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Mode Rail
Reference No. RR201300019
Date reported 22 October 2013
Concern title Safety issues which have not been addressed by the operator for considerable time
Concern summary

The concern related to on-going issues which had been raised with the operator’s safety department but had not been adequately resolved.

Industry / Operation affected Rail: Freight
Concern subject type Rail: Rolling stock maintenance

Reporter's concern

The reporter considers that the following issues have not been satisfactorily addressed by the operator:

  1. High-intensity headlights (HID) cannot be dimmed sufficiently so must be turned off when passing an opposite direction train.
  2. The Brake equipment rack vents into the vestibule area beside driver's cabin causing a constant deafening air noise
  3. No operating manuals for the operator’s locomotive
  4. No fault manuals for the operator’s locomotive
  5. Whistles are slow to operate and are ineffective in heavy rain
  6. White powder leaking from exhaust silencer cavity was not tested for some time and when this was tested in was found to contain asbestos
  7. Some locomotives can be started without the insertion of the safety key.

Operator's response (Operator 1)

We wish to restate our concerns the ATSB's is not applying the rigour stated when the REPCON process was under consultation. The regulations were designed to ensure that the process minimised opportunities for abuse. It is not at all clear that the ATSB has made any attempt to " ... used our best endeavours to verify the accuracy of the report." It is clear "However we have not conducted an investigation". Without and cursory investigation, the complaint process is certainly open to abuse.

We will respond however, in large part the ATSB could easily have verified the information.

Specifically;

1.  Our headlights exceed the minimum compliance standard to ensure that drivers have good visibility of hazards in both low and high beam. We are satisfied that these lights work effectively and reduce hazards when used in accordance with the Code of Practice.

Refer to rule 5.6 "Locomotive Headlight Operation" Code of Practice for the DIRN, Operations and Safeworking Rules.

5.6.1 (b) - The train crew SHALL ensure that the headlight is turned off when the train is waiting to cross another train ...

5.6.1 (e) - The train crew SHALL... if "visibility" or ''ditch" lights are fitted, switch off the headlight when ... (iii) approaching junctions/ terminals or crossing locations ... (iv) approaching locations where a train is at stop ...  (vii) approaching a train ... on a parallel track.

The locomotive is fitted with ditch lights and is compliant with the current standards. We are aware of the driver concerns and are currently working with staff to determine if there is a better way to approach these issues. If the complainant is a Locomotive Driver, we request that the ATSB ensures that there is appropriate instruction provided. However, we have become aware that there is some ambiguity across Regulatory jurisdictions regarding this issue and we are investigating further.

2. The locomotive vents internally, near the vestibule, where there is ventilation to the outside. When venting, tests show that there is a 3 second exposure to noise at levels up to 106 dB, while in the vestibule. The National Standard for Occupational Noise [NOHSC: 1007(2000)] states:

3.1  The national standard for exposure to noise in the occupational environment is an eight-hour equivalent continuous A-weighted sound pressure level, LAeq, 8h, of 85dB(A). For peak noise, the national standard is a C-weighted peak sound pressure level, LC, peak, of 140dB(C).

Although peak noise exposure in the vestibule is well below the national standard maximum exposure, we cannot imagine many circumstances in which a driver is required to be within the vestibule while a brake application is being made. Within the locomotive cabin, noise exposure is lower than most of the national locomotive fleet and tested to be well below the noise exposure guideline thresholds.

We would expect that both crew members are in the cabin of the locomotive while the train is in motion and should only egress into the vestibule after the brakes are applied. The venting can only occur if manually operated from the driver's seat. We would expect that the Second Persons would not be required to be outside the locomotive cabin while the brakes are applied and venting in motion. If both drivers are diligently performing their duties, there is very limited exposure to the brake venting noise in the vestibule. We are aware of the Diver concerns regarding this issue also and are currently working with staff to determine if there is a better way to approach these issues.

3. Crews are trained in the operation of these locomotives and we have identified that the Manuals need to be reviewed and rewritten, this process is approximately 75% complete and we are currently working with staff to ensure the manuals are to an acceptable standard.
 
4. We have a 24/7 help desk to assist should any faults arise to assist crews in these circumstances. This is the first time in this allegation has been bought to my attention. These locomotives have been in operation for two years and went through a full commissioning process to verify compliance with operating requirements.
 
5. Whilst we have had faults logged regarding the whistles, all faults are checked and repaired. We are unaware of any driver reporting this as an outstanding issue; we will continue to work with staff to determine if there is a better way to approach these issues.

6. Aluminosilicate Fibre is installed in the locomotive mufflers. This product was tested prior to entry into the country. Subsequently it was retested by Bureau Veritas due to concerns raised. After testing, they stated; "Exhaust insulation- No asbestos detected. Synthetic mineral fibre detected. Organic fibre detected. We have issued a number of communiques to staff and continue to supply open and transparent communications in relation to health and safety concerns raised over this matter.
 
7. The locomotive is designed to allow the traction motors to be isolated to ensure that the locomotive cannot be moved while undergoing maintenance. It is possible to start the diesel engine that generates electricity, during maintenance if required by maintenance staff when undertaking some maintenance activities where this is required. Some locomotives do not have this feature, which can introduce a risk of locomotives moving, when started for maintenance. Our staff and maintainers are trained in "lock out" and "isolation" procedures to minimise any risks during maintenance and operations in addition to the engineering controls designed into the locomotive.

We will continue to maintain procedures that minimise the risks associated with railway operations and encourage all our staff to report any hazards. However, with newer type locomotives, such as the ones we operate, we have introduced newer and we believe better technologies to improve safety. We operate the youngest main line fleet in the country, which are compliant with all current design standards.

Regulator's response (Regulator 1)

1. In regard to the above outstanding issue, the ONRSR is satisfied with the operator's response. The operator's response was reviewed in conjunction with examining the Code of Practice for the Defined Interstate Rail Network.

2. No comment.

3. The ONRSR has sighted evidence of operating manuals for the CSR Class locomotives utilised by the operator. The manuals have been written in English; however, it is clear that issues do exist in regard to the interpretation of what is recorded within the manuals. The operator has indicated that the manuals are currently being reviewed with a projected completion date to be provided to the ONRSR.

4. In regard to fault finding manuals, the operator conceded that they do not exist. As such, the operator has initiated a 'Help Desk' process. If faults are detected, the operator advised that drivers adhere to the 'help desk' process, whereby; they receive advice from manufacture and technical specialists. The operator advised that access to the 'Help Desk' is available at all times.

In view of the above information, the ONRSR is satisfied with the action taken by the operator in addressing the issue.

5. No comment.

6. In regard to this issue, we can confirm the locating of asbestos material within the CSR Class locomotives utilised by the operator. Upon being located the operator advised the ONRSR:

  • All CSR class locomotives were immediately 'grounded', quarantined and prohibited from any form of use or access.
  • All asbestos related material was removed from all CSR class locomotives prior to being deemed fit for operation.

Information received by the ONRSR suggests that there does not appear to be any contamination due to the contained asbestos, nor does there appear to be any widespread contamination within the locomotive.

In view of the above information, the ONRSR is satisfied with the action taken by the operator in addressing the issue.

7. In regard to this issue, the ONRSR is satisfied with the response from the operator.

 

ATSB comment

The operator has disputed the Regulators comments in relation to item 4 above.

 

Operator's comment

We have extensive fault manuals available. Unlike more common, older class Australian locomotives, which rely on the drivers to analyse and identify faults from the mechanical indications inside the locomotive engine room, our locomotives have advanced computer driven self-diagnostic for the locomotive. This system displays locomotive faults to the driver on a screen to the driver. If a fault occurs, the locomotive displays an error code. This error code is relayed to the Help Desk for analysis and recommended actions.

And in an advanced locomotive such as ours, this process is an important risk mitigation strategy. Drivers are discouraged from directly diagnosing faults and entering the engine room without appropriate instruction. It also assures that qualified engineering staff makes appropriate determinations on how to proceed if a fault is identified. We do not distribute the fault manuals widely as this may encourage inappropriate actions.

 

 
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Last update 11 August 2014