There's more to this than just th ORR being mean, the WCRC have not been holding up their end of the bargain:
You are failing to ensure the health and safety of your passengers and crew, thus putting them at risk of serious personal injury, as you are not implementing the controls identified in your risk assessment for rolling stock fitted with secondary door locking, in that:
- Passengers are being told by train crew to operate the secondary door locks;
- Stewards are not preventing passengers from operating the secondary door locks;
- Stewards are not preventing passengers from leaning on train doors or from leaning out of the open droplight windows in train doors of moving trains; and
- Secondary door locks are not in the ‘locked’ position or are being opened by train crew before the train is stationary; Therefore, creating a risk of persons falling from a train or being struck by infrastructure being passed by the moving train.
The WCRC have form for poor adherence to railway operating rules - they've been banned before once, see the Wootton Bassett Junction near miss (where one of their steam tours came within under a minute of colliding with a high speed train due to train crew routinely defeating safety systems) - https://en.wikipedia.org/wiki/2015_Wootton_Bassett_rail_incident - in brief, this ended up with WCRC being banned from the national rail network for a time, the notice stating "the operations of WCR are a threat to the safe operation of the railway".