DOO and Destaffing Investigation

Our investigation into driver-only operation (DOO) started in 2016, when industrial action to ‘Keep The Guard On The Train’ began on Govia Thameslink Railway.

Since that time, we have uncovered extensive evidence proving DOO to be a toxic and illegal policy, 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 long running 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.

Our archive proves that operational guidance, as well as safety and accessibility policy, are being developed behind closed doors; without consultation or any publicly-available equality impact assessments. Neither RDG nor the RSSB is subject to freedom of information law, the public sector equality duty, or regulation by the Office of Rail and Road.

Key documents exposing the RDG:

  • June 2022 – The ‘secret plan’ to close all 980 ticket office in England

In June 2022, the rail industry’s secret plan to close or “repurpose” all ticket offices was revealed in a Sunday Times article, which was deleted after it went viral on social media. It is archived here. The RMT union first publicised the news in May 2022.

In 2018, the Rail Delivery Group commissioned the consultancy Steer to develop accessibility 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 MP forced the DfT to publish the report – her final act as Chair of the Transport Select Committee. In failing to provide any mitigation for DOO, the Steer report showed that a full staffing model is the only solution.

In June 2017, we published a buried report on accessibility, commissioned by the RDG. 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 breach the Equality Act. We exposed the RDG live on multiple BBC channels, and the entire episode was written up in a House of Commons research briefing (pages 19-22). The RDG published the report on their website a few days later.

The RSSB report’s primary finding on safety is 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.

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 Logistics and Transport (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.

For more information:

[This page remains under editing as new documents are revealed. It was last updated on 13/08/2022]

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