The reporter has raised a safety concern regarding train drivers regularly breaching twelve-hour shifts resulting in driver fatigue.
The reporter states that the operator is enacting an unforeseen circumstances clause regularly, rather than rostering effectively to mitigate driver fatigue.
Whilst the reporter acknowledges that the excessive hours may not breach any regulations, the reporter advises that there is insufficient communication from the operator to drivers, regarding methods for preventing, reporting, and managing fatigue. Specifically, the reporter is concerned about the lack of understanding drivers have around the operator’s fatigue risk management system, particularly around responsibilities and accountabilities.
Operator's response (Operator 1)
[Operator] takes any safety concern very seriously and to address the concerns raised in the REPCON, we can confirm that [Operator] is using a risk-based approach to Fatigue Management (FM) which includes the following set of controls:
- [Operator] Fatigue Management procedure
- The [state] Code of Practice - Working Hours
- Independent Risk Assessment by [contractor] (Service provider)
- Individual Fatigue Assessment forms available to all employees
- Fatigue Management awareness and training for all employees
- Fatigue Management awareness and training for all supervisors
- Engineering controls (ATP) to enforce safe train driving in Train Control territory
- Use of Supervisor check calls to check on driver welfare during their shift
- In-cab vigilance monitoring
- Recording of statistics on hours worked in safe-working duties to allow accurate analysis and planning to minimise the risk of fatigue.
On occasion, due to faults in the network or equipment, the plan for a driver may need to change. If this occurs and there is a chance a driver may be required to work beyond 12 hours, the following additional controls are implemented:
- Drivers are relieved at the last ATP signal and have enforcement of LOA (before entering dark territory in yards).
- Drivers are relieved on track by an LV and driven as a passenger back to camp or their home base.
- Fatigue check completed before work is commenced on the next rostered shift.
In addition, [Operator] plans to reinvigorate driver awareness around fatigue management and the above controls to ensure drivers have an understanding of the systems and processes we have in place to effectively manage fatigue.
Regulator's response (Regulator 1)
ONRSR has reviewed the information provided by the reporter contained within REPCON RR20180013 including the response by the rail transport operator (the accredited rail transport operator). ONRSR has sought and received further information from the operator and is satisfied that the matter is being managed through the operator’s internal corrective actions processes. ONRSR will monitor the implementation of related corrective actions through the national work program.