What You Need to Know for December 2025 and Beyond
As the rail industry continues to reduce the use of Lookout working, changes are being made to ensure that safety competencies reflect modern working practices. It has been agreed that the Controller of Site Safety (COSS) competence will no longer automatically cover the planning and delivery of work involving Lookouts.
Instead, this capability is being separated into a new, standalone competence. Anyone who requires the ability to plan or manage Lookout-based Safe Systems of Work (SSOWs) will now need to hold COSS (LKT), but only after they have first qualified as a COSS.
What This Change Means for Primary Sponsors
From the 5th of December 2025, the COSS competence will be split into two categories:
- COSS
- COSS (LKT) – required for planning and delivering Lookout-based SSOWs.
Primary Sponsors will now be responsible for determining whether each of their COSS employees also needs to hold the additional COSS (LKT) competence. This is not automatically assigned.
To add COSS (LKT):
- The Primary Sponsor must confirm the requirement to the training provider.
- A Company Director must provide written approval for the individual to undertake COSS (LKT) training.
- Once the training is completed, the individual’s Sentinel record can be updated in the usual way.
This ensures that only those who genuinely need Lookout-related competence receive the additional qualification.
Evidence Requirements for COSS (LKT)
At the first recertification after the 5th of December 2025, COSS (LKT) holders will be required to supply evidence of Safe Work Packs (SWPs) that include Lookout warning arrangements. This must be provided in addition to the standard COSS practice requirements.
The number of Lookout-related SWPs required will depend on the date of the recertification:
- Up to 5 March 2026: 1 SWP
- March 6th – June 5th 2026: 2 SWPs
- June 6th – September 5th 2026: 3 SWPs
- September 6th – December 5th 2026: 4 SWPs
After the 5th of December 2026, the requirement will stabilise, and COSS (LKT) holders must complete 4 Lookout-based practices every 12 months, in line with the revised standard.
Increase to COSS Practice Requirements
The updated standard brings a significant increase in the practice evidence required for a COSS to maintain competence. The requirement is rising from:
- 4 practices in 12 months → 10 practices in 12 months
To help ease the transition:
- Between December 2025 and December 2026, COSS holders will still only need to meet the current requirement of 4 practices in 12 months.
- From 5 December 2026 onwards, all COSS holders must meet the new requirement of 10 practices in 12 months.
This increase aims to strengthen safety competence by ensuring more frequent practical engagement and demonstrable experience.
Phasing Out Paper-Based Evidence
A major modernisation of evidence recording is also taking place.
From the 5th of December 2025:
- All track safety competence usage must be recorded in Sentinel.
- Paper-based Work Experience Books will be discontinued and will no longer be available.
- If evidence was collected in a Work Experience Book before the 5th of December 2025, it can still be used, but only for the individual’s first COSS recertification after that date.
There will be a grace period until the 5th of December 2027, during which Work Experience Book evidence will still be accepted.
This shift to digital recording will help improve accuracy, consistency, and visibility of safety-critical experience across the industry.
Initial COSS Training After 5 December 2025
For anyone attending COSS initial training after the changes go live:
- The Primary Sponsor must inform the training provider in advance if the candidate also needs to obtain COSS (LKT).
- A Company Director must endorse the request in writing.
- Updated practice requirements will apply following initial qualification, and the revised Standard (NR/L2/CTM/021 Issue 5) should be referred to for full details.
In Summary
These changes mark a significant step in aligning the COSS competence with modern track safety practices. The introduction of COSS (LKT), increased practice requirements, and the move to digital evidence all support a more robust and transparent competence framework.
Primary Sponsors, training providers, and COSS holders should familiarise themselves with these changes now to ensure a smooth transition ahead of the 5th of December 2025.
If you have any questions or need support preparing for the transition, we can support you.