CSM (Common Safety Method)

Commission Implementing Regulation (EU) No 402/2013 of 30 April 2013 on the common safety method for risk evaluation and assessment and repealing Regulation (EC) No 352/2009 sets the Common Safety Method (CSM) for the evaluation and assessment of risks arising from changes to the railway system in an EU Member State.

It assigns entities (in particular railway undertakings - RUs, infrastructure managers - IMs, entities in charge of maintenance - ECMs, contracting entities or designated bodies, applicants for placing in service of a structural system) to apply a risk management process to the introduction of any changes to the railway system of a Member State under certain conditions.

The aforementioned entities (generally referred to as proposers) are required to prepare a proposer's safety declaration.

The risk management process is a method to apply this Regulation in its entirety and is defined in Annex I to the consolidated version of Regulation (EU) No 402/2013.

The Regulation covers technical, organisational and operational changes on national a regional railways.

Currently, the CSM has to be approached from two different perspectives, which both mutually overlap and contradict each other in some aspects:

1. application of the CSM in the full scope of the Commission Regulation (EU) No 402/2013, hereinafter referred to as the CSM, within the scope of the significant change institute, including all Annexes 1 - 3 (applicable to all subsystems)
2. application of Commission Regulation (EU) No 2018/545 Article 13 "Requirements capture" (applies only to the RST and CCO subsystem - i.e. to all types of rolling stock), see clarification note ERA1209-146 about requirements capture

In terms of our safety system it is therefore necessary to distinguish whether the common safety method (CSM) applies to a change

• of a technical nature (mostly related to the INF, ENE, CCS, RST subsystems)
• of an operational nature (mostly related to the OPE, MAI, TA subsystems)
• of an organisational nature (mostly related to OPE, MAI, TA subsystems)

and which of the two will be followed:

*) The control-command and signalling subsystem ("CCS") is divided into control-command trackside (CCT) and control-command on-board (CCO).

Therefore, in terms of rolling stock (which consists of a maximum of two subsystems - RST and CCO) the following applies:

As shown in the following figure, the safety assessment represents an ERA's attempt to gradually suppress the institute of "significance of change according to Article 4 of the CSM" and replace it with the newly introduced institute of "requirements capture".

The basic difference is that, using the requirements capture method, it is always necessary to provide a safety assessment report, regardless of the safety relevance of the change implemented and defined by the proposer. This means that an independent assessment (i.e. Safety Assessment Report) by an accredited/recognised assessment body must always be included as part of the authorisation process.

This implies that the ERA is progressively phasing out the option which is given to proposers by the CSM Regulation and which allows them to split the changes made to rolling stock into one of the following categories:

• a change having no impact on safety (Type B)
• an insignificant change (Type C)
• a significant change (Type D)

Instead, it requires the implementation of the 'Requirements Capture' procedure, both in terms of the change they are making and of the overall safety level of the vehicle.

This issue is addressed by the "Requirements Capture" programme developed by the Rail Authority which is freely available here on the CSM portal on page Procedure under Regulation No 2018/545.

The clarification note ERA1209-146 about requirements capture mentioned above requires that the safety assessment report, which is, according to Article 6 and Article 15 of the CSM Regulation, only produced for a change categorised by the proposer as significant, should now always be supplied as part of the VA (Vehicle Authorisation) process.

In simple terms, it can therefore be stated that whenever any requirement or aspect is captured under Article 13 of Commission Regulation (EU) No 2018/545, one should now follow the well-known procedure under Annex 1 to Commission Regulation (EU) No 402/2013 (i.e. identify the hazard and worst-case risk scenario from this captured requirement/aspect and control the risk to an acceptable level).

The ERA clarification note ERA1209/146 about requirements capture, V1.2, chapter 2.3.6, paragraph two explains:

Elements, such as system definition, identification and specification of requirements, implementation of requirements, and demonstration of compliance, are the fundamental elements of every requirements capture process and can be applied to address requirements capture for all essential requirements described in Annex III of Directive (EU) 2016/797.

However, some adaptations are necessary, as the risk assessment process as defined in the CSM RA cannot be directly applied to requirements other than safety requirements (e.g., using a hazard record is not suitable for essential requirements other than safety, although the underlying principles are similar). 

The Rail Authority is aware of this difference. However, as it is not yet clear what adjustments should, according to the above paragraph, be made to the process method for the Requirements Capture in terms of essential (other than safety) requirements, it will accept the application of the risk management process as per Annex 1 to Commission Regulation (EU) No 402/2013 to all essential requirements as listed in Annex III to Directive (EU) 2016/797 as part of the consistency of the whole proposed system.

On the contrary, the Rail Authority recommends applying Annex 1 to Commission Regulation (EU) No 402/2013, as the individual assessment bodies (AsBo) are also accredited/recognised and fully proficient in this method and can be expected to achieve the best currently achievable results in the new assessment system.

The above information shows that the application of the common safety method to rolling stock necessitates using the procedure under Commission Regulation (EU) No 2018/545. In other cases, Commission Regulation (EU) No 402/2013 remains fully applicable. For this reason, it is necessary to select the right procedure (see the following links):