Not everyone is fully fit. I have friends who have disabilities or are elderly and are not wheelchair users. The large step up to the 442s fears them with dread, especially the stupidly positioned grab rails outside the doors to haul them up on the train (which you have to let go of before you’ve steadied yourself on the train!!!) and the step boards you have to tread sideways on as one complete step from the platform to train is impossible for people who are unsteady on their feet.
@Nammer is absolutely right and cuts to the matter. The issue as I see it is this: what happens when a passenger uses these badly positioned grab rails to try to haul themselves up on an icy platform edge at Godalming, and slips down into the gap unseen. The train is given the right away. Whose fault is the ensuing accident and the associated 2 hour delay? Does the guard cop it? Are SWR liable for the Delay Repay?
There will doubtless be those who say “well that could happen with any train”. But that would be missing the point by a mile. The point is that whoever gave these trains dispensation against PRM-TSI could find themselves the liable party in the event of an accident.
The real issue is that the Department for Transport caved in to Angel and SWR. They went for the softest implementation of the regulations against legacy rolling stock. It should have been the hardest: that if legacy stock could not be made compliant
on any grounds (cost, unable to modify...) then it should have been withdrawn. If that resulted in gaps in the timetable then Train Operating Companies should have taken the government to court on the grounds that the issue was foreseeable given that the legislation allowed ample time to procure, test and introduce new, compliant rolling stock by the deadline.
My impression, if social media is anything to go by, is that the class 442s aren’t liked by our passengers very much. Who can blame them?!