Origins of the yellow end requirement
The opening of the middle section of the Elizabeth Line (formerly known as Crossail) was rightly greeted with much fanfare despite the delays and cost overruns. There was a large amount of mostly positive media coverage about the scale of the project, the engineering and the overall design of stations and so forth. However, one aspect which did not excite any comment was the livery of the trains. Yes, the purple colour scheme was noted and some excited first passengers even wore purple outfits and dyed their hair purple in honour of this purple new addition to the tube map. But the trains are lacking something, namely, a big dollop of yellow paint on the ends which, until relatively recently, would have been required on any train running on the national network. This may appear an inconsequential detail to most; however, to those of us of a certain age, this marks the passing of an era. The yellow end requirement was introduced as a safety measure to increase the visibility of diesel and electric trains which were far quieter than their steam predecessors. This posed an added danger to permanent way gangs and anyone using unmanned crossings, although most countries never seemed to bother and just relied on the audible warning of a claxon. Indeed, it is worth noting that electrification of suburban routes began in the early 20th Century and the issue of audibility and visibility did not seem to be raised as an issue until much later. In any event, in the UK, the yellow ends soon became an integral part of the BR era.
‘BR Blue’ era
Indeed, to anyone who grew up in the 1970s and 80s, BR blue locos and blue/grey multiple units with full yellow ends and a discrete BR ‘arrows’ logo on the side were as British as red telephone boxes, policemen’s helmets and fish & chips. In the ‘BR Blue era’ the yellow section (which had started as a relatively small ‘warning panel’ in the British Railways ‘Lion and Wheel green era’) had grown to cover the full end of flat ended locos and multiple units and the entire front of the nose sections of locos such as the classes 37, 40, 45 etc.
When the Intercity 125 trains were introduced in the late 70s, the livery sported by the Class 43 power cars full embraced the yellow ends which wrapped around the sides as an integral part of the design (although the yellow cab roof area was soon painted blue as its proximity to the exhausts meant that keeping it looking yellow was a losing battle). In the 1980s a revised livery on some locomotives (notably Class 37s and Class 50s) similarly endeavoured to make a design feature of the yellow which was extended to the cab sides and combined with black paint around the windows. The livery was also notable for the fact that the hitherto discreet BR arrows logo went to the opposite extreme and assumed gigantic proportions on the side of the locomotive. This new look was also incorporated in many of the new liveries designed for ‘sectorization.’
Privatization and escape from ‘BR Blue’
Privatization of the industry in 1993 resulted in an explosion of new liveries which was quite dazzling to those of us who were accustomed to endless blue and grey. However, the yellow end requirement remained and one can only imagine the frustration of graphic and industrial designers whose smart new liveries were effectively ruined form an aesthetic point of view by the application of big dollops of yellow paint on the end. Some liveries worked better with the yellow ends than others; as with the HST power cars, the new Class 373 high speed Eurostar trains incorporated the yellow requirement into the entire livery. However, in many cases the yellow ends looked somewhat incongruous – rather like someone wearing a high vis vest with a dinner jacket! Nevertheless, there was no way round it as the yellow end requirement formed one of the standards which had been inherited from British Rail.
It is actually quite difficult to track down the exact origins of the yellow end requirement in that it was not imposed as a legislative requirement, rather, it was adopted by British Railways as a policy. Having said that, we must remember that British Railways (BR as it later became) was an old school nationalized industry in the fullest sense of the term. It was effectively a branch of the state (or ’emanation of the state’ to use EU ECHR terminology) and was in many respects self-regulating. Thus, given that the state owned the network through BR and had full control over it, internal policies and procedures might as well have had the status of legal requirements.
When the industry was privatized in the early 90s the new companies inherited some 9,000 of these internally set technical requirements and it is likely that the original yellow end requirement is buried in there somewhere. However, as the Ladbroke Grove Rail Inquiry Report noted, the new structure of the industry demanded the establishment of a new separate body in charge of reviewing and formulating standards.
A new regulatory architecture was ushered in by the Railways and Transport Safety Act 2003 which established the Office of Rail Regulation (which later became the Office of Road and Rail Regulation (ORR)) to replace the hitherto somewhat fragmented system of regulation. The ORR assumed responsibility for authorizing and approving new rolling stock and infrastructure which entailed ensuring compliance with the plethora of relevant technical standards including the 9000 BR era internal technical notes. The task of reviewing, updating and producing new standards was passed to a new body, the Rail Safety and Standards Board (RSSB), which was a main recommendation of the Ladbroke Grove Inquiry. The RSSB was established by the industry itself with a view to ensuring consistency across all the different companies comprising the sector. To this end the RSSB immediately set about the task of reviewing and revising the aforementioned 9000 standards inherited from BR in addition to formulating new standards; new and revised standards were termed Railway Group Standards. Although these standards were set by the industry they were afforded legal status by dint of the fact that compliance with them would be a necessary requirement of gaining ORR authorization for a new vehicle or project. An added dimension was the need to ensure compliance with the EU legal requirements on interoperability (introduced by a series of Directives commencing in 1996 with Directive 96/48/EC on the interoperability of the trans-European high-speed rail system) designed to facilitate compatibility between rail systems operating in the EU. To this end a number of Commission Decisions establish Technical Standards on Interoperability (TSIs) As we shall see, these interoperability requirements proved instrumental in the decision to relax the yellow end requirement. The key implementing regulations in the UK remain the Railways (Interoperability) Regulations 2011 SI 2011/3066.
The relaxation of the yellow end requirement
Given the magnitude of the task faced by the RSSB it is, perhaps, not surprising that altering the yellow end requirement was not a priority and it was preserved in its entirety in Railway Group Standard GM/RT2483 published in June 2004. However, in subsequent years there were dramatic improvements in lighting technology thanks to advances in LED systems. In 2016, it was finally determined that yellow painted ends were superfluous in most cases given improvements in lighting technology – apart from the obvious point that yellow paint is of no help whatsoever after dark! A new Railway Group Standard – GM/RT2131 (also described as a ‘national technical rule’ in line with the interoperability requirements) dispensed with the yellow end requirement provided that headlamps etc complied with EU technical standards established under the interoperability regime. The technical standards in question (known as Locomotive and Passenger Technical Specifications for Interoperability (LOC & PAS TSI)) were set out in Commission Decision 2011/291/EU passed pursuant to the interoperability regime (Directive 2008/57/EC on the interoperability of the rail system within the community).
Going forward it is worth noting post Brexit arrangements regarding technical requirements and the rail industry. The EU TSIs have effectively been rolled over into domestic law and rebranded as National Technical Specification Notices under the The Railways (Interoperability) (Amendment) (EU Exit) Regulations SI 2019/345. These must be sanctioned by the Secretary of State pursuant to section 3B of the aforementioned Railways (Interoperability) Regulations 2011. The LOC & PAS TSI setting out technical requirements for lighting etc is now set out in a LOC & PAS NTSN published on 21 January 2021. National Technical Rules (NTRs), such as the Railway Groups Standard on the audibility and visibility of trains remain in forces but are distinct from NTSNs in that they are not directly concerned with implementing interoperability and do not derive from the EU TSIs which the NTSNs replace (for further information on the distinction between the two types of standard see Department for Transport Guidance – Rail Interoperability: current national technical rules). However, as we have seen, they may clearly be relevant to interoperability and may need to cross reference and interact with them. Thus, as explained above, the relaxation of the yellow end requirement was only made possible by the existence of EU technical requirements on lighting which have now been adopted as part of domestic law.
Making the most of no yellow ends
Since the relaxation of the requirement there has been a proliferation of smart new liveries which have completely dispensed with yellow ends – one can sense a palpable sense of glee amongst the graphic and industrial designers who no longer have to work around this requirement! Apart from the Class 345 Elizabeth Line trains other notable examples of ‘yellow free’ trains include the Hitachi Class 802s operated by TransPennine and the brand new Bombardier Class 730s and CAF Civity Class 197s operated by West Midlands Trains and Transport for Wales respectively:-
However, it is important to note that the requirement has been relaxed and not entirely scrapped. Clearly, the requirement remains if the rolling stock is not equipped with the requisite headlamps etc. Moreover, even if the latest lighting requirements have been installed on rolling stock, the yellow end requirement can only be dispensed with following consultation with all interested parties on a particular route or part of the network and a risk assessment focusing on particular issues associated with that route or network. In this respect, it is interesting to note that the new GWR Class 800/801/802 high speed trains, built by Hitachi and resplendent in the Brunswick green of the steam era as a nod to the heritage of the GWR, still display yellow warning panels; as do the ones operated by LNER (another operator to adopt a branding which taps into railway heritage). However, as we have seen, those bearing the striking TransPennine Express Livery have dispensed with the warning panel. It would be interesting to know what local factors might have influenced these decisions, but the author has not researched this point as yet.
Why does it matter?
One might be forgiven for querying the importance of this issue which, to some at least, may appear to be an aesthetic detail only of interest to ‘gricers’ and industry insiders. However, I would maintain that the relaxation of the yellow warning panel (or entire train end in many cases!) tells us something about railway history and the nature of rail regulation. It shows how a requirement or practice can become very deeply entrenched and taken for granted. The issues also shines a light on the complex web of technical standards, many of which are inherited from BR days, and how they can be difficult to disentangle and organize into a new coherent structure. EU membership and the requirements of interoperability proved to be an important motivating factor in terms of tidying up domestic standards and putting them on a statutory footing. There has been an attempt to maintain this structure post Brexit and it is to be hoped that these efforts will continue.