Working near the railway: how CDM 2015 applies

The regulations do not change

The Construction (Design and Management) Regulations 2015 apply to works near the railway in the ordinary way. The client appoints a principal designer, and a principal contractor where more than one contractor is involved. Duty holders must plan, manage and monitor the work. Information has to flow between the client, the designers and the contractor. None of that is different because there happens to be a railway on the other side of the fence.

What is different is what a proportionate response to the risk looks like.

The interface risks

Working next to an operational railway adds a specific set of hazards that a standard site plan does not address:

• Moving trains. The line stays open. Anything that can encroach on it — a load, a piece of plant, a person, a collapsing excavation — is a hazard with consequences well beyond the site boundary.
• Overhead line equipment. Electrified lines carry live conductors overhead. The exclusion distances are not intuitive and the consequences of getting them wrong are immediate.
• Conductor rails. On third-rail routes the hazard is at ground level, which changes how access, deliveries and any work at the boundary have to be planned.
• Restricted access. Work at or over the boundary often cannot be done at will. It happens in booked windows, sometimes at night, and the window closes on time whether or not the work finished.
• Night working. Which brings its own fatigue, lighting, noise and supervision considerations.

Those risks need to be reflected in the design risk management and in the construction phase plan. Reflected, not appended: the point of CDM is that risk is designed out where it can be, and only managed on site where it cannot.

Designing it out

A good deal of railway interface risk is a design decision in disguise. Where the crane stands, and therefore whether it needs to oversail railway land at all. Whether the foundation solution requires piling close to an embankment or can be arranged to avoid it. Whether the drainage strategy sends surface water toward the railway. Whether the scaffold can be erected and struck without working over the boundary. Whether the façade can be built from within the site.

Each of those is easier and cheaper to resolve on a drawing than on site, and each is a design risk management question that belongs in the principal designer's remit. Raising them late does not remove them; it just removes the options.

The construction phase plan

A construction phase plan for a rail-adjacent scheme should be recognisably about that scheme. Generic text about working near railways is not much use to anybody. What is useful is a plan that identifies the specific interfaces on this site, states the controls, and is honest about the sequences where the risk is highest.

It should also align with what has been agreed with Network Rail. Where an asset protection agreement is in place, its conditions and the construction phase plan need to say the same thing. Where they diverge, the divergence tends to be discovered at the worst possible moment.

Competence and site staffing

CDM requires duty holders to have, or to secure, the skills, knowledge and experience appropriate to the work. On a rail interface that means people who understand the environment — not only general construction safety, but how railway access works, what the exclusion requirements are, and what a Network Rail representative will expect to see.

Where the work involves access to railway land, or work adjacent to a live line, there are competence and certification requirements attached to the individuals involved. Planning the work without confirming that the people are in place to do it is a common and avoidable programme risk.

Glare, lighting and the things that are not obviously safety

Not every railway safety consideration looks like a construction hazard. A glare assessment considers whether reflective surfaces such as glazing, cladding or solar panels, or new external lighting, could distract a train driver or make a signal harder to read. Network Rail may ask for one where a development overlooks the railway, particularly close to signals, and local planning authorities sometimes attach one as a planning condition.

That is a permanent-works safety issue rather than a temporary-works one, but it arrives through the same conversation, and it can affect material and façade choices. Like most things on this list, it is best identified before those choices are made.

The practical summary

Treat the railway as a live interface from the first design meeting rather than as a boundary condition discovered during pre-construction. Get the interface risks into the design risk information. Make the construction phase plan specific. Confirm competence before you plan around it. And keep what you have told Network Rail and what you have told your own site team in the same document set.