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Transport for London

London Underground

Categ o ry 1 Stan d ard

S1642 The Management of


Temporary Approved
Non-Compliance
(TANC)

Issue date: April 2013


Issue No.: A7 Review date: April 2018

MAYOR OF LONDON --```,`,,,`,,,````,,,````,````,`-`-`,,`,,`,`,,`---

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Title: The Management of Temporary Approved Non-Compliance (TANC)
Number: S1642
Issue no: A7
Issue date: April 2013

Contents
1 Purpose ___________________________________________________________________ 3
2 Scope ____________________________________________________________________ 3
3 Requirements _______________________________________________________________ 4

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3.1 Compliance with Standards _______________________________________________ 4
3.2 The Management and Control of Temporary Non-Compliance _____________________ 4
3.2.4 TANC Accountable Managers (TAM) ________________________________________ 5
3.3 Process for the Management of TANC _______________________________________ 8
4 Responsibilities _____________________________________________________________ 8
5 Supporting information ________________________________________________________ 8
5.1 Process for the management of TANC _______________________________________ 8
6 References _______________________________________________________________ 10
6.1 References __________________________________________________________ 10
6.2 Abbreviations _________________________________________________________ 10
6.3 Definitions ___________________________________________________________ 10
6.4 Person accountable for the document ______________________________________ 11
6.5 Document history ______________________________________________________ 11

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Title: The Management of Temporary Approved Non-Compliance (TANC)
Number: S1642
Issue no: A7
Issue date: April 2013

1 Purpose
1.1 This Category 1 Standard describes the steps to take to permit non-compliant assets
to temporarily remain in service and provide the appropriate compliance
documentation.

1.2 The aim of this Standard is to ensure that all discovered or introduced non- compliant
assets that are allowed to temporarily remain in use are covered by a Temporary
Approved Non-Compliance (TANC) Management Plan. The TANC Management Plan
(described in clause 3.2) ensures that all tolerable safety risk is assessed and
managed through timely and appropriate controls / mitigation at a level that is as low as
reasonably practicable.

1.3 To ensure that only staff that have been assessed and recorded as competent via a
competence management system or by holding an appropriate Safety Critical License
undertake the role of a Temporary Approved Non-Compliance Authorised Persons
(TAP) to permit non-compliant assets into service subject to risk assessment and a
management plan to reduce risk to as low as reasonably practicable (ALARP).

2 Scope
2.1 This Standard defines requirements for the regulation and control of the conditions
under which assets may be permitted to remain in use for a pre-determined period
following the discovery or introduction of non-compliance with LU Standards.

2.2 This Standard applies to assets in most asset groups (for exceptions see clauses 2.6
and 3.1.1). It provides a process for the management of all non-compliance discovered
or introduced by whatever means and which will be made compliant in accordance with
the TANC Management Plan.

2.3 The steps described in this Standard are not an alternative to other mandatory
Standards or legal requirements which preclude or specify prescribed circumstances
under which assets may remain in service for a defined period pending the rectification
of specified defects and which provide for the monitoring and signing off of the
rectification works. The interface between such Standards and this Standard is
described in greater detail in Section 3.

2.4 This Standard does not cover permanent /indefinite, planned or known non-compliance
with Standards. If non-compliance is discovered or introduced and which is expected to
continue beyond the non-compliance close-out date identified in the TANC Management
Plan an application for a Concession must be made in accordance with Category 1
Standard S1641 “Concessions to Standards”.

2.6 This standard shall not be used to allow non-compliant assets to remain in use where
this would put LU or Tube Lines in breach of any regulation, or where there are specific
prohibitions in LU standards. For the avoidance of doubt, this standard shall not be
used in the heavily regulated Lifts and Escalators (L&E) asset group where the
overriding obligation to be legally compliant renders the TANC process inappropriate.

2.7 The competence requirements in this standard apply to LU, Tube Lines and all other
Suppliers employees engaged in the role of Temporary Approved Non-Compliance
(TANC) Authorised Person (TAP) when managing non-compliance in accordance with
this Standard.
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Title: The Management of Temporary Approved Non-Compliance (TANC)
Number: S1642
Issue no: A7
Issue date: April 2013

3 Requirements

3.1 Compliance with Standards


3.1.1 This Standard shall not be an alternative to other Category 1 and Category 2
Standards that specify circumstances in which assets may remain in use under
controlled conditions following the discovery of a pre-defined variant condition and
subject to the implementation of any pre-determined minimum actions.

3.1.2 It shall not be necessary to invoke the steps described in this Standard in situations
where a formal Concession in respect of non-compliance has been granted under the
procedure specified in Category 1 Standard S1641 and is current.

3.1.3 In all other cases where a non-compliance with Standards is discovered or introduced,
i.e. which are not covered by 3.1.1 and 3.1.2 above. The controls set out in this
Standard shall be used in order to determine whether the asset may remain in service
pending correction of the non-compliance or granting of a concession in accordance with
Category 1 Standard S1641“Concessions to Standards”.

3.1.4 The application of this Standard is not an alternative to the Concessions process
described in Category 1 Standard S1641 (see also 3.1.2 above), but may in certain
circumstances be a precursor to it.

3.2 The Management and Control of Temporary Non-Compliance

3.2.1 Risk assessment

3.2.1.1 A common risk assessment process shall be adopted by LU and Tube Lines for the
assessment of safety risk which shall be appropriate to the type of asset and the nature
of the risk presented by the non-compliance. The process framework used for assessing
safety risk shall be in accordance with LU Category 1 Standard 1-526 “The Assessment
and Management of Health, Safety and Environmental Risk”.
3.2.2 Rectification of non-compliance

3.2.2.1 A non-compliance in respect of this standard shall exist when an inspection or similar
activity by a designated inspector/maintainer identifies a physical condition in respect
of an asset which does not comply with Category 1 or Category 2 Standards.

3.2.2.2 If the non-compliance can be rectified before the asset is brought back into use or the
minimum action specified in the appropriate Standard can be carried out, the non-
compliance shall be closed out as required by the applicable standard and no further
action is required.

3.2.2.3 If the non-compliance cannot be rectified, this shall be reported to a TANC Authorised
Person (TAP) to assess whether the non-compliance presents a significant safety risk.
In accordance with the TANC Management Plan this involves assessing the likelihood
and severity of an incident if the asset was to continue in service.

3.2.3 TANC Authorised Persons (TAP)

3.2.3.1 A TAP shall be an authorised and competent person who holds a current and relevant
means of identification in accordance with LU Category 1 Standard S1548 “Safety
Critical Work” and:
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Title: The Management of Temporary Approved Non-Compliance (TANC)
Number: S1642
Issue no: A7
Issue date: April 2013

a) has defined responsibility for and is competent to decide whether or not any
discovered or introduced non-compliance creates a significant safety risk,
b) is authorised and competent to produce a TANC Management Plan and to ensure
that the plan is fully implemented by Tube Lines or LU person responsible for the
safety of the asset concerned.
c) has been authorised as competent to undertake the function of TAP as defined
within this standard.

3.2.3.2 TAP Competence Assessment

a) Competence shall be demonstrated by successful completion of an authorised


assessment and sign off of a review form.

b) The assessment of a candidate‟s competence in technical skills and knowledge


shall be carried out under the auspices of a competent assessor who shall sign
the review form.

c) On expiry of the period of validity, a person‟s authority to carry out the function
of TAP shall be re-assessed by a competent assessor.

d) Only persons demonstrating compliance with the competence requirements


contained within this standard shall be recorded as authorised via the
competence management system or issued a Safety Critical Licence to perform
the role of a TAP.

3.2.3.3 Competence Requirements for TAP

Prior to being assessed as competent to undertake the function of a TAP, individuals


shall meet the following pre-defined level of competence:-

a) Have achieved the prescribed level of competence and licensing for declaring
assets or processes as fit for continued service as defined within the
appropriate Safety Critical Work and/or other standard.

b) Hold a current „means of identification‟ as required by LUL Category 1 Standard


S1548 Safety Critical Work and appropriate competence assurance
arrangements.

c) The means of identification must be for the same asset group / process area as
that of the non-compliant asset or process being assessed.

d) Assessment of the impact of the non-compliance on safety, operations and


interfacing assets / processes / operations.

e) Application of the site-based TANC risk assessment method relevant to the


asset.

f) Setting TANC management plans to control risk and to implement mitigation


measures appropriate to the level of significance of the safety risk identified
from undertaking the site based risk assessment

3.2.4 TANC Accountable Managers (TAM)


3.2.4.1 TAMs could be local Asset Managers or Delivery Managers and shall ensure that:-
a) adequate number of staff are trained and deemed competent TAPs.
b) records supporting the nomination of TAPs are maintained.
c) TANC Assessments are undertaken by TAPs in compliance with local work
instructions and this standard.

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Title: The Management of Temporary Approved Non-Compliance (TANC)
Number: S1642
Issue no: A7
Issue date: April 2013

d) non-compliances are prioritised by risk for their TANC Assessment.


e) mitigations originally put in place are reviewed by competent staff, and
where deemed to present unacceptable risk, remedial action is implemented
urgently.
f) the status of individual TANC Management plans are tracked and periodically
reviewed by competent licensed staff to ensure they remain appropriate and
finally closed out.
g) a concession is sought immediately when a non-compliance is deemed
safety significant.
h) Take action, as necessary, following the independent review by the
Standards Competent Authority.
i) ongoing assurance is provided to the Standards Competent Authority that
controls are effective and in place.
j) progress on the closeout of TANCs is provided to the Standards Competent

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Authority
k) records of the closeout of TANC is maintained.

3.2.5 TANC Management Plans (Development)

3.2.5.1 The TANC Management Plan ensures that all tolerable safety risk is assessed and
managed through timely and appropriate controls and mitigation to a level that is as
low as reasonably practicable.

3.2.5.2 The TANC Management Plan shall contain a structured collection of activities and
records which shall be undertaken to achieve adequate control of temporarily non-
compliant assets through to close-out.

Note: The level of detail provided in the TANC Management Plan will be appropriate to
the nature of the safety risk presented by the non-compliance and will also
support the information that is required to be presented to LU in advance of the
Asset Performance Review Meetings (APRM) as set out in clause 3.2.4.4 and
shall typically include but not limited to:
a) the name of the TAP responsible for the TANC Management Plan.
b) the original date of assessment of the non-compliance by the TAP.
c) general Details, including LU or Tube Lines, Asset Group, Line, WPP No. /
Project No.
d) details of the standard/s against which the TANC is being sought, including
Title, Number, Version and clause number.
e) a description and identification of the need for the TANC (i.e. explain why the
asset / part of asset is non-compliant with standards and why).
f) an on-site assessment of the safety risk that the non-compliance poses to
customers / staff and others (using your knowledge, experience and
judgement assess the severity, frequency and likelihood)
g) details of the mitigation / controls that have been considered and how they
manage the safety risk as low as reasonably practicable.
h) a description of how the identified controls / mitigation will be implemented
maintained and managed for the pre-determined duration of the TANC and the
name of the person who has accepted responsibility for this.
i) the date by which full compliance with standards will be achieved (closure of
the TANC) and the justification for this based on the assessed risk and the
effectiveness of mitigation in use.

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Issue no: A7
Issue date: April 2013

j) the arrangements that will be established in order to provide the designated


Tube Lines or LU Competent Person with assurance in respect of the on-
going effectiveness of the risk mitigation measures.
k) details of the outcome of any review undertaken by the designated Tube
Lines or LU Competent Person and a description of any subsequent actions
taken in respect of the original TANC Management Plan.
l) evidence that a line / asset based assessment of TANC‟s is being undertaken
and to provide assurance as to how the cumulative affect on risk of approved
TANC‟s is being assessed / managed.

3.2.5.3 TANC Management Plans shall be reviewed by the designated Tube Lines or LU
Competent Person for the asset in order to confirm:

a) the adequacy of the risk assessment


b) the effectiveness of the mitigation / risk controls
c) the appropriateness of the time scales for achieving compliance

3.2.5.4 The designated Tube Lines or LU Competent Person shall ensure that timely
information in respect of TANC Management Plans, including changes to plans and
instances where Plans will not be achieved and a concession is required, is provided
to the relevant asset performance reporting.

3.2.5.5 In the event that the designated Tube Lines or LU Competent Person determines that
the TANC Management Plan is inadequate and / or there is insufficient information
provided to determine whether the non-compliance will be adequately managed the TAP
shall be advised and the TANC Management Plan and any associated mitigation
implemented shall be amended as soon as practicable.

3.2.5.6 The designated Tube Lines or LU Competent Person shall review and authorise any
changes to the TANC Management Plan.

3.2.5.7 All changes to the TANC Management Plan shall be recorded.

3.2.6 TANC Management Plans (Implementation)

3.2.6.1 TANC Management Plans that have been reviewed and agreed by a designated Tube
Lines or LU Competent Person shall be implemented as soon as practicable by the
Tube Lines or LU person identified by the TAP as being responsible for the safety of
the asset concerned.

3.2.6.2 The identified Tube Lines or LU person shall manage the non-compliance in
accordance with the TANC Management Plan.

3.2.7 Concessions

3.2.7.1 In the event that the agreed time scale for achieving compliance will not be met or,
following review, the designated Tube Lines or LU Competent Person determines that a
Concession is required the designated Tube Lines or LU Competent Person shall apply
for a Concession to the relevant standard in accordance with the LU Category 1
standard S1641 “Concessions to Standards”

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Title: The Management of Temporary Approved Non-Compliance (TANC)
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Issue no: A7
Issue date: April 2013

3.3 Process for the Management of TANC


3.3.1 The process for the management of TANC is shown in the flow chart in 5.1 below,
which contains cross-references to the TANC Management Plan.

4 Responsibilities
4.1 Responsibilities are as outlined in section 3.2

5 Supporting information

5.1 Process for the management of TANC


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Title: The Management of Temporary Approved Non-Compliance (TANC)
Number: S1642
Issue no: A7
Issue date: April 2013

Functional Responsibility
Designated Tube Lines or
Tube Lines or TANC Tube Lines or LU person
Activity Description LU Inspector Authorised LU (responsible
or Other Person (TAP) Competent for asset
Person safety)
1. Identification of introduced or
discovered non-compliance R

2. Can non-compliance be rectified


before asset is returned to No
service?

Yes
3. Close out non-compliance as
required by the appilcable R END
standard

4. Complete TANC Management


Plan as detailed in section 3.2.
R

5. Can the asset remain in service


subject to appropriate, practical Yes
mitigation / conditions as defined
in the TANC Management Plan
being in place?

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No
6. Comply with applicable
standards, which may require
R
specific controls or withdraw the
asset from service.

7. Are details of the TANC


Management Plan agreed? If No
No, liaise with TAP and arrange
immediate modifications to
TANC Management Plan and any
associated mitigation identified /
introduced.

8. Manage non-compliance until Yes


close out in accordance with R
TANC Management Plan.

9. Include details of TANC in R


statistics for Performance
Reporting.

10. Submit formal concession when


it is known that planned close out R
date in TANC Management Plan
will not be met or when non-
compliance ceases to be
temporary.

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Title: The Management of Temporary Approved Non-Compliance (TANC)
Number: S1642
Issue no: A7
Issue date: April 2013

6 References

6.1 References
6.1.1 LU documents

Document no. Title


S1521 Safety Decision Making
1-526 Assessment and Management of Health, Safety and Environmental Risk
S1548 Safety Critical Work
S1641 Concessions to Standards
W0128 Track – Management of Temporary Approved Non- Compliance (TANC)
F0174 TANC Form – Track
F0175 Track TANC Approved Person (TAP) Competence Form
F0176 Track TAP Continued Competence Form
W0539 Signals – Temporary Approved Non- Compliance (TANC)
G1251 TANC Guidance Note
F0773 Signals TANC Approved Person (TAP) – Competence Form
F0774 Signals TANC Approved Person (TAP) – Continued Competence Form
F0601 TANC Form – Signals and Control
W0907 Power Delivery Management of TANC
F2850 Power Delivery TANC Risk Asessment Form

6.2 Abbreviations
The following abbreviations are created:

a) within London Underground‟s Glossary of Terms S1622


b) from published sources that are clearly identified.

Abbreviation Definition Source


LU London Underground a
HSE Health, Safety and Environment a
TANC Temporary Approved Non-Compliance a
TAP Temporary Approved Non-Compliance Authorised Person a
TAM TANC Accountable Manager b
WPP Work Package Plan a

6.3 Definitions
The following topic specific definitions are created:

a) within London Underground‟s Glossary of Terms (1-622) (a Category 1 Standard);


b) from published sources that are clearly identified.

Term Definition Source


Work Package has the meaning ascribed to it in clause 7.1 of Schedule 3.1 of the a
Plan PPP Contracts;

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Title: The Management of Temporary Approved Non-Compliance (TANC)
Number: S1642
Issue no: A7
Issue date: April 2013

6.4 Person accountable for the document


Paragraph number Technical content manager
All HSE Senior Manager – Jon Jones

6.5 Document history


Issue no Date Changes Author
SQE-S-012 R1 Feb 01 – Nov Early development and consultation
to R12 01
A1(d) November Issued for use MG
2001
A2(d) April 2002 Issued for use MG
R13 January 2003 Removing obsolete references and TT
correcting terminology used.
R14 March 2003 Addressing agreed comments made in formal TT
consultation with Infracos
R15 April 2003 Both Tube Lines or LU Accountable Manager TT
and Tube Lines or LU Competent Authority
(TANC Regulation) recognised in standard as
having identical meanings so as to satisfy
Tube Lines or LU terminology used.
A3 May 2003 Issued for use TT
2-05304-012 A4 August 2003 Standard re-numbered, no change to content LH
R16 December Simplification of site safety assessment and TT
2004 removal of Class 1 and Class 2 TANC
requirements.
R17 March 2005 Achieving LU „Settled Position‟ in PSC TT
R18 September Further PSC changes incorporated TT
2005
R19 December Further PSC changes incorporated TT
2005
1-624 A5 September Issued for use TT
2006
S1642 A6 November Renumbered, formatted and revised as well Jon Jones
2011 as attaching a sample guidance form as per
DRACCT No. 01247 --```,`,,,`,,,````,,,````,````,`-`-`,,`,,`,`,,`---

S1642 A7 April 2013 As per DRACCT No. 01639, the form Dan Eyob
attached has been removed, relevant forms
have been linked and the competence
requirements from category 2 standard
S2600 A1 has been incorporated to allow
withdrawal of S2600 A1.

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