As a public body, London Underground has to carry out an assessment of the impact of any new policy on various equality issues. The attached file is LU's Equality Impact Assessment (EQIA) for its current OSP (policy of cutting 800 mainly-stations jobs). Below is the response to this document that I have written on behalf of RMT. You will see from this that LU's EQIA falls woefully short, and ignores key equality issues. It even has the temerity to suggest that removing hundreds of staff from London Underground stations will have a positive equality impact on groups including elderly and disabled passengers!

The first part concerns staff; the second part passengers.

RMT continues to oppose these job cuts. The union is also seeking legally advice as to whether LU's Equality Impact Assessment is so inadequate as to not properly constituent an Equality Impact Assessment at all, and therefore whether LU has failed to meet its legal duty.

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An examination of London Underground's Equality Impact Assessment (EIQ) of its OSP (its programme to cut up to 800 jobs, mainly on stations) has revealed it to be woefully inadequate. In particular, the document:

• fails to give any consideration to many important equality issues
• 'cuts and pastes' assessments from one equality group to another, showing no consideration of the specific needs of different groups and revealing a lazy and cursory approach
• makes the bizarre claim that removing up to 800 station staff has a 'positive' impact on customers in all equality groups, including women, disabled people, ethnic and sexual minorities, older and younger people.

It is not simply a matter that RMT disagrees with the opinions or conclusions contained in the EQIA. We believe that it has not been done properly or in accordance with LU's legal obligations in this area. It is our contention that the EQIA is shabby, ill-considered, and an exercise in box-ticking rather than genuinely assessing the impact of its policy on equalities.

We believe that such a significant cut in staffing levels can not help but impact on equalities, especially given the context of existing inequalities within society, the workforce and the customers. We suspect this is why LU has so dramatically failed to adequately assess the equality impact - as any such adequate assessment would reveal that the staffing cuts are themselves an attack on equalities and can not be made equal or fair by small adjustments or monitoring.

There follows an examination of LUL's EQIA table.

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STAFF

Women - CSA / SAMF

The EQIA deals with the grades of CSA and SAMF together, as if there were no difference between the grades. There should be separate assessments for each of the two grades.

An assessment for CSAs should address the increase in lone working brought about by the reduction in staffing levels - both working completely alone at a smaller station, or alone at a particular location in a larger station eg. a gateline. Lone working increases the likelihood of assault and verbal abuse, and for women, the likelihood of sexual assault and/or sexist verbal abuse. For this reason, opposition to lone working is included in RMT's Women's Charter.

An assessment for SAMFs would also address grade-specific issues, for example examining the reason why this is the most popular operational grade for women workers.

While admitting that "The reduction in numbers may impact on the % of women staying within these roles", this section of the EQIA goes on to claim that "it is not anticipated that female staff will be impacted disproportionately compared to male staff". These two statements, contained within the same sentence, appear contradictory.

This section also does not address the likelihood that cutting posts in these two grades - those with the highest % of women workers in operational grades - will impact negatively on the overall % of women employed by London Underground, probably decreasing it, and almost certainly at least slowing its recent increase.

While admitting that the reorganisation of station groups will require more travelling time for reserve staff, the EQIA wrongly claims that the ïncreases "are not expected to be significant or unreasonable", and is generally dismissive of any real detriment for duties booking on or off during traffic hours. This assessment takes no account of staff who have caring responsibilities and who need to, for example, pick children up from school after work or attend to elderly or disabled adult dependants. It is well-documented that although some men have these responsibilities, the majority of those who do are women.

This section fails to acknowledge the impact of increased travelling time or less predictable working hours on those employees who would be displaced from a rostered to a reserve position, nor does it address the possibility that changes to rostered working times may impact on caring responsibilities. Some employees may be so significantly affected as to make continuing in their job difficult or even impossible.

It also fails to address the fact that with fewer staff, London Underground will have reduced capacity to meet requests for flexible working, many of which are made by women.

Males - CSA / SAMF

The vast bulk of this section is simply a 'cut and paste' copy of the section on females in these grades. This shows that LU has failed to give consideration to the impact on women and men as distinct groups, which is the core purpose of the legislation requiring LU to conduct this assessment.

No consideration is given to the fact that some proposed roster changes see an increase in weekend working, nor to the impact on people who are to be displaced from a rostered to a reserve position. Both these changes would make it harder for employees to visit children who do not live with them, the majority of these employees being men.

It also fails to address the fact that with fewer staff, London Underground will have reduced capacity to meet requests for flexible working, many of which are made by men.

Females - Station Supervisor

This section claims that there will not be 'any significant change to the role' of Station Supervisor. This is inaccurate, as there are planned changes to some SS rostered working times; the nature of the SS work while on duty; and the workload arising from reduction in numbers of staff in other station grades ie. CSA/SAMF.

Some SS working times would change in such a way that would have an adverse impact on caring responsibilities.

The reduction in overall staffing levels is accompanied by an increase in lone working for Station Supervisors, including in vulnerable positions such as on gatelines.

Males - Station Supervisor

This section is an exact 'cut and paste' copy of the section on female Station Supervisors, revealing that LU has made no attempt whatsoever to address the impact on women and men as distinct groups.

Black and Minority Ethnic - CSA / SAMF

This section is virtually identical to the section for female CSA / SAMF, showing that LU has not even considered issues and impacts specific to these groups.

Issues the company should have, but has not, considered, include: increased vulnerability to racist attack due to increased lone working and increased customer frustration at reduced service and staff availability; reduced support available from other staff in the event of racist attack; reduced ability to meet requests for time off for cultural or religious events due to reduced availability of cover.

Moreover, the EQIA reveals that, with 43.9% BAME CSAs and 48.8% BAME SAMFs, London Underground has a high proportion of black and ethnic minority employees.

There is no reason to believe that this would not continue to be the case were it to keep its current staffing levels, and continue to recruit new employees to replace those who leave. Thus, the loss of 800 jobs could have a negative impact on the employment rates in various minority ethnic groups, some of which have a higher-than-average level of unemployment.

Black and Minority Ethnic - Station Supervisor

This section is an exact, 'cut and paste' copy of the sections on female and male Station Supervisors, showing that once again, LU has made no attempt to consider these distinct groups and the potential impact on them of the OSP.

Disabled people - CSA / SAMF

Again, the EQIA considers the grades of CSA and SAMF together, despite them being distinct grades with distinct impacts.

This section acknowledges that further monitoring is required, and commits to taking into account reasonable adjustments and medical restrictions during the 'detailed staff deployment phase'. It then goes on to comment on the displacement process, again exactly reproducing the text from previous sections, thus not considering the impact on disabled staff at all.

This section does not consider the impact of the staffing reductions on London Underground's ability to make reasonable adjustments for disabled staff, or to accommodate medical restrictions. Nor does it consider the impact on disabled staff of the reduction of the number of colleagues they will be working with and therefore the support available to them.

The statistics in the section reveal that only 0.2% of SAMFs are disabled, and 0% of CSAs. These figures are shockingly low, and should alert London Underground to the need to improve the opportunities it offers to disabled people rather than to reduce staffing and therefore reduce those opportunities.

Disabled people - Station Supervisor

The first part of this section is a cut-and-paste copy of the first part of the section on disabled CSAs / SAMFs; the second part is a cut-and-paste copy of the sections on female / male / BAME Station Supervisors.

This does not constitute a genuine equality impact assessment, as it does not consider the impact on this specific equality group.

Lesbians, gay men and bisexuals

This section does not break down by grade, and consists wholly of the single sentence 'It is not anticipated that these changes will have any specific equality impact on this group.'

It offers no justification for this statement, and does not consider issues such as the risk of increased vulnerability to homophobic attack/assault arising from the increase in lone working.

Transgender people

This section does not break down by grade, and consists wholly of the single sentence 'It is not anticipated that these changes will have any specific equality impact on this group.'

It offers no justification for this statement, and does not consider issues such as the risk of increased vulnerability to transphobic attack/assault arising from the increase in lone working.

Faith groups

This section does not break down by grade, and consists wholly of the single sentence 'It is not anticipated that these changes will have any specific equality impact on this group.'

It offers no justification for this statement, and does not consider issues such as the risk of increased vulnerability to faith-based attack/assault arising from the increase in lone working; nor the reduced capacity of LU to accommodate requests for time off for religious occasions.

Older people - CSA / SAMF

Similarly to previous sections, this section does not distinguish between CSAs and SSMFs, consists entirely of a cut-and-paste copy of previous sections, and gives no consideration of the impact on the equality group supposedly under consideration. This is not a bona fide equality impact asssessment.

Older people - Station Supervisors

This section consists entirely of a cut-and-paste copy of previous sections about Station Supervisors, and thus does not consider the impact of the OSP on the equality group supposedly under consideration. This is not a genuine equality impact asssessment.

Younger people - CSA / SAMF

This is the only section for which London Underground admits a negative equality impact on the group concerned. It does not, however, offer any specific remedy for this.

The remainder of the section is, once again, an identical copy of previous sections and again, considers CSAs and SAMFs together rather than separately.

It does not address the loss of promotional opportunities for younger people in the CSA grade caused by the reduction in SAMF posts.

Younger people - Station Supervisors

This section is an identical copy of previous sections about Station Supervisors, and thus does not consider the impact of the OSP on the equality group supposedly under consideration. This is not a genuine equality impact asssessment.

CUSTOMERS

We find it utterly shocking that this section:

• consists of a single, virtually identical paragraph for each equality group
• does not even mention specific issues that may affect that group
• preposterously claims that the loss of up to 800 staff posts on Underground stations will have a *positive* impact on all the various equality groups.

The text common to each group's assessment is as follows: 'The proposals aim to ensure more effective and visible staff in customer facing areas. This will assist in providing the visible uniformed staff presence in station environments that customers identify as a priority in providing a safe and secure environment.' The policy being assessed here involves the loss of 7,500 hours of ticket office opening time; and a 10% reduction in staffing in station ticket halls. It defies all logic for LU to claim that such reductions make staff 'more effective and visible'. By definition, if there are fewer staff, they will be less visible.

(Other documentation from LU explains that the increased effectiveness and visibility in fact comes from initiatives that it claims 'accompany' the OSP but are in fact entirely independent of it eg. the introduction of Wide Aisle Gates and new ticket offices having fully-windowed fronts.)

Some of the issues specific to particular equality gorups of customers which are completely overlooked by LU's EQIA include:

Women

• The documented fact that women are more likely to travel with shopping and/or children and therefore more likely to need staff help.
• That many women fear travelling through stations with few or no staff, and avoid doing so.
• The level of sexual assault and sexist abuse experienced by women passengers and the importance of staff in deterring this and dealing with it when it does occur.

Black & minority ethnic

• The increased likelihood of racist abuse and assault when fewer staff are available to deter such crimes or deal with them when they do occur.
• Those customers who may not be fluent in English, and who therefore may need staff help, whether in day-to-day travelling or in emergency situations, rather than relying on PA announcements, leaflets or posters.
• The specific requirements of stations which are local to ethnic minority cultural venues.

Disabled people

• The need for staff to provide information and directions to those who may not be able to hear PAs or read literature.
• The need for staff assistance in evacuating disabled passengers from stations in the event of an emergency.
• The help provided by staff in accompanying blind and visually impaired people through stations; and stopping escalators so that passengers with assistance dogs can use them.
• The need for staff to reassure and support those with learning, social or communication difficulties during service disruptions.
• The fact that many disabled people may not be able to use ticket machines or other outlets, and so require open, staffed ticket offices.
• The increased likelihood of abuse or assault against disabled people when fewer staff are available to deter such crimes or deal with them when they do occur.
• The specific requirements of stations which are local to disabled people's organisations and facilities; and to hospitals and other health services.
• The fact that several disabled people's organisations oppose the reduction in staffing, and believe that it will have a negative equality impact rather than the positive impact claimed by London Underground.

Lesbians, gay men and bisexuals
The increased likelihood of homophobic abuse and assault when fewer staff are available to deter such crimes or deal with them when they do occur. The Gay London Policing Project (GALOP) has conducted relevant research in this area.

Transgender people
The increased likelihood of transphobic abuse and assault when fewer staff are available to deter such crimes or deal with them when they do occur.

Older people

• Older people may be less confident with modern ticketing technology and so prefer to use an open, staffed ticket office.
• Older people may have ticketing issues (eg. failed Freedom Pass) which can be resolved by a staffed ticket office but not by a machine.
• Some older people may be frail or otherwise vulnerable and require staff assistance.
• Older people may be more vulnerable to certain crimes eg. mugging, when fewer staff are available to deter such crimes or deal with them when they do occur.
• Consideration should be given to some stations being local to facilities for older people.

Younger people and children

• Staff assistance is crucial in the distressing situation of a child becoming lost or separated from his/her travelling companions.
• Fewer staff will mean less assistance available to children travelling in groups eg. on school trips. Consideration should be given to some stations being local to popular destinations for such trips.
• Some tickets for children and young people are available only from ticket offices, not ticket machines.

Faith groups

• The increased likelihood of faith-related abuse and assault when fewer staff are available to deter such crimes or deal with them when they do occur.
• The specific requirements of stations which are local to places of worship and other faith venues.

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Supplementary information: gender statistics

Percentage of London Underground operational staff who are women:

Station Assistant Multi-Functional (SAMF): 28.9%
Customer Service Assistant (CSA): 25.9%
Operational staff overall: 17.3%
Station Supervisor: 12.5%
Train Operator (driver): 10%

Proportion of London Underground's passengers who are male and female:

Commuters (59.7%): 59.14 % male / 40.86% female
Leisure (35.8%): 54.36% male / 45.64% female
Tourists (04.5%): 56.44% male / 43.56% female
Total (100%): 57.31% male / 42.69% female

These figures show that significantly more men travel on London Underground than women, which reflects a continuing gender division and inequality in our society.

There are no doubt several reasons for this. The gap is at its widest in the 'commuter' category, which may reflect that women are more likely to work nearer home and walk or use the bus to get to work, and men more likely to 'commute' further distances and use the Tube.

The higher number of men in the other categories may well reflect the fact that men still have higher wages and more economic independence than women do, and may also have more 'spare time' as women are more likely to have caring responsibilities for children and other family members. These are social causes over which London Underground Ltd specifically has some, but little, influence. However, there are factors over which London Underground Ltd has significant control, as addressed in the commentary above.

I also asked London Underground, on behalf of RMT, for information as to the times of day that men and women travel, as I am concerned in particular that women may avoid travelling at certain times of day due to safety fears and that the proposed reduction in staffing levels may exacerbate this. LU refused to provide this information, on the grounds that it was irrelevant to the OSP consultation.

Janine Booth
November 2010