The reporter expressed a safety concern relating to the fatigue management at [operator].
The reporter advised that drivers employed by the operator are being rostered for long hours and are not receiving the minimum breaks between shifts.
The Rail Industry Safety Standards Board (RISSB) published fatigue risk management guidelines, which advise ‘Recognition of the risk associate with long commutes by both individual workers and their organisations is important, but management of the risk is best left to the individual and their immediate supervisor.’
Employees who have a significant commute between their home and their workplace are not having this taken into consideration in the breaks between shifts.
The reporter advised that drivers work a 12 hour shift and if they have an hour travel time then they are effectively working 14 hours. They get a minimum break normally of 12 hours but by the time they are home, this does not leave much time to wind down, sleep and then wake to prepare for their next shift.
The reporter also advised that the roster can be adjusted on a daily basis and the shifts can be changed by bringing the start forward or back by up to 4 hours. This is often extended well past the nominal hours with start times changing significantly – sometimes moving from a 2am start to a 10–11am start. This does not allow the drivers the certainty required to prepare for a busy 12-hour driving shift.
In response to investigations previously conducted by the ATSB, [the operator] has advised that they would be updating their Fatigue Management Standard and the appropriate use of bio-mathematical tools.
Reporter comment: Shift work takes its toll even when managed well. I am concerned for driver’s safety on the job as well as when traveling to and from work.
Operator's response (Operator 1)
These concerns have received comment from [the operator] below.
- Drivers working within the [location] Bulk Rail business have defined maximum hours of work and minimum hours of recovery (between shifts) stipulated in the rostering guidelines, and also built into the live rostering system. The live roster system does not allow a worker to be rostered for a shift without achieving the mandatory minimum time between shifts. In addition to minimum time between individual shifts, a worker cannot work in excess of 11 consecutive shifts without a mandatory rest day off. Mandatory rest days must conform to the provisions of a rostered day off (e.g. minimum of 30hrs duration, commencing no later than midnight, and cannot recommence duty earlier then 0600am the follow day). Train crew may acquire days off during the 11 consecutive shift period but if it does not conform to the minimum 30hr mandatory rest day the count does not cease.
- We recognise that the risk associated with long commutes is a dual responsibility of both the individual and the organisation. Commute risk is an identified hazard within [location] Bulk Rail and action has been taken to address this risk. The business has a current project in place, which aims to address the hazard of road transportation through the systematic identification, review and hazard reduction of road travel (including commute considerations). Additionally, a review and rewrite of the mandatory fatigue management training includes a section on commute risk and commute planning to upskill employees with practical risk management strategies. Strategies used to manage commute risk exist including alternative transportation opportunities (other employee drives worker home, taxi voucher) or supply of rest location such as barracks, on an as needs-basis.
- Current lift up/lay back provisions within the rostering guidelines does allow a shift to be brought forwards by 2 hours, or pushed backwards by 4 hours. In the example provided of a 2am start being pushed backwards by 8+ hours, this would not sit within the lift up/lay back provisions and would only occur with prior agreement by the worker. Additionally, lift up provisions cannot infringe on mandatory minimum rest periods. Fundamentally changing a shift (how we are utilising the crew) is an exceptional circumstance. This is via agreement only, because you are fundamentally changing them outside the clauses of the EA and rostering guidelines. Within the business there are mechanisms in place to manage these exceptional circumstances [Ref: Notice of Dispute, Rostering Committees, HSR Committees] to allow for investigation of root cause to prevent further occurrences.
- Maximum outer-limits of work hours are determined using a risk based approach (a solo operator has a lesser maximum shift length than does a dual operator as the second person acts as a secondary safety device and allows for fatigue management controls such as task rotation). Although two person operations do have a maximum outer-limit of 12-hour shift length, average shift lengths are considerably less. An example shift report from the live roster system shows that on average, less than 6% of actual shifts go over 10 hours. The master roster (with pre-defined days of work and rostered days off) is known to the worker at least 6 weeks in advance. The working roster (with defined days of work including training days, leave etc and rostered days off) is published nine days before the commencement of the six week period, and then is updated on a daily basis. As to advice periods relating to specific shift start times - train crew, as a minimum, will know the planned next shift start time and expected planned maximum shift length at the completion of their previous shift, or no later than 1730 after a rostered day off.
- We have been working closely with ONRSR over the past 12 months to upgrade and improve how the business manages fatigue. Current activities include:
- a revised national fatigue management standard
- development of business-level fatigue risk assessments and subsequent fatigue risk management programs
- review and re-write of mandatory fatigue management training courses.
- We are invested in the continuous improvement of the health, safety and fatigue standards across the business. The business recognises that worker fatigue provides a real and timely risk to our people and we are taking steps to continually improve our fatigue management system and supportive tools and strategies. We have mechanisms in place to support this process including health and safety committees, hazard reporting process, health and safety representatives, and rostering committees.
Regulator's response (Regulator 1)
ONRSR has undertaken inspections of the operator’s fatigue management processes, and has verified that the operator has processes in place to manage fatigue for its locomotive crews.
However, the inspections have identified deficiencies within these processes. The ONRSR is monitoring the operator’s corrective actions to improve its systems and processes. The ONRSR will continue to monitor the operator through inspections and audits during the year in order to ensure that the systems and processes remain effective and continue to be followed, taking into consideration the specific issues identified within the REPCON report as regulatory intelligence.