Draft Disabled People's Protection Policies (DPPPs)

prepared during autumn 2002

6. Management Arrangements (Section 9 of the Guidance)

9.1 The provision of services for disabled passengers should not be perceived as a bolt-on to a licence holder's core business interest, but as an integral part of a railway business activity. A Director within the licence holder's company must be allocated responsibility for the DPPP. A DPPP must have a statement of management arrangements which will show:

6.1 Most operators answered this section well but a substantial number did not name the responsible director or just named the Managing Director which, unless very small organisations, would not really be practical.

(a) that the DPPP is integrated into both business plans and the planning stage of projects;

6.2 Those policies that included a management statement generally included this point. We believe it is essential that this point is made explicit and thought through effectively.

6.3 Integrating the Policy into the business plans and planning of projects will help ensure the railway moves towards a more inclusive environment. It will also help to turn the Policy into a 'live' document.

(b) the senior management arrangements for implementation of the DPPP; including how they are cascaded down

6.4 With a few notable exceptions this was poorly answered. Whereas many mentioned their induction programmes for staff, little mention was made of training for managers and budget holders, who because of their influence within the company, need such knowledge to enable the Policy to be properly integrated within company operations.

6.5 It is the senior management who set the framework under which the Policy will be integrated and implemented into the work of other staff. They need to buy into its implementation and enable the effective delivery of the Policy.

(c) how managers and staff are made aware of their responsibilities to disabled passengers

6.6 As above, most mentioned staff training at induction but very few mentioned management. Without management training on the relevance to their roles it is unlikely that the Policy will influence the framework under which improvements for disabled passengers are taken forward.

6.7 There was also a concern that although many mentioned induction training on disability awareness it was not highlighted for existing staff or as part of an on-going programme.

(d) that systems are in place to ensure that the provision of services for disabled passengers are not overlooked, e.g. when new projects are being planned;

(e) that systems are in place for assessing the costs and financial benefits of improvements for disabled passengers

6.8 There were very few policies covering this point which was disappointing. It is essential that systems are included if operating companies are to provide effective services for disabled people. This exercise could save operators valuable money by making sure resources were spent effectively and lessons learnt for future projects.

6.9 We would recommend the responsible Director being a champion for access and disability training issues who would benefit from such systems and the feedback they would provide.

6.10 Too often access for disabled people is only seen as a cost with no benefit. The improvements in service benefit all passengers and produce savings.

6.11 Systems for assessing such costs and benefits should be developed but consider the whole-life costings of improvements. The SRA should consider leading the development of such costings and addressing concerns about returns on investment if franchises change hands.

(f) that procedures are in place for liasing with relevant industry organisations for ensuring action is taken jointly where necessary;

6.12 This process has demonstrated a pressing need for the industry to be more open and engage with relevant industry and passenger organisations to address issues of concern to both operators and passengers.

6.13 Most operators made a commitment to engage with existing procedures, however operators need to commit to co-operating with each other if they are to make the best use of existing facilities in delivering services for disabled people. The SRA's new franchising policy requires operators to focus on delivering services rather than rely on enhancements.

(g) that training for staff and managers as set out in Section B1.1 in the code of practice is included in the overall training programme to enable them to meet the needs of disabled passengers and that details of timetables for training, including the numbers of staff who have received training, will be reported annually to the Authority;

6.13 To be effective, especially until numbers of disabled people travelling builds up, staff should receive on-going training, not just induction training where realistically people are so bombarded with information it is likely to be ineffective.

(h) how compliance with the DPPP will be overseen; and

(i) that annually, and more frequently if appropriate, the Authority receives a report detailing any difficulties which have been experienced with the DPPP and progress towards achieving the objectives within it.

6.14 This is the critical section of the Policies for many disabled people who have seen many policies and plans that have not had any impact. This round of Policies must be implemented if the system is to have any credibility with disabled people.

6.15 We believe that the SRA needs to have effective enforcement capabilities and report on compliance itself.

6.16 Most operators included reference to an annual report to the SRA but few mentioned progress in that report. South West Trains included plans for monitoring compliance including 6 monthly reviews of the policy. Without some monitoring, the mention of a 'live' document is meaningless.

Published: 17 February 2003

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