SOO Waivers

August 23, 2018

Many of you will know that we have had serious concerns with LULs wildly dangerous interpretation of the SOO waiver process .

 

This ended up as a compliant to the ORR .

 

There have been some developments which robustly back up our argument on the criteria of the waiver.

 

The ORR have stated the following in correspondence with LUL ( see below ) .

 

* waivers must be issued on safety grounds .

* waivers must be issued if the rule being waived is less safe than the waiver

* waivers can’t be issued on the grounds of reputational damage

* waivers can’t be issued on the grounds of customer service.

 

There is still work to be done on the issue of waivers and stations CCEP which us and TSSA are currently putting together .

 

Attached is the letter from LUL in response .  They are evidently not happy and are looking to fight it .

 

We will be writing to the director of safety in the next 24 hours , setting out our position in light of the ORR.

 

Many of you will know that we have had serious concerns with LULs wildly dangerous interpretation of the SOO waiver process .

 

This ended up as a compliant to the ORR .

 

There have been some developments which robustly back up our argument on the criteria of the waiver.

 

The ORR have stated the following in correspondence with LUL

 

* waivers must be issued on safety grounds .

* waivers must be issued if the rule being waived is less safe than the waiver

* waivers can’t be issued on the grounds of reputational damage * waivers can’t be issued on the grounds of customer service.

 

There is still work to be done on the issue of waivers and stations CCEP which us and TSSA are currently putting together .

 

Attached is the letter from LUL in response .  They are evidently not happy and are looking to fight it .

 

We will be writing to the director of safety in the next 24 hours , setting out our position in light of the ORR and will cover this for all functions . John – I will send this to you first .

 

 

ORR SOO Waiver August 2018

 

 

 

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