The reporter expressed a safety concern related to the commencement of driver only operations (DOO) by [operator] from the [location] depot.
The reporter is concerned that the risk assessment conducted by the organisation may not have identified or considered all the relevant hazards. For example, the hazards associated with (this is not a comprehensive list):
- a train exceeding its authority or passing a signal at danger
- a lack of continuous radio coverage over the entire network
- the process for receiving, verifying and recording train orders.
The reporter also advised that if a comprehensive risk assessment has been completed, the employees have not been advised and do not have a clear indication of the controls which have been implemented to manage the identified risks.
Reporter comment: I have worked on rail networks where driver only operations have been in place and I am happy with the concept, it is the lack of consultation and transparency in the process which is of concern here.
Operator's response (Operator 1)
[Operator] has been operating Driver Only Operations (DOO) since [year].
We have undertaken considerable consultation in the [location] since 2011 with regard the introduction of DOO in the [location]. The consultation is minuted in the [location] safety meeting minutes.
Limited DOO is already being conducted in the [location].
We have risk assessments in place associated with our railway operations.
In relation to the proposed extension of DOO in the [location] the consultation included employees (4 locomotive drivers) participating in a risk assessment to identify risks associated with this particular DOO route / service that are specific to this DOO and in addition to our current risk assessments. This risk assessment was tabled at the [location] safety meetings that involved elected safety representatives.
The regulator has stipulated standard conditions that we must comply with for endorsement by his office for the introduction of DOO.
A condition is that only DOO approved locomotives may operate on DOO services. The locomotives must have operational primary and secondary forms of communication being:
- primary - open channel radio;
- secondary - satellite or mobile telephones.
These two forms of communication must have coverage over the DOO route and the regulator will not permit the DOO service to commence without satisfying this requirement.
The process for receiving, verifying and recording Train Orders remains unchanged and is managed in accordance with the Track Manager Rules and Instructions.
In addition, our DOO procedures have a long standing provision for DOO locomotive drivers taking Train Orders which states: For the issue of any Safeworking Forms the train must be brought to a stand, at a location agreed with the Train Controller.
To finalise this matter, these and other safety concerns were tabled and discussed at [location] on [date] at the [location] safety committee meetings. This meeting is attended by safety representatives.
- a risk assessment has been undertaken in regards to DOO for the proposed services
- the risk assessment identified and considered relevant hazards
- employees were consulted as part of the risk assessment and safety committee meetings and
- we have taken steps to reduce and manage the risks and hazards to employees, and this has been communicated to employees.
Regulator's response (Regulator 1)
The driver only operation services and routes referenced in the communication are as follows:
- [freight] mainline and private sidings operations in the [location] region including train, shunt, shuttle, relief or light engine movements over the following routes
- [location 1] and from [location 2].
It should be pointed out that the Rollingstock Operator has been operating freight trains in DOO mode over select services and routes across the network since [year]. Approval to operate over these select services/routes in DOO mode has been subject to strict conditions imposed by the regulator.
These conditions relate to rigorous risk assessments needing to be conducted to identify and address safety related risks including:
- the assessment of the suitability for proposed routes for DOO
- safe working arrangements to be applied
- consultation with affected staff
- registration of locomotives proposed to be utilised to ensure forward panorama and cab ergonomics (human factors) are acceptable for single person operation
- delivery of training for affected staff
- emergency management arrangements
- implementation of relevant procedures and SMS documentation
- proposed crew rostering and fatigue management planning over the affected networks and
- primary and secondary communication coverage over the proposed routes.
With further reference to the [location] district, approval to operate in DOO mode was initially granted on [date] on a restricted basis due to communication issues beyond specific locations. Following recent infrastructure upgrades (including communication issues), DOO was extended in the [location] in [date] to include the afore mentioned routes.
As identified above, confirmation that communication coverage over the total proposed DOO route length is required before the regulator will endorse DOO operation over a specific route. Safe working arrangements (including Train Order Working) must be compliant with the rail infrastructure manager’s Rules and Instructions. In addition, the operator’s procedures require that DOO locomotive drivers must bring trains to a stand at a location agreed with Train Control prior to the issue of Safe working Forms.
With due regard to the issues raised relating to the [location] DOO, the regulator is liaising with the operator’s safety representatives and will monitor, through the audit process, to ensure that DOO requirements are not only adhered to but are communicated effectively to affected staff.