The Office of Rail and Road have confirmed that all gateline and other customer-facing station staff, including agency staff, must be trained in ramp provision.
Where disabled passengers experience problems due to the lack of said training, they can demand thousands in compensation for every incident.
The Problem
Often station staff won’t deploy boarding ramps. This is a problem for me with delay, uncertainty, stress and pfaf getting the guard to do it.
It is much more of a problem on trains without guards.
Office of Rail and Road opinion
My interpretation is that this shouldn’t happen. Every staff member who interfaces with the public, including agency gateline staff, must be ramp trained.
So I asked the Office of Rail and Road. They have made the position clear in an email to me today.
Thank you for your emails of 1 and 17 April, where you raised questions about whether Gateline staff, including those who are agency staff, should be trained to deploy wheelchair ramps for trains.
You have identified the relevant sections of the ATP guidance. All frontline staff that interact with passengers should be trained to deploy wheelchair ramps and, where reasonably practicable, training should also be provided to frontline agency staff and frontline staff contracted on a temporary basis.
You may be interested to know that, to support us in monitoring compliance, from 1 April this year, we have started collecting data from operators on their delivery of disability awareness training (which includes ramp deployment) as part of our core data requirements.
Couldn’t be clearer, really. Disgraceful that many train operating companies, including Northern and SouthEastern, make no effort at all to train gateline staff to operate ramps – with the result Christiane experienced as above, as do so many of us.
Train Operating Companies Don’t Comply
Northern said to me in a Freedom of Information Response:
Ramp training is provided to conductors, dispatchers and ticket office staff that provide platform duties. It is not provided as part of gateline training, as gateline staff are not responsible for ramp deployment as part of their normal role.
The ORR are now watching Northern:
You raised particular questions about Northern’s conduct. As you may be aware, we are already in regular discussions with Northern regarding the actions they have committed to take to improve the reliability of their assistance provision. We have now raised questions on their training for frontline staff as part of that ongoing engagement.
Why are so many train operating companies breaking their licence conditions by making no effort to train gateline staff how to deploy wheelchair ramps? Do they not care about the uncertainty and distress this causes to wheelchair users, particularly where Driver Only Operation is in effect? And why hasn’t the ORR noticed and taken action before?
The regulations are clear. Any frontline staff member who interacts with passengers as part of their job must be trained to deploy ramps, amongst other things.
Discrimination
If the lack of ramp training of station staff causes a disabled person a problem on a journey, I think it is pretty clear that the station operators has discriminated against the disabled person contrary to the Equality Act. They’ve failed to provide an auxiliary aid or service, contrary to Section 20 of the Equality Act.
I would encourage the Passenger to complain to the company and to demand compensation in the form of thousands of pounds for each individual incident. Should the company not cough up, I recommend appealing to the Rail ombudsman.
Given the companies clearly don’t care about the impact their breach of licence has on disabled customers, perhaps being hit in the pocket will act as an incentive instead.
The Regulations
Here’s the nitty gritty. All train and station operators must have an Accessible Travel Policy (ATP) that complies with the ORR’s ATP Guidance. They have to do so as part of their licence to operate train services in Great Britain (Condition 5 of the Station Licence and GB Statement of National Regulatory Conditions: Passenger).
Section B6.1 of the Guidance includes:
Operators must make the following commitments in their Accessible Travel Policy in relation to staff training, setting out a plan for how these commitments will be delivered: …
b. all frontline staff that interact directly with passengers at any time as part of their duties must, as part of their induction, receive training that delivers mandatory training outcomes 7, 8 and 9 as set out in Appendix D. …
f. where reasonably practicable, agency staff and staff contracted on a temporary basis that interact directly with passengers at any time must receive a condensed version of the disability awareness training or disability equality training, to deliver as a minimum mandatory training outcomes 6 (Passenger Assist), 7 (Communication) and 9 (Providing safe assistance) as set out in Appendix D.
(original emphasis)
Appendix D states:
9. Providing safe assistance
Staff are made aware that it is their duty to ensure that both staff and passengers remain safe at all times. They are able to:
a) Identify and deploy the correct ramp safely for boarding and alighting
b) Transport a passenger safely, correctly and comfortably in the station wheelchair
c) Correctly guide a blind or visually impaired person
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