The reporter expressed a safety concern related to the roster for drivers at [operator].
The reporter advised that drivers are often rostered on to drive for ten hour shifts finishing in the early hours of the morning and will then be rostered to start their next shift the following evening. While this allows the drivers enough time to sleep on paper (or within the FAID system), in reality the driver will need to sleep to recover from the shift they have just completed – they will try to limit this to 6-8 hours’ sleep so they can get some sleep later in the day before their next shift begins. Because they are trying to sleep during the afternoon, due to the body’s circadian rhythm, they often cannot get any sleep. This then means they can be awake for up to 20 hours towards the end of their next shift. It has been shown that periods of 17 hours of wakefulness produces impairments in psychomotor functioning equivalent to a blood alcohol concentration of 0.05%.
The reporter has also advised that the lack of available drivers on the roster has added to the problem.
The response from management when these issues have been raised is that drivers need to learn to manage their sleep better, but a more useful response may be to look at the rosters, not just with an aim to comply with regulations but to ensure that the drivers are assisted in their attempts to manage their fatigue to improve safety for all concerned.
Operator's response (Operator 1)
Our fatigue management program is underpinned by our Safety Management System, which provides controls designed to meet the range of root causes of fatigue as listed in the risk assessment provided. These causes and controls are all relevant as and where applicable to specific business-as-usual tasks. Control effectiveness is gauged via reasonable due diligence and assurance arrangements that support ongoing compliance of the SMS which is auditable.
Specifically, we set requirements for limitations to overtime, consecutive number of shifts, total shift length and FAID tolerance levels, which are reflected in the rostering system. Through use of this methodology, our rostering procedures minimise the build-up of chronic sleep loss and helps ensure adequate sleep opportunity.
Further, our rosters are maintained to ensure shift lengths and rest periods are within legal and other organisation limitations, including industrial agreements. With respect to the rostering system, the rostering system is calibrated to ensure that breaks between shifts are in accordance with legislative provisions and industrial agreements. It does not in all circumstances require a minimum break of 12 hours (for example when in barracks or away depot).
In relation to FAID scores, our system coordinators monitor FAID scores during shifts and are in regular contact with rail crew. Fatigue management is a shared responsibility of both the company and the worker to address their respective duty of care associated with the risks of fatigue in the workplace. Rail crew are responsible for informing their manager/supervisor if they are experiencing fatigue concerns that may affect their ability to undertake their allotted duties in a safe and effective manner.
Regulator's response (Regulator 1)
ONRSR has given consideration to the safety concerns raised and also the response provided by the operator.
ONRSR can confirm that an educational workshop regarding elements of fatigue management will be undertaken with the operator.
It is the intention of ONRSR to consider the safety concerns raised in REPCON RR20170016 when determining the scope of an ONRSR audit on the operator, scheduled for early 2018.