DOO and Destaffing Investigation

Our investigation into driver-only operation (DOO) began in 2016, when industrial action to ‘Keep The Guard On The Train’ began on the Thameslink, Southern and Great Northern franchise.

Since that time, we have uncovered vital evidence showing DOO to be a ‘toxic’ and ‘illegal’ policy on accessibility grounds, and successfully lobbied the Equality and Human Rights Commission (EHRC) to step in on the government’s plans to expand DOO nationwide. In 2019, the EHRC established a legal fund to support victims of discrimination on public transport.

In addition to a major investigation into the Department for Transport’s statutory advisors on accessibility (DPTAC), we have published a number of reports previously buried by private industry-led organisations. The following documents put the Rail Safety and Standards Board (RSSB) and the Rail Delivery Group (RDG) firmly in the frame for the cover-up around DOO and station destaffing.

Neither the RSSB nor the RDG are subject to Freedom of Information law, meaning that all DOO policy and research has been developed under conditions of the utmost secrecy; by organisations that are dominated by private interests.

Key documents exposed by ABC:

Michael Woods, Head of Operations and Management Research at the RSSB explains the plan to ‘significantly extend the coverage of DOO to much more of the network, on behalf of RDG and ultimately DfT.’ Upon challenge by accessibility experts from the Chartered Institute of Transport and Logistics (CILT), he argues that ‘having mobile teams of customer service staff…but not one-per train, is the way forward.’ The Chairman of Accessibility at CILT went public with his opposition to DOO in 2017, and we published the email correspondence later that year.

The RSSB report’s primary finding on safety was that DOO ‘may increase the likelihood of an event occurring or increase the severity of its consequence.’ Its cost-benefit analysis for DOO proposes strategies for staff redundancies and deskilling (page 48-57). We published the report in 2016, following a Private Eye expose.

In June 2017, we published a buried report on accessibility, commissioned by the Rail Delivery Group in 2015. ‘On Track for 2020’ raises urgent concerns about the threats posed to accessibility by DOO and destaffing, and warns that unstaffed trains running through unstaffed stations will be a breach of the Equality Act. We exposed the Rail Delivery Group live on multiple BBC channels, and the entire episode was written up in the House of Commons library (pages 19-22). The Rail Delivery Group published the report on their website a few days later.

In 2018, the Rail Delivery Group commissioned the consultancy Steer to provide guidance on implementing DOO on the railway network. After learning that DPTAC had called the report ‘wholly inadequate’ and ‘to be approached with extreme caution’, we chased the report through Freedom of Information requests for months. Finally, Lilian Greenwood forced the DfT to publish the report – as her final act as Chair of the Transport Select Committee. In failing to provide any acceptable mitigation for DOO, the Steer report proved that a full staffing model is the only solution.

Our campaign to make the RDG and RSSB subject to Freedom of Information law continues. For more information, email:

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