CER Position Paper on the Social consultation on the revised common safety method on risk evaluation and assessment

CER Position Paper on the Social consultation on the revised common safety method on risk evaluation and assessment

Friday, 4 May 2012

CER has critically and constructively supported the revision of the CSM regulation 352/2009/EC on risk evaluation and risk assessment and its objective to facilitate the access to the market for rail transport services through harmonisation of:     a) the risk management processes used to assess the impact of changes on safety levels and the compliance with safety requirements; b) the exchange of safety-relevant information between different actors within the rail sector in order to manage safety across the different interfaces which may exist within this sector; c) the evidence resulting from the application of a risk management process.

CER believes that the specification of RAC at the correct level has the potential to improve mutual understanding of risk assessment, facilitate EU-wide acceptance of safety demonstration and safety-related equipment, and therefore to reduce cost.
 
CER, together with UNIFE, in order to fully benefit from mutual acceptance across borders, is proposing more detailed risk acceptance criteria for Annex I § 2.5.4. Our proposal is based on internal review and validation amongst our members. CER is asking the European Commission and the European Railway Agency to motivate the concerned but yet silent stakeholders to validate our proposal. The inclusion of a robust set of more detailed explicit risk acceptance criteria with different severity classes as soon as possible is crucial for the CER members reduce cost while keeping the existing level of safety.