The reporter has raised the following safety concerns in relation to non-route qualified Freight Operators continually rostered to perform shunting and control panel duties.
The reporter provided the following example:
After a reported derailment, it was discovered that one of the two Freight Operators was not route qualified for the particular section of track. The reporter acknowledged that the incident was a mechanical fault with the points however they were not advised at sign on that one of the Freight Operators was not qualified to perform shunting or panel duties at the location. The reporter states, they were not advised at the toolbox talk by the [position title] at the commencement of their shift. It seems that the [Operator] [leadership position] at [Location], think this is okay to roster non-route qualified Freight Operators on this kind of work as a cost-saving measure instead of bringing route qualified staff in on their rostered day off to work these duties as well. The reporter further states, this is not the first time non-route qualified Freight Operators have been rostered to conduct shunting and panel duties in this location.
The reporter advised there should have been two qualified Freight Operators on shift (three in total) in order to provide adequate supervision of the non-qualified Freight Operator in accordance with [Operator]'s standard.
Thank you for your Notice advising of this REPCON. [Operator] acknowledges the reporter’s concerns and provides a response on each element below.
The reporter has raised a concern relating to the operation of rollingstock at a location which the Freight Operators were not qualified to perform shunting or panel duties. The reporter further advises this was not raised at the toolbox talk at the commencement of the shift.
[Operator] can confirm Freight Operators are permitted to perform the duties listed above, provided these operators are under the direction of a yard familiar Freight Operator. [Operator]’s [standard 1] and related training governance documentation do not require any further qualification. A shunt plan was completed compliant to [Operator]’s [standard 2] that identified the single authorised worker and the responsibilities of all competent workers for the shunt movement.
The reporter states the aforementioned example is not an isolated incident of non-route qualified Freight Operators conducting shunting and panel duties in this location
As above, it is acceptable per [Operator]’s SMS that a non-yard familiar Freight Operator conducts rollingstock movements in [Location] with sufficient oversight. [Operator] has not received any reports of non-yard familiar Freight Operators conducting shunting and panel duties at [Location] without the suitable supervision required.
[Operator]’s standard dictates that two qualified Freight Operators (three in total) should have been on shift in order to provide adequate supervision of the non-qualified Freight Operator
[Operator] is unsure of the standard being referenced here. There is no requirement that dictates two yard familiar Freight Operators are required to oversee a non-yard familiar Freight Operator. In relation to the shift described above, both workers were qualified to perform their role as Freight Operators. One Freight Operator was not yard familiar with [Location], however this individual has been signed off as a competent Freight Operator.
The reporter is of the belief that [leadership position] at [Location] are intentionally manufacturing rosters with non-route qualified personnel
All movements scheduled by [Location] leaders have been produced in accordance with [Operator]’s standards.
ONRSR confirms it received ATSB REPCON report number RR2024-00011 regarding non-route qualified freight operators performing shunting and control panel duties. ONRSR has reviewed the reporter’s concerns and operator’s response. The information in the report will be considered in the scoping of a regulatory activity conducted on the operator as part of the ONRSR National Work Program. This activity will include a focus on the operator’s management of rail safety workers working in yards and locations where they may have limited route knowledge.
The reporter provided a response to the operator's response with additional concerns as follows:
I wish to say that I have read the operator's response and wish to point out a few concerns.
The Rail Operator (company) states in a response, that the second qualified freight operator is safe to operate this panel if being mentored by the first fully qualified freight operator. I remind you that on this particular day, the first (lead) fully qualified freight operator giving the mentoring was up to 800 metres away from the panel. There is no way that the first Freight Operator can be certain that their instructions given to operate certain switches for signal and points settings, by the second unqualified freight operator, can be carried out correctly or safely, if the first freight operator is not directly watching the unqualified freight operator. This is why two fully qualified Freight Operators needed to be rostered on, and the unqualified Freight Operator to be mentored on shunting and panel duties.
I would like to see a rail regulator representative attend these shunting duties at [Location] to understand how these shunting/panel duties are carried out before making a final outcome on the concerned safety issue.
I would like to point out, that a bus driver giving mentoring to a new bus driver, does not sit at the back of the bus giving mentoring instructions. Also a pilot mentoring a new pilot, does not sit at the back of the aircraft giving mentoring instructions. They are both seated as close as possible to the learning participant for mentoring. So how is an unqualified Freight Operator operating a panel/and or shunting at a new location different from the above scenarios?
The ATSB invited the operator to provide a further response which has been supplied as follows:
In response to the reporter's concerns, [Operator] reiterates that both Freight Operators in the referenced incident are fully qualified Freight Operators having passed the mandatory qualifications in setting points, and operating switches. There is no mandatory level of oversight prescribed for familiarisation, as the proximity of the yard familiar Freight Operator and level of supervision is to be determined by the yard familiar Freight Operator, varying in accordance with the nature and complexity of the task.