Request ID: FOI-4801-2324 Date published: 23 April 2024
You asked
Dear Transport for London,
Unmanned Underground Station risk assessment
Please could you provide me with :-
Your risk assessment for unmanned underground stations.
Procedures for unmanned stations
If your public liability insurance covers stations that are unstaffed.
We answered
TfL Ref: 4801-2324
Thank you for your request received by Transport for London (TfL) on 28 March 2024 asking for information about unstaffed London Underground stations.
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 some of the information you require. You specifically asked:
Please could you provide me with :- Your risk assessment for unmanned underground stations. Procedures for unmanned stations If your public liability insurance covers stations that are unstaffed.
Customer and workforce risk assessments are hazard based rather than activity based so would cover the hazards that customers and colleagues are exposed to across their journey on London Underground therefore there isn’t a specific risk assessment for unstaffed stations. It is also worth noting the availability of customer help points on most of our stations for customers who need help.
All London Underground stations are rostered to be staffed during operating hours. Stations located underground have specific staffing requirements and minimum staff numbers, which vary depending on the size of the station. This is a fire regulation requirement arising from the King's Cross fire in 1987.
While there is no regulatory or legal requirement for London Underground's above ground stations to remain staffed when services are operating, we continue to plan to staff all stations at all such times. Sometimes operational requirements may mean that some above ground stations become unstaffed temporarily, for example when an incident occurs elsewhere on the line and the assistance of another member of staff is required. During these times the gates are temporarily left open, and the station remains safe to operate. After all attempts to staff a station are exhausted, neighbouring stations and the controller are informed the station will be unstaffed. This only ever relates to above ground stations. We aim to minimise closures as far as possible and strive to always exhaust all avenues before making the decision to close a station. However, on some occasions it is unavoidable, and due to safety regulations we may not have the option of having certain stations remaining open without staff.
We review staffing levels regularly to avoid stations being unstaffed. Stations would only be left unstaffed or closed after exhausting the use of overtime, requesting support from staff from other stations or our Special Requirements Team.
In terms of procedures, we confirm that we hold the information you require however, this information is exempt from disclosure under sections 24 (National Security) and 38 (Health and Safety) of the Freedom of Information Act. The procedures are internal documents designed to be used by operational staff in the running of the London Underground. The documents detail various rules, instructions, protocols and procedures which LU operational staff are governed by. This material would be of use to any persons wishing to disrupt London’s transport infrastructure by placing into the public domain information which would otherwise not be available via other means. Whilst we make no suggestion that you would use this information for anything other than you own interest, disclosure of information under FOI has to be regarded as a disclosure to the public at large. As you will no doubt be aware, the transport system in London has been the target of attacks in the past. The information requested contains sensitive information about the operation of the network which could be of use for anyone seeking to research or plan for such an attack or to actively cause disruption to the network. Further, there is no meaningful way in which the material can be redacted. While some sentences or passages may appear innocuous in isolation, taken together across the suite of documents it would still allow somebody to build up a detailed picture of operational processes and the language used in the operation of the network.
The Information Commissioner’s Office has previously issued a Decision Notice regarding the application of sections 24 and 38 to withhold information in relation to security at transport hubs. Whilst the information requested in this case is different to the information you have requested, we believe the same arguments can be applied:
The use of the section 24 and 38 exemptions are subject to an assessment of the public interest in relation to the disclosure of the information concerned. We recognise the need for openness and transparency by public authorities and acknowledge that there may be some interest in the information in question - as evidenced by the fact that you have requested it. However, as we believe this information could potentially be obtained and utilised by individuals who may wish to use it to cause disruption or harm to London’s transport infrastructure, in this instance we believe that minimising the risk to that infrastructure and protecting the safety and welfare of members of the general public and our staff outweighs the limited public interest in disclosure.
TfL’s public liability insurance provides cover for legal liability arising out of TfL’s operations in the UK, whether those operations are on staffed or unstaffed stations. As with most insurance policies, there are some exclusions however none of those relate specifically to unstaffed stations.
We will continue to monitor the level of staffing across the network to ensure that customers are kept safe and receive the best possible level of service and assistance at all times.
If this is not the information you are looking for, or if you are unable to access it for any reason, please do not hesitate to contact me.
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
Sara Thomas FOI Case Management Team General Counsel Transport for London
