The reporter expressed a safety concern related to the training and refresher training (and competency based assessments) provided to signallers in the [operator’s] network.
The reporter advised that over the last ten years, signallers working for [operator] have not been provided with refresher training in required competencies. According to the [operator’s] procedures, safe working competencies must be reassessed within a two-year period or the competency will be viewed as lapsed and the requirements for initial certification must be met before the authorisation can be reissued.
Examples of this are:
- competency C105- Control Rail Traffic Movements Level 1
- act as a lookout
- give and interpret hand signals to control rail traffic movements
- act as a hand signaller at defective signals
- compile and interpret, and use an Infrastructure Booking Authority (IBA)
- use of Special Proceed Authority (SPA)
- use of the pilot staff working method of special working (PSW).
Recently, [operator] has introduced a competency assurance assessment. However, this does not address all the criteria in the Network Rules and Procedures Certification Standard, including many of the competencies relating to the control of rail traffic movements and safe working practices while working on track - as mentioned above in this report.
Signallers have raised numerous other issues with the current competency assurance process which are still unresolved. It is the reporter’s belief that these concerns are not being taken seriously enough and [operator] are pushing ahead with the competency-based model in what appears to be deadline driven as opposed to ensuring its effectiveness.
The reporter has advised that despite a spike in safe working breaches, no extra training has been provided to signallers to ensure they are maintaining their competencies.
There is also a concern amongst signallers that due to there being a high level of change in the management personnel in this area, and that positions are being filled with people with no signalling background, this has led to a decrease in awareness of the issues. Furthermore, management do not fully comprehend the implications of signallers not being adequately trained in procedures that may not be used on a regular basis. The constant changes also mean any headway gained in that understanding is often reset.
As well as the training issues, [operator] management failed to advise a majority of signallers about Network Rules and Procedures changes, only notifying some staff a week after the amended rules came into effect. Staff were not provided opportunities to review the changes.
It is the reporter’s belief that there is not a sufficiently comprehensive or robust system in place to address potential knowledge and competency gaps, which should be obvious given the amount of safeworking incidents that have occurred.
The failure to advise of rule changes, provide training or, properly consider the concerns of signallers is indicative of the culture of complacency and indifference [operator] management have towards ensuring we have the tools, skills and knowledge to adequately and safely perform our duties.
Signallers generally feel [operator] need to take more accountability in ensuring signallers maintain not only their qualifications but also their competency in completing tasks critical to their roles as signallers.
Signallers have repeatedly requested more refresher training, which has repeatedly been ignored.
Signallers who have voiced concern about their knowledge of rules and procedures are generally treated punitively, hence has created a culture of fear of speaking out about potential knowledge or competency deficits.
Operator's response (Operator 1)
The training that [operator] delivers for signallers is informed by a Risk Based Training Needs Analysis (RBTNA). The RBTNA allows [operator] to prioritise the higher risk elements of signaller duties for refresher training.
In 2014 [operator] introduced a simulator based Competency Assurance (CA) model for Signallers. With this model we are able to assess staff in emergency operations, degraded operations and all track work authorities. We also assess their behavioural component (communications, leadership, situational awareness, decision making and problem solving). Feedback and re-training/coaching is provided where it is identified as being required.
CA is carried out on a two yearly cycle. This model was introduced in consultation with an independent psychologist and the signallers union, and has their full endorsement. Each new cycle of CA has different scenarios written to ensure they cannot be learnt and shared throughout the signalling staff, also ensuring a risk based approach is taken in ensuring new scenarios are based upon data of frequently occurring incidents.
[Operator] has been through one cycle of CA and are currently in the second cycle. The scenarios have been re-written, however the CA process remains the same. The reporter is correct that we do not assess all criteria relating to their competencies. We base our assessments on the RBTNA and also the incident information over the time period of the previous CA cycle. For example during the previous CA cycle [operator] experienced an increase in “block working” incidents therefore we have included block working scenarios in this round of CA.
We are unaware of any outstanding concerns from other signallers (all previous concerns were addressed with the union) and have received positive feedback from signallers that have progressed through this current cycle of the CA process.
[Operator] provides the appropriate documentation, training and or briefing for any changes to our Network Rules. The complexity of the change drives the level of documentation, training or briefing that we provide.
The reporter’s assertion that no extra training has been provided due to an alleged increase in Safeworking breaches is incorrect. Any Safeworking breach where a signaller has had their rail safety worker authority removed results in coaching and or retraining with a qualified trainer. This is recorded and tracked.
With regard to the background of management personnel, this is a business decision for [operator]. We do not accept the contention that there is a punitive culture within the Network Operations business unit that includes our signallers. If the reporter of the REPCON had provided information that would enable us to identify such an instance, it would be investigated. Such information has not been provided.
Regulator's response (Regulator 1)
A number of Rail Transport Operators including this operator have moved to Risk Based Training structure for refresher training in order to identify and prioritise the focus of this training. While this could be arguably contrary to the literal standards referred to in the complaint (which are the operator’s standards) it is not inconsistent with the Risk Based Focus and Risk Based Decision processes expected to be implemented by Rail Transport Operators in managing the risks associated with their operations. As indicated in the response this refresher training has in some cases also expanded from classroom based to include the use of simulator training.
Notwithstanding the above and while recognising the sense in prioritising topics that have arisen as part of incident reviews and/or investigations, ONRSR recognises that there should be a proper and transparent process in place to ensure that an appropriate balance including less frequently encountered situations is also in place.
The issues associated with the introduction of a new management structure within the Signalling Complexes were subject to a change management process by the operator, with the competencies identified based on the expectations and duties to be undertaken by those management positions.
The claim that there is a failure to advise of rule changes is difficult to accept, notifications of the existence of imminent changes are given in weekly notices and other associated documents. There are however, occasional concerns raised between the Signallers and the operator regarding the 'clarity' of the changes being proposed and the level of training and or briefing required. On a number of occasions ONRSR have reviewed the issues as well as routinely reviewing proposed changes.
Training and Competency issues are an ongoing element of the ONRSR audit and inspection program, as part of that program we will use the issues raised in the REPCON as part of our intelligence to inform the scope of our inspections and audit to further evaluate the operator’s recertification process.
The ATSB notes that [operator] has not been provided with information within the REPCON that would enable them to identify an instance where signallers may have been treated punitively for raising concerns regarding procedures. The ATSB accepts that it is difficult to respond to these claims without being provided any examples. However, a primary element of the TSI (Voluntary and Confidential Reporting Scheme) Regulation 2012 (REPCON) is the protection of any individual referred to in the report. As such, specific incidents claiming a punitive culture would not be permitted in a REPCON.
The reporter was provided with a copy of the responses and provided the following feedback:
The operator in my opinion has made some rather erroneous statements in response to the initial report and did not address many of the key components in the report.
Firstly, the Competency Assurance model is heavily referred to in the response provided by the operator and is not reflective of the many issues that were raised in the report. The CA model is also only an assessment process and there is no training component as part of this.
Signallers sit an examination on a simulated panel. This simply tests the signallers competency for a range of scenarios. It is accepted that not every scenario can be tested and that a RBTNA model is used, however this does not address the competency assessment requirements set out in the standards.
Further the operator has stated the signallers union has fully endorsed the CA process and that they are unaware of any outstanding concerns from signallers and that all previous concerns have been addressed with the unions. This is wholly an untruthful statement.
Whilst the unions agree with the CA in principle, there are significant concerns that have been raised by both the unions and signallers through emails and formal meetings with line managers. Whilst the operator has stated that feedback has been positive, this is unsubstantiated and evidence to the contrary exists.
One of the many existing issues is how signallers are retrained once identified not yet competent. Whilst each case will require different retraining requirements, many signallers have been required to re-sit the assessment at a later stage with no supported retraining. There is a difference between being found competent in an assessment and being confident in the tasks required of the position. It is arguable that while some may pass the assessment, they are not confident in a range of other tasks they have rarely if ever completed. So whilst CA goes some way to assess signallers competencies in certain limited scenarios, an issue in the report was that of training, both refresher training (being able to practice scenarios - not just be tested on them), training to meet the competency requirements in the standards and training when changes to rules and procedures are implemented.
Further to the paragraph above, from a risk based approach, scenarios that are uncommon and have low confidence levels would surely register as a high risk. In the aviation industry, scenarios not practiced by pilots in simulators have resulted in numerous air incidents and have since been incorporated into training. We receive no such training in rare scenarios. The report also raised a concern that where a higher than acceptable level of safeworking incidents have occurred in a particular area, that no intermediate training is provided.
The operator stated that those involved in a safeworking incident are re-trained, which is correct, but the concern raised was that when there is a spike in a particular area, no action is taken to ensure all other signallers have the requisite skills and confidence to ensure the error is not repeated. Rather, the operator would wait until the two yearly cycle of CA to “capture” those who might need remedial training in such areas. If indeed the claim is that training has occurred, the reporter would again like this to be substantiated with evidence of such. In lieu of any training, a bulletin in these circumstances is not sufficient in itself to ensure confidence and skills. In essence, the position of the operator is not even reactionary response training, least of all proactive, but a delayed two yearly assessment based approach.
The statement in relation to notification of rule changes was made in reference to latest changes within the suite of Network Rules and Procedures, where no communication was received by signallers from line management about the changes, what the changes were, and any opportunity to review changes or ensure they are understood. Many locations were not aware of the rule changes until some time after they were implemented. This can be affirmed by signallers in the outer regions of the network.