The reporter has raised concerns in relation to the following operational procedures.
Pre-departure train checks
Brake tests can take 60-70 minutes to be completed properly. Brake holding tests (valid brake docket) should be completed prior to every departure from the yard. Tests are being signed off without actually being completed in order to remain on schedule.
FAID scores
FAID (fatigue estimation) scores are calculated on commencement and completion of actual driving times rather than duty sign on/sign off time.
Drivers permitted to work beyond duty hour limitations
The reporter states that it often occurs that drivers are extending beyond their 12-hour shift if behind schedule. The reporter states that drivers are routinely extended beyond their 12-hour shifts, even when the operator is aware that the shift will require extension prior to commencement. Train Coordinators are not arranging relief drivers when requested and are not reporting limitation of hour breaches to ONRSR in accordance with the national rail law.
Drivers tasked to operate in areas where they are not route qualified
The reporter provided an example where a driver and trainee were tasked to [Location 1] and were not route qualified yet accepted the trip as they were loyal to the company and wanted to help out. The reporter advised this usually only occurs on one or two sectors, not entire routes. The reporter states that the drivers do have the option to refuse the task knowing they are not route qualified, however in this case, the company should not have permitted this to occur.
[Location 2] - maintenance
The reporter is concerned there is not adequate lockout procedures in place to protect maintenance staff working in and around locomotives at the [Location 2] yard. Red flags are used only on the locomotive being worked on, not the entire consist. There is nothing in place to prevent collision or movement of locomotives during maintenance activities. It would not be difficult for someone to unknowingly enter a locomotive three or four units along and move it while maintenance staff may be under or between wagons/locomotives that are connected.
The operator has provided the following response in relation to the concerns raised:
Pre-departure train checks
All brake tests are conducted by a maintenance contractor at [Location 2]. Every train that departs has a hold test completed by the [Contractor] examiners as per [Contractor] work instruction [approved procedures] vehicle brake holding test.
[Contractor] does this by asking the shunters what the last three wagons will be on the consist. This does not always take place after the whole train is assembled, in fact the hold test will most likely be one of the first tests conducted by [Contractor] when preparing for an outbound departure, therefore has zero impact on the train departure schedule.
FAID scores
All FAID Scores are calculated on book on and book off times. Train control record book on and book off times when drivers call through and report times. These are then used to calculate FAID scores. This is covered in [Operator’s procedure] in their SMS.
[Operator] was recently audited by ONRSR regarding fatigue management and FAID management.
Drivers permitted to work beyond duty hour limitations
At times due to network delays there have been instances where shifts have extended past 12 hours. This is managed as per [Operator procedure]. Section [no.] states if a 'live run’ event occurs, which may impact on the operation of the service, [Operator] will implement reasonable and practicable actions such as putting the crew to rest, relieving the crew or managing the crew’s fatigue status to reach its final destination.
Rail safety workers who believe that they are fatigued but feel that they are fit to continue duty will have their performance monitored by their supervisor who will carry out regular welfare checks of the rail safety worker.
In the event that an emergency situation has occurred, the maximum shift a rail safety worker can be required to work will be 16 hours. Most times the actual driving time is less than 12 hours but exceeds while they are in transit to depot or barracks (not completing safe work duties) until book off.
Drivers tasked to operate in areas where they are not route qualified
The operator was aware of the occurrence referred to in the report. The operator has acknowledged the [alternate Operator's] drivers route qualifications were not checked until post-shift.
Individuals involved have been reissued route qualifications. The operator has developed processes to ensure that only [Operator] approved qualified drivers will be rostered going forward.
[Operator] have also been audited by ONRSR regarding driver training.
[Location 2] - maintenance
[Operator] has a lockout procedure in place for the [Location 2] yard. Any failure to ensure correct lockout is due to failure to follow procedure. As part of the [Location 2] terminal upgrade we are moving all locomotive maintenance activities to within a maintenance shed on site and further engineering lockout controls will be implemented to ensure the safety off all rail users.
ONRSR has recently undertaken an audit of the operator’s railway operations focusing on rail safety worker (drivers') competence and fatigue risk management. As a result of the audit, ONRSR is working with the operator to ensure that deficiencies identified in compliance are being satisfactorily addressed.
In relation to the issues of pre-departure checks and maintenance at a yard, ONRSR rail safety officers will continue to monitor available data and consider the issues when planning future regulatory activities.