Reflecting on the Safety Management System (SMS) Determination: Is It Time to Review Railway Safety Permit Requirements?

By Sma Ngcamu-Tukulula (Smart Ergonomics Managing Director and Certified Human Factors/ Ergonomics Specialist)

Managing Railway Safety

The safety of railway operations in South Africa is high on the agenda for the Railway Safety Regulator (RSR) and railway operators alike. While the strategies for improving railway safety may often center around railway occurrences, it is becoming increasingly apparent that railway safety cannot only be limited to the absence of occurrences or only focus on compliance-driven safety initiatives. Instead, evidence suggests that the effective management of safety requires a more holistic approach where safety transcends the need to avoid undesirable events, while also focusing on creating organisations that are resilient to dynamic risks and complex changes across the system. In line with this, local and international best practices and case studies support the need for the systemic management of safety through the development and implementation of safety management systems (SMS).

What is the SMS Determination and what is it used for?

From a legal perspective, the National Safety Regulator Act 16 of 2002 requires that all railway operators must have a safety management system in place. It defines an SMS as a “framework for integrating safety into day-to-day railway operations and includes safety goals and performance targets, risk assessment, responsibilities and authorities, rules and procedures, monitoring and evaluation processes and any other matter prescribed”. Through the requirements set out in the same Act, the SMS Determination was developed, and provides detailed guidelines on the format, form, content of a railway operator’s SMS as well as the form, content and manner of submission of a safety management system report.

Since its introduction in May 2018, the SMS Determination has been used by railway operators when applying for a new safety permit or renewing an existing one. Furthermore, the SMS Determination requires railway operators to document and submit a written report that describes the organisation’s SMS; namely the SMS Report (SMSR). The SMS Determination is also used by the RSR when developing tools for assessing permit applications, such as the Safety Permit Conformity Assessment Methodology (SPCAM), and to formulate safety oversight protocols to monitor the implementation of SMS requirements by railway operators once they have been granted a permit.

Railway SMS Review

The SMS Determination has arguably been pivotal in consolidating safety permit application requirements and more clearly defining the requirements for the systemic management of railway safety across operators’ systems. However, being a new document, there are likely gaps that need to be addressed. It is also likely that the users of this document can share insights into some of the challenges in using this document as well as opportunities for improving the management of railway operations. As such, four (4) years since the publication of the SMS Determination, it is prudent for our industry to reflect on the extent to which this document still supports railway operators in safely executing their business, while also enabling the RSR to oversee the safety of railway operations. In lieu of this, the RSR is reviewing the SMS Determination and all its associated documents, including the SMS Report and the Safety Permit Conformity Assessment Methodology (SPCAM).

The South African railway landscape has changed over the last four years due to changes in the regulatory landscape, the COVID-19 pandemic, and socioeconomic ills leading to further encroachment into the railway reserve and the decimation of railway infrastructure. These changes have contributed to diminished capacity to deliver reliable and safe railway operations. Positive changes have also been observed where some railway operators have expanded their operations while others have introduced more advanced technologies and rolling stock. Existing operational conditions, together with numerous other changes that are typical of complex railway systems, have implications for the safety of railway operations and SMS requirements by extension. Consequently, some of the aspects that will be explored in the review of the SMS requirements will include exploring the following questions:

  • Are the elements that operators have to incorporate into their SMS suitable for different kinds of operators?
  • To what extent do the SMS Determination requirements assist operators in managing railway safety in practice
  • In its current form, do the prescribed SMS requirements adequately enable railway operators to comprehensively capture and document their safety management systems as they truly are in practice?
  • Are there better perspectives of railway safety and approaches for managing railway risks that could be integrated into the SMS Determination requirements?
  • Are the current methods and tools used to review operator permit applications and safety management systems effective for evaluating organisations’ ability to manage railway risks?
  • To what extent do the current SMS requirements enable or restrict railway operators from exercising their prerogative to manage railway risks in more effective ways that may not be aligned to the SMS Determination requirements?

Call for Industry Participation

The RSR is adopting a participatory approach and is calling for the South African railway industry players to be active participants and contributors to reviewing railway SMS requirements. Operators can be involved in various ways, including participating in the industry survey, workshops, and the industry working group. Project details and progress updates will be communicated periodically through the RSR website ( and social media pages. Additionally, railway stakeholders may contact the RSR project manager, Muziwandile Masango ( or the project team leader of the appointed service provider that is partnering with the RSR on this project, Sma Ngcamu-Tukulula ( for further information or project-related queries.

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