Level crossing safety management

Thank you for the opportunity to comment on REPCON RR2026-00008. [Operator] takes all safety concerns raised through the REPCON scheme seriously and provides the following response, which addresses each concern in the de-identified report. [Operator] acknowledges that this response may be published by the Australian Transport Safety Bureau (ATSB) and provided to the Rail Safety Regulator and has prepared it accordingly. This response is based on the information available to [Operator] as of the date of this letter.

Background

The [Location 1 road] level crossing is on [Location 1 road], off [Location 2 road], and is protected by flashing lights and half-boom gates. [Operator] is the Rail Infrastructure Manager (RIM) for the level crossing, and [local Council] is the road manager.

The crossing lies within the footprint of a [State] Government rail duplication project (the Project). The [State transport regulator] is the project owner. A Principal Contractor delivers the works, and [Operator] is the RIM for the project.

Importantly, the works at [Location 1 road] include the construction of a grade-separated road bridge, which will enable the permanent closure of the [Location 1 road] level crossing and eliminate the road-rail interface at this location.

The Principal Contractor provided information on the incidents described below to [Operator] and [State transport regulator] through its incident reporting and root cause investigations. [Operator] reviewed the information provided through the Principal Contractor's incident investigations and considered the findings in conjunction with its own operational knowledge, signalling information and risk assessments.

The four incidents and the boom gate activation time

'The reporter notes there have been four incidents where a truck from the project has either contacted the boom or been contacted by the boom gate at the level crossing and queries why the boom gate activation time has not been extended by [Operator] to allow for the safe transit of large project vehicles.'

[Operator] confirms four incidents at the crossing involving project-related vehicles occurred on [various dates]. Each incident resulted in contact with and damage to a boom gate. In the [date] incident, the approaching train was brought to a controlled stop before the crossing after the driver observed the dislodged boom across the track. In the [date] incident, an approaching train made light contact with the dislodged boom arm, and subsequent trains received written instructions until repairs were completed. In the other incidents, trains continued through the crossing under normal or managed operating conditions. All incidents were investigated, and [Operator] has received and accepted the resulting root cause (5 Whys) investigation reports.

[Operator] has interpreted the query about ‘boom gate activation time’ as the delay between the flashing lights activating and the boom gates commencing to lower, consistent with the reporter’s reference to section [x] of [Operator]’s safety management system specification [Level Crossing Principles]. The reporter has quoted part of that section. The full provision reads:

'The flashing lights operate for eight seconds before the booms start to lower. This delay shall be implemented by means of a vital slow-release timer which is guaranteed to release in the specified time or less. This timer shall be powered from a battery power supply. Where long or slow vehicles regularly use a crossing, this time shall be increased to reduce the probability of the boom lowering onto the vehicle (length > 19 m or speed < 10 km/h). (See Signalling – Level Crossing Heavy Vehicle Design Guideline [x].)'

The specification defines a 'long or slow’ vehicle as one longer than 19 m or travelling at less than 10 km/h. [Operator] understands the gazetted vehicle length for this council road is 19 m.

The vehicle involved in the first incident ([date]) was a float longer than 19 m, delivering an excavator to the construction site. In response, the project prohibited the use of vehicles over 19 m at the [Location 1 road] level crossing unless a track occupancy authority is in place, temporarily preventing rail traffic from approaching the level crossing. The vehicles involved in the second, third and fourth incidents were truck-and-dog combinations shorter than 19 m that ordinarily travel at speeds greater than 10 km/h. They do not regularly use the crossing as ‘long or slow’ vehicles within the meaning of the specification. The completed investigations identified driver actions and traffic control communications, rather than the warning time, as the contributing factors in the incidents.

For completeness, the boom gate activation times at the crossing are set in accordance with approved signalling designs and [Operator]’s safety management system specification. The timing settings were considered in responding to the incidents. Because the vehicles regularly using the crossing do not meet the ‘long or slow’ criteria, and because the contributing factors identified by the investigations related to driver actions and traffic control communications, extending the delay was not identified as an effective control for the causes of these incidents. Risk at the crossing is instead being managed through controls identified in the project’s site-specific risk assessment, as described below, pending the crossing's permanent closure.

Contributing factors

'Contact with the crossing boom has been attributed to several factors including the length and relatively slow speed of the trucks.'

The completed investigations identified driver actions and interactions with the traffic control arrangements, rather than the performance of the level crossing protection equipment, as the contributing factors. In the first and fourth incidents, communications from traffic control to drivers were significant contributing factors. In each incident, the level crossing protection operated as designed. A summary follows:

[Date] 
Float (over 19 m)

The vehicle, a float longer than the 19 m gazetted limit for the road, entered the crossing as it left the worksite. The crossing activated while the vehicle was partway across, and the float’s elevated loading ramp contacted the boom gate. The driver underwent mandatory post-incident alcohol and other drugs testing.

[Date]
Truck and dog (trailer)

The vehicle followed the preceding truck past the traffic control point without authorisation, contrary to the traffic control procedure, and came to a standstill at the crossing within the yellow-hatched no-stopping zone.

[Date]
Truck and dog

The vehicle slowed to give way to an exiting vehicle while turning from [Location 2 road] into [Location 1 road]. The driver, attending to the exiting vehicle, did not observe the flashing lights, which had activated eight seconds before the boom gates commenced lowering. By the time the driver reacted, the vehicle was committed to the turn; the driver assessed that stopping would leave the vehicle on the tracks and continued through, with the trailer contacting the lowering boom gate.

[Date]
Truck and dog

A radio instruction directed to another vehicle caused the driver to slow almost to a stop while traversing the crossing. The lights activated as the vehicle entered the crossing, and it was not clear of the boom gates after the eight-second delay.

In each case, the flashing lights activated, and the booms commenced lowering after the designed eight-second delay.

Interface Agreement concerns

The Interface Agreement for the crossing is between [Operator], as Rail Infrastructure Manager, and [local Council], as the Responsible Road Manager. It gives effect to the parties’ obligations under section 107 of the Rail Safety National Law. The agreement does not specify a fixed five-yearly review cycle; rather, it requires the parties to meet annually, or at such other times as the parties may agree, to review the provisions of the agreement and the adequacy of the safety risk identification, assessment and management at the crossing. 

In [Operator]’s view, the risks arising from the project’s temporary use of the crossing are best identified and managed through project-specific risk documentation developed in consultation with [Operator], because the project determines the work methods, vehicle movements and traffic arrangements and can deploy and adjust controls directly. This approach has been taken, including a site-specific risk assessment of [Location 1 road] level crossing operations to identify risk-reduction measures so far as is reasonably practicable (SFAIRP).

[Local Council] has been engaged where its role as Responsible Road Manager arises: the project submitted the construction traffic control arrangements for [Location 1 road] to the Council, which approved them. It is also important to note that the crossing will be permanently closed upon completion of the grade separation.

Safety management system compliance and the Australian Level Crossing Assessment Model

'On this basis, the reporter is concerned that [Operator] has not followed their own safety management system requirements and notes that [Operator] has not undertaken an assessment of the crossing under the Australian Level Crossing Assessment Model (ALCAM).

As outlined above, [Operator] considers the crossing’s timing settings consistent with section [x] of [Level Crossing Principles]: the vehicles regularly using the crossing do not meet the definition of ‘long or slow’, and the completed investigations did not identify the warning time as a contributing factor in the incidents.

[Operator] completed the most recent Australian Level Crossing Assessment Model (ALCAM) assessment of the crossing in [month] 2024. ALCAM is a risk assessment and prioritisation tool used to compare crossings across a network; it is not a determination that a crossing is ‘safe’ or ‘unsafe’. An ALCAM assessment would be unlikely to identify additional controls beyond the active protection (flashing lights and half-boom gates) already in place at this site. For a defined construction activity of this nature, the project-led, site-specific risk assessment undertaken in consultation with [Operator] is the more effective approach, because the project determines the work methods, plant, equipment and traffic arrangements and can directly deploy additional treatments to manage the road-rail interface. This has been the approach adopted.

Safety action taken

'In summary, the reporter concludes that given the significant change in conditions and use of the level crossing during the project, [Operator]’s inaction in preventative risk management at the [Location 1 road] level crossing has resulted in at least two of the incidents that occurred at the crossing.'

[Operator] does not accept that it has been inactive. [Operator] has participated in numerous workshops with the Principal Contractor and the Project Owner to examine the root causes of the incidents and determine how the risks can be managed so far as is reasonably practicable. Additional controls have been progressively implemented after each incident, including:

In addition, following the second incident, [Operator] commenced an assessment of track-blocking options, including any associated operational risks. The assessment has concluded that an All Trains Block is a suitable additional control and would be applied if truck and dog movements across the crossing were to recommence, noting that any such recommencement would occur only following consultation with [Operator]'s asset management and operations functions.

The permanent solution remains the grade separation currently under construction, which will eliminate this level crossing entirely.

Conclusion

Based on the completed investigations and the information available to it, [Operator] considers that the level crossing protection at [Location 1 road] operated as designed in each incident; that the investigations identified driver actions and traffic control communications, rather than the warning time, as the contributing factors; and that the risks arising from the project’s use of the crossing have been, and continue to be, actively managed through escalating controls implemented in consultation with the Principal Contractor and the Project Owner, up to and including the suspension of project haulage movements across the crossing. [Operator] will continue to monitor the effectiveness of the controls at the crossing, in consultation with the Principal Contractor and the Project Owner, until the crossing is permanently closed. [Operator] thanks the reporter for raising these concerns and the ATSB for the opportunity to review its safety management arrangements at this location.