The reporter has raised a safety concern relating to train crew rostering and fatigue management.
The reporter is concerned that the [Operator]'s current rostering system is ineffective and potentially contributes to an increase in train crew fatigue. The reporter states, 'Train crew are regularly rostered in a manner that does not allow for adequate, good quality sleep'. The reporter provided an example whereby train crew will work a number of night shifts starting at 0130 or 0230, finishing around midday, with the next shift commencing again at 0630 the following day. Crew will then sleep during the day and naturally be awake again during the night leading up to the start of their shift, that is, with minimal/disrupted sleep.
The reporter advised a further fault within the rostering system contributing to fatigue, is the practise of 'backward rostering'. For example, a train driver may be rostered the following shifts:
Day 1 - start 1100 and finish 2100
Day 2 - start 0900 and finish 1900
Day 3 - start 0700 and finish 1700
The reporter acknowledges that rest times associated with the above shift pattern comply with the minimum rest period as per the [Operator] Enterprise Agreement (EA), however the pattern of progressively commencing shifts earlier each day, makes it difficult to achieve effective sleep between shifts.
The reporter provided a further example of how the current rostering system contributes to driver fatigue and states, '[Operator] will routinely roster one particular service [service number] to start at 1800 and every shift train crew will be called to start at an earlier time. This shift used to be rostered for 1600 however on the odd occasion the train was late, [Operator] had to pay overtime'. The reporter further advised, the rostered start time was changed to 1800 in order avoid paying overtime. The issue increases fatigue as it interrupts sleep with drivers receiving calls and texts requesting the earlier start. Additionally, crew are not able to adequately plan their lives around it.
The reporter states, 'Fatigue scores are not published with the roster and train crew are not told they have high fatigue often until they have already commenced Safeworking activities. There are no controls put in place to manage high fatigue. Train crew are routinely expected to work beyond their rostered (10) hours irrespective of their fatigue level'.
The reporter is further concerned that complaints and suggestions to [Operator] 'fall on deaf ears' and the fatigue risk management system is outdated and requires a thorough review in order to improve driver fatigue mitigation.
[Operator] have reviewed the REPCON and provide the below response:
[Operator]’s Fatigue Risk Management Program (FRMP) is compliant with Section 29 of the Rail Safety National Law National Regulations 2012. In addition to the requirements outlined in the Rail Safety National Law National Regulations 2012, further fatigue management requirements are outlined in our Fatigue Management Procedure and our EA.
[Operator]’s [Management system] uses built-in system algorithms to incorporate rule set definitions and conditions, including EA requirements, fatigue management (including FAID scores), training, qualifications, and route knowledge to better manage shifts and employees.
The shift length limits and duration of time between shifts as prescribed in the EA were developed in consultation with the appliable Union and our workforce. The limits were determined using industry and company best practice, with consideration made to adhere to the [State 1] and [State 2] Schedule 2 requirements.
[Operator] has not found any evidence to suggest that the reporter's claims are valid and in breach of [Operator]’s FRMP.