COMET’s Account Director, Paul Hastings, was recently featured as a guest contributor in the September 2026 edition of Rail Freight Group News, writing on one of the most overlooked challenges facing rail organisations today. Read his full article below.

Rail is unusually good at counting the immediate cost of failure. When a signalling fault causes a delay, a possession overruns, or a worker is injured on track, the rail industry knows how to price the consequences. Delay attribution and Schedule 8, medical treatment, plant damage, investigation hours: Network Rail, the tier 1 contractors and their supply chains all track those figures.

The harder cost to see is the one that appears later, when the organisation pays for the same failure twice.

The second event may happen on another route or within another contractor team. Its circumstances will look different enough to appear new, yet the underlying causal conditions may be familiar. The issue is no longer simply that an incident occurred. It is that the organisation had already encountered part of the answer and failed to convert it into effective control.

Repeat incidents are evidence, not coincidence

Rail organisations do not lack investigation activity. Safety events, near misses and operational failures generate reports, reviews and corrective actions. The process can be extensive and still fail to produce organisational learning.

The weakness often appears when an investigation settles on the first credible explanation. A worker did not follow procedure. A component failed through wear. A possession overran because of poor planning. These statements may describe what happened but rarely explain why the conditions existed for it to happen.

A procedure may be difficult to apply in the field. Wear may reflect an unsuitable maintenance regime. A planning failure may originate in incomplete information or weak interfaces. Unless the analysis reaches those conditions, the action that follows is likely to address the symptom rather than the source.

This is how reasonable corrective actions can leave risk intact. A briefing is issued, a checklist amended, or a requirement restated. The action is completed, but the conditions that shaped the event remain unchanged.

The second incident changes the question

Repeat failure changes what the incident says about the organisation, because the financial and safety cost of an incident is rarely linear. A first occurrence may be relatively contained. But each repeat carries compounding cost: increased regulatory attention, reputational exposure with Network Rail and passenger bodies, insurance and contractual implications, and critically the erosion of confidence in a contractor's safety management system during framework reviews and tender evaluations.

For tier 1 contractors operating across multiple frameworks, a repeat incident is rarely viewed in isolation. It is read as a signal about the maturity of the wider safety management system, which can affect standing well beyond the specific contract or site where the failure occurred.

The challenge with isolated investigations

Robust root cause analysis produces better questions asked in a consistent order. COMET's coded taxonomy and Root Maps carry the investigator past the first answer into the conditions that allowed the failure, across communication, operating environment, management, equipment and training. Barrier and change evaluation exposes the defences that failed or were never in place, and human factors analysis runs inside the same workflow, keeping human error from becoming the terminal finding.

Consistency: Root cause analysis shouldn't depend on which investigator happens to be assigned, or how much time they have that week. A structured, repeatable process ensures the same rigour is applied whether the incident happened on a major renewals scheme or a routine maintenance shift.

Closure, not just logging: A preventive action is only effective if it is tracked through to verified completion, and if its effectiveness is actually checked afterwards. An action that "made sense at the time" but was never followed up is functionally the same as no action at all.

The business case reframed

The value of an investigation is not proven when the report is signed off. It is proven when the organisation can show that the conditions behind the event have changed.

Completing an action confirms that something was done. It does not confirm that it worked. If the same causal factor appears again, the organisation needs to know whether the action was insufficient, poorly implemented or based on an incomplete diagnosis.

This is where the business case for better RCA becomes stronger. Every repeat incident requires the organisation to spend again on investigation, disruption, recovery, assurance and management attention. It creates another exposure to harm that prior experience should have reduced.

A mature rail organisation should become more capable as its incident history grows. It should recognise recurring conditions earlier, connect learning across boundaries and test whether preventive action has altered risk.

If it cannot, then the hidden cost is not simply recurrence. It is the cost of repeatedly acquiring knowledge the organisation already paid to learn.

Key links

The DNA of a Failure | Cost of Repeat Failure | COMET

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