Excessive platform gap with trains designed for narrow gauge track

Rolling stock operator response

[The rolling stock operator] provides the following response to the above Repcon received on 2 July 2026.

Passenger safety has been a key consideration throughout the design, assurance, acceptance and introduction of the [train model] fleet. The concerns raised regarding platform gaps, vehicle suitability and CCTV-based monitoring system have been comprehensively assessed through the project's engineering, safety and regulatory assurance processes.

The assertion that the [train model] was designed for a narrow-gauge railway and subsequently adapted for [City]'s broad-gauge network is incorrect. The [train model] has been specifically designed, engineered and assured for operation on [City]'s 1600 mm broad-gauge network. Vehicle dimensions, kinematic performance and network compatibility assessments have been undertaken against [City]'s infrastructure and operational requirements.

While there are minor differences in car body width compared with the existing fleet types, the [train model] dimensions are comparable with trains already operating safely on the [City] Metropolitan Rail Network. A comprehensive platform gap study, supported by extensive testing, verification and validation activities, was undertaken to optimise the vehicle-to-platform interface and minimise gaps so far as is reasonably practicable while maintaining appropriate clearance requirements. These activities did not identify any unacceptable safety concerns and demonstrated that the [train model] platform interface performance is comparable with existing fleet types operating on the network.

It is acknowledged that larger platform gaps exist at some locations across the network due to legacy infrastructure constraints, such as platform curvature and historical design standards. These conditions are not unique to the [train model] and affect all rolling stock operating on the network. [The rolling stock operator] continues to address these risks through ongoing infrastructure improvement and platform renewal programs.

Concerns regarding the use of CCTV rather than external mirrors are also not supported by the evidence. The CCTV-based monitoring system provides drivers with dedicated views along the full length of the train-platform interface and aligns with contemporary rolling stock practice. Similar systems are already successfully deployed on [City]'s [other train] fleet and internationally. CCTV technology overcomes many of the limitations of traditional mirrors, particularly when monitoring the rear sections of long trains, and is considered a safety enhancement rather than a reduction in safety. While some ongoing refinement and optimisation of CCTV presentation and driver usability continues as part of normal fleet introduction activities, these matters do not indicate that the system is unsafe. Rather, they represent continuous improvement activities associated with commissioning a new fleet.

The project has maintained ongoing regulatory engagement with ONRSR throughout the procurement, design, assurance and acceptance phases, including regular monthly meetings attended by ONRSR representatives and the Independent Safety Assessor (ISA). This forum has provided transparency of the project's safety assurance activities. Through this established assurance framework and hazards have been systematically identified, assessed and subject to independent review, providing confidence that safety risks are being appropriately managed and reduced so far as is reasonably practicable (SFAIRP) prior to entry into service.

In summary, the available evidence does not support the assertion that the [train model] presents an increased or unacceptable safety risk to passengers. The [train model] has been specifically designed for [City]'s network, platform interface risks have been thoroughly assessed and validated, and the fleet has been subject to robust engineering, independent and regulatory assurance processes prior to entry into service.

[State Government Department] response

The [State government department] has reviewed the recently submitted safety report “Excessive platform gap with trains designed for narrow gauge track” (REPCON No: RR2026-00012).

[State Government Department] offers the following response.

The [train model] fleet was designed to specifically meet [State]'s technical specifications that includes all relevant industry standards. The vehicle’s maximum width is 2,996 mm, comparable with existing [City] train fleets, and its geometry has been deliberately optimised to minimise platform gaps while still fitting within the network gauge. 

Platform gaps are a challenge on the Metropolitan Rail Network (MRN). These gaps are primarily the result of an older legacy train network. The [City] train network comprises 227 stations and more than 1,000 km of track built over more than 150 years. This system includes many curved platforms where gap reduction is inherently limited. The [train model] performs favourably compared with other train fleets and incorporates a flexible rubber gap filler at passenger doorways to address the safety risk.

Mirrors are no longer considered best practice for modern rolling stock when viewing the train-platform interface (that in [City] are over 140 m in length). The [train model] uses a CCTV-based dispatch system that has been validated through stakeholder engagement, full-scale mock-ups, and type testing. [State government department] notes the [other] train fleet has safely operated on the MRN since 2020 with a similar CCTV system, and these systems are widely accepted around the world as the default option for this purpose now.

[State Government Department] rejects the claim that the vehicle design is inherently unsafe. The [train model] fleet has undergone a rigorous independent safety assurance process. An Independent Competent Person (ICP) certified compliance with all referenced standards, and an Independent Safety Assessor (ISA) reviewed the evidence that demonstrated hazards were eliminated or mitigated so far as is reasonably practicable (SFAIRP) as required by Rail Safety National Law.

Detailed responses to the specific concerns raised in the report follow below.

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Claim:

The rolling stock was not designed or intended for use on a broad gauge (1600 mm) network. The kinematic envelope is narrower than any existing legacy fleet types at 3.04 m wide. The width of each [train model] car is approximately 2.7 m wide, and it was designed to operate on 1067 mm gauge.

[State Government Department] Response: 

The [train model] rolling stock was designed specifically for [City] to comply with the State’s technical specification including the network gauge requirements.

The car body dimensions have been optimised to minimise the gap between the train and the platforms when stationary, whilst avoiding platform edge collisions on curved track under reasonably credible passenger loading and train/infrastructure fault conditions.

A comparison of the basic geometry of the [train model] trains to the maximum permissible rolling stock static outline, and the other fleets currently operating on the MRN is shown below.

Nominal dimensions for the width of each fleet have been sourced at 4 key locations as indicated in [the supplied image - [train model] vehicle with location of key points of interest shown].

(The image RR2026-00012-01.png was provided separately to the ATSB and ONRSR).

As can be seen in [the table provided - Comparison of the basic geometry of trains on the [City] Rail Network], for the most part the [train model] train is not the narrowest operating on the MRN. 

(The table RR2026-00012-02.png was provided separately to the ATSB and ONRSR).

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Claim:

At platforms, where external doors (not plug doors) are not attached, the platform gap can reach up to 0.42 m, placing children, elderly, vision impaired or any passenger in danger on a crowded platform.

[State Government Department] Response: 

Without knowledge of the location where it was measured, it is difficult to provide a detailed response on the claimed platform gap of 0.42 m raised by the reporter. What can be stated with confidence is that larger horizontal gaps are primarily due to track/platform geometry rather than rolling stock design.

While modern standards specify the installation of tangent (i.e. straight) track through new station platforms, the MRN consists of 227 stations and over 1,000 kilometres of track built over a period of more than 150 years. On curved platforms there are limitations as to what can be achieved to minimise the gap through rolling stock design.

As discussed above, the gap at the platform interface for the [train model] compares favourably with other fleets operating on the MRN. The primary area of safety risk of passenger slips, trips, falls and entrapment along the platform-train interface is at the doorways. The [train model] design incorporates a frangible gap filler in this area, and consequently the new train compares favourably to the other MRN fleets.

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Claim:

As the EMU is not fitted with mirrors, but has CCTV installed, it would be too easy for a driver to miss any incident whilst scanning 6 CCTV images on the surveillance screen prior to moving the train'.

[State Government Department] Response: 

Train or platform-mounted mirrors are no longer considered best practice for aiding the driver to monitor the platform-train interface for new rolling stock fleet.

Within the rail industry, on-train cameras & monitors are well-established. The technology provides a means of enabling the driver to undertake train safety checks prior to train dispatch from a station and whilst departing from the platform.

The CCTV system on the [train model] has been developed incorporating extensive stakeholder engagement during the design phase, including a full-size functional mock-up. The performance of the system was validated through type testing of the completed train prior to being put into passenger service.

Regarding the reporter’s concern that 'it would be too easy for a driver to miss any incident whilst scanning 6 CCTV images on the surveillance screen prior to moving the train', research commissioned by the UK Rail Safety & Standards Board (report T535) found that:

It is further noted that the [other train] fleet has been operating safely on the MRN with the use of 7 CCTV images since 2020.
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Claim: 

This rail vehicle's design cannot be managed to improve safety as the issues are inherent in its design and manufacture… the decision to acquire rail vehicle types that are not suited to the rail infrastructure, resulting in an increased risk to the travelling public which is then subsequently managed by the rolling stock operator.

[State Government Department] Response:

The [train model] vehicles have been delivered by a reputable global supplier accredited by the regulator (ONRSR) for the construction and commissioning of rolling stock.

The rolling stock was designed in accordance with relevant international, Australian and local network standards. It was developed by applying a systematic process for specifying requirements for Reliability, Availability, Maintainability and Safety (RAMS); and demonstrating these requirements were achieved. A system safety approach was followed, applying standard techniques and methods to derive the safety requirements, as well as the safety integrity requirements for the system and to apportion them to the subsystems.

An ICP has certified the compliance of the design and construction of [train model] rolling stock against the referenced standards prior to network registration of the rolling stock.

Prior to entry into passenger service, an ISA endorsed the rolling stock supplier’s safety assurance processes, tools and methods adopted during the delivery phase of [train model] vehicles. The rolling stock supplier adequately demonstrated all reasonably foreseeable hazards had either been eliminated or mitigated SFAIRP, in compliance with relevant legislation and accreditation obligations.