Request ID: FOI-0256-2324 Date published: 23 May 2023
You asked
Dear FOI team,
I was guided to approach you by xxxxx from MyHRData. My request is simple and deals with items readily available on the intranet.
I would like to have copies of the following:
1. The TfL’s medical redeployment policies and guidance valid between August 2022 and April 2023.
2. Any other TfL’s redeployment policies and guidance valid between August 2022 and April 2023.
3. TfL’s Category 1 Standard S1069 – Low Voltage Electrical Installations. All the versions valid between March 2022 and April 2023.
4. TfL’s Category 1 Standard S1066 – Lighting of London Underground Assets. All the versions valid between March 2022 and April 2023
5. All the Depot Maintenance Unit’s Risk Assessments active between March 2022 and April 2023.
6. All the Depot Maintenance Unit’s work instructions and method statements active between March 2022 and April 2023.
For the points 1&2 my main focus is on the policies in place to deal with the London underground’s employees. For 3&4 I need the standards in connection with the London Underground assets. For 5&6 my main focus is on documents pertaining to the electrical works. Please do not hesitate to contact me if you have any questions.
I look forward to receiving your answer and confirmation that this email is being actioned.
We answered
TfL Ref: FOI-0256-2324
Thank you for your request received by Transport for London (TfL) on 24th April 2023.
Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy.
I can confirm that we hold the information you require. Your questions are answered in turn below: Questions 1 and 2: I would like to have copies of the following: 1. The TfL’s medical redeployment policies and guidance valid between August 2022 and April 2023. 2. Any other TfL’s redeployment policies and guidance valid between August 2022 and April 2023. Answer: Please see the two documents attached. Questions 3-6: 3. TfL’s Category 1 Standard S1069 – Low Voltage Electrical Installations. All the versions valid between March 2022 and April 2023. 4. TfL’s Category 1 Standard S1066 – Lighting of London Underground Assets. All the versions valid between March 2022 and April 2023 5. All the Depot Maintenance Unit’s Risk Assessments active between March 2022 and April 2023. 6. All the Depot Maintenance Unit’s work instructions and method statements active between March 2022 and April 2023. Answer: I am afraid that the information is exempt from disclosure under section 14 of the Freedom of Information, which can apply where the impact of a request on a public authority cannot be justified. The following guidance from the Information Commissioner on the use of the exemption provides more detail:
The exemption applies in this instance because of the large amount of information covered by these questions. Questions 3 and 4 constitute two documents totalling over 100 pages. Question 6 alone covers around 140 documents, some of which are well over 10 pages long. Even at a conservative estimate of 5 pages per document, this amounts to 700 pages. Question 5 adds further material. In order to release this information we would need to review it all page by page to see if there is any information that should be exempt from release. For example, having discussed the matter with colleagues in London Underground I understand that there is likely to be some information that is commercially sensitive, and some technical information about operations may be exempt under the National Security and / or the Health and Safety exemptions, if it would be of use to those looking to attack or disrupt the network (noting that release of information under FOI is considered to be to the world at large rather than the individual applicant). The process of reviewing over 800 pages of material would not be a straightforward or quick task, and would require collaboration among different colleagues to complete (for example, those with FOI expertise and those with more knowledge of the subject matter). As you can see above, the guidance from the ICO on the use of the exemption includes the following advice:
“You should consider using it if, after taking account of all the circumstances, you believe the request is disproportionate or unjustified.”;
“The ICO recognises that dealing with unreasonable requests can strain resources and get in the way of delivering mainstream services or answering legitimate requests”;
And;
“The key test is to determine whether the request is likely to cause a disproportionate or unjustified level of disruption, irritation or distress. A useful starting point is to assess the value or purpose of the request before you look at the impact handling the request would have on you”.
We consider that the amount of resource that would be required to fully and appropriately review this material would represent a disproportionate effort, requiring the re-allocation of already limited resources and placing an unacceptable burden on a small number of personnel. Further, whilst we appreciate your personal interest in the subject matter, we do not see any particular wider public interest that would justify the allocation of the necessary resource. We therefore believe that it is reasonable for section 14(1) to apply and forthis part of your request to be refused on that basis.
Of course, you may wish to submit a revised request, narrowing its scope to focus on the information that is of most importance to you. If you do so I would advise that you make it as specific as possible. So for example, I appreciate that for your current questions 5 and 6 you stated that your “main focus” was in relation to “electrical works”. This is a very broad / vague request, and any reframed request should state explicitly what information you require, citing actual documents where possible. You may also wish to ask specific questions rather than submitting a ‘catch all’ request if you are unsure exactly what information exists.
Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.
Yours sincerely,
David Wells FOI Case Officer FOI Case Management Team General Counsel Transport for London
