.

Having actually worked on presenting calculated value for money for prioritising road safety improvements, I can assure you that it is readily understood.

Back to the HSTs, and it looks like we now have come up with yet another of the multiple justifications that the railway seems fixated with for withdrawing perfectly serviceable stock, and thus never being able to get adequate resources for the demand, because there's always some reason for withdrawing stock "by a certain date". There have been a string of these, and their separate reasons, in recent years, as commented on in another thread.

 

[43301]

Back to the HSTs, and it looks like we now have come up with yet another of the multiple justifications that the railway seems fixated with for withdrawing perfectly serviceable stock, and thus never being able to get adequate resources for the demand, because there's always some reason for withdrawing stock "by a certain date". There have been a string of these, and their separate reasons, in recent years, as commented on in another thread.

and frequently blamed on 'EU rules' (in the case of the PRM issues), when in fact the rules didn't stipulate any cut-off data and clearly envisaged that they would gradually come into compliance as fleets were replaced or heavily refurbished. Most countries took a pragmatic view, but not this one where they set a cut-off date well into the future, then left it far too late to replace or upgrade all the stock concerned.

 

[Justin Smith]

It is really though. The job of the writers in rail magazines, of rail unions and of rail accident investigators is to make rail safer. How safe other activities are isn't particularly relevant. Their interest is how to make rail as safe possible (obviously taking into account cost and other factors ).

I can certainly agree with that.

Yes, and it's the 'other factors' that are at play here. It's one of the many examples of 'safetyism' - something which has a very, very minimal impact or none at all in the real world, but those advocating it push really hard for it. And it's definitely the case that Covidianism has increased it in all areas of life - nearly all the Covid "safety" theatre was extreme safetyism, and it's led to a further increase in the idea that all risk has to be banished, no matter how small that risk is in reality.

I agree with this completely.
"Safetyism" has been on the march for about 150 years, and for most of that time it was undoubtedly a positive. But, over that last 20 or so years, it has gone mad. Banning opening windows on trains (even on heritage laines) is the most extreme example of this. But it will get worse and worse because, depressingly, I can see no end to it. If anything the trend is accelerating, people have to start fighting back or Gawd knows where it will end......
What is very worrying is that if someone makes the point that it is not worth doing "x" to save, say, one life a year (because it either costs too much or restricts people's freedoms excessively) they are considered selfish, or insufficiently valuing human life, or some other BS.

You can make all of the philosophical arguments that you want. However, they are absolutely irrelevant when set against the fact that TOCs/FOCs are employers and subject to Health and Safety legislation with respect to their employees. Specifically the principle is ALARP ("as low as reasonably possible") sometimes referred to as SFAIRP ("so far as is reasonably practicable"). The principle is that the residual risk shall be reduced as far as reasonably practicable. All of your guff about the risk to potential passengers who drive instead is completely irrelevant.

It is not "guff"and it is most certainly not irrelevant.
Just out of interest, who do you think should pay the millions of pounds it will cost to get rid of HSTs earlier than is actually necessary ?

The passenger through increased fares or reduced service ? I am a passenger and I do not want to do that, train travel (esp flexible ticket train travel) is already far too expensive.

The train crews through reduced wages (or more accurately smaller increases...) ? Can't see that, the unions might complain about "dangerous" HSTs but they would not want their members to pay for it in any way, hypocrites.

The tax payer ? Why should they ? I'd rather any extra subsidy (because that's what it is) went to improving services for passengers, more services, upgraded faster track, reopened lines, even more service desk open selling tickets, I almost missed my train queueing for my ticket the other day !
I am at more risk dying in my shop of a fall or some other accident than a train driver has of dying in a train accident, so, following your logic if the government paid me a far smaller amount (not tens of millions but a mere few hundred grand would suffice) I could shut my shop and reduce that risk to zero.

Back to the HSTs, and it looks like we now have come up with yet another of the multiple justifications that the railway seems fixated with for withdrawing perfectly serviceable stock, and thus never being able to get adequate resources for the demand, because there's always some reason for withdrawing stock "by a certain date".

Good point, and what about the environment ? Scrapping perfectly serviceable trains is environmentally unfriendly. Same with cars and all other consumer products, repair and keep is more environmentally friendly.

 

[irish_rail]

Are 222s/Voyagers that much worse/different?

Trouble is in GWR land we won't get that. We will get cascaded turbos or 150s whilst the Scots get any decent stuff that is going.

 

[Taunton]

"Safetyism" has been on the march for about 150 years, and for most of that time it was undoubtedly a positive. But, over that last 20 or so years, it has gone mad. Banning opening windows on trains (even on heritage laines) is the most extreme example of this.

I quite agree with you. Banning "unsafe" opening windows followed two particular fatalities. Both of these were occasioned by Network Rail failing to maintain the specified structure gauge, in both cases long term. The real issue was their inability to do so. It's a good cop-out to say that it was the train windows that were unsafe, rather than keeping the lineside trees and signal posts (in these cases) up to spec. I questioned at the time why the much-vaunted Network Measurement Train didn't measure structure gauge clearance, only to be told "that's not what it's for".

 

[AndrewE]

I wish any rail company good luck in advancing that argument in Court in the event of civil (or indeed criminal) litigation arising from an accident.

I would say it's not "reasonably practical" to replace HST's until there is something adequate to replace them.

In the case of the Midland Mainline, the HST's have been removed before there was adequate stock to replace them, precisely because an arbitrary deadline was put in place.

"Safetyism" has been on the march for about 150 years, and for most of that time it was undoubtedly a positive. But, over that last 20 or so years, it has gone mad. Banning opening windows on trains (even on heritage laines) is the most extreme example of this. But it will get worse and worse because, depressingly, I can see no end to it. If anything the trend is accelerating, people have to start fighting back or Gawd knows where it will end......
What is very worrying is that if someone makes the point that it is not worth doing "x" to save, say, one life a year (because it either costs too much or restricts people's freedoms excessively) they are considered selfish, or insufficiently valuing human life, or some other BS.


Good point, and what about the environment ? Scrapping perfectly serviceable trains is environmentally unfriendly. Same with cars and all other consumer products, repair and keep is more environmentally friendly.

"Reasonably practicable" is a term which came in with the HaSaW Act, and is well understood in safety circles: it means that you have to keep making improvements until the additional costs outweigh the benefits. Some chemicals have set exposure limits, others (e.g. some carcinogens which have no lower known safe exposure) used to have Maximum Exposure Limits, where by definition exposure had to be reduced SFRP, and at least down to the limit.

Railways have rails and points interlocked with signalling, so most causes of collisions have been engineered out already. HSTs and most other trains of the last 70 years were well designed and built, and on top of the inherent safety of the railway are going to be a safer way of travelling than almost any road-based mode. I bet more cars and lorries fall apart in use than trains, even with MOT tests. Thus withdrawing rolling stock (which it is not negligent to be running) and having inadequate capacity on the replacements will push people to less-safe modes of transport. Scrapping HSTs is therefore not currently reasonably practicable, full stop.

What has been a problem over the last few decades is people who are not well trained in risk assessment, or who don't properly understand their industry being given safety responsibilities and then issuing edicts attempting to eliminate risk.
It's a tragedy that government is so weak and swayed by lobbies that they can't see things like this - and that they can't do the joined up thinking to consider the embedded energy (carbon) costs of scrapping stuff which is not life-expired.