Fatigue management for rail protection workers

Our primary concern is for the safety and welfare of all track users and we welcome any system providing the opportunity to review, improve and strengthen our internal management systems should any weaknesses be identified.

1. General Issues

In relation to the general issues raised in the REPCON, our comments are as follows.

1.1 Safety Policy

We are absolutely committed to maintaining a safe working environment for all of our staff, industry colleagues, contractors and network users.

This is expressed in our Safety Policy and communicated at every opportunity to our staff. Our staff have been made aware that they are completely empowered and will have full management support to undertake any action necessary to maintain safety and protect persons.

1.2 Fatigue Policy

We understand the legislative requirements for fatigue management under national rail safety law. We have in place an appropriate Fatigue Policy and undertake a risk management process including full risk assessment to evaluate all risks associated with planned works. Identifying potential fatigue issues is only one element of this process.

Where potential fatigue issues are identified, appropriate controls and mitigations are put in place.

2. Specific Matters

In relation to the specific matters raised in the REPCON, our comments are as follows:

2.1 Fatigue

Generally speaking, shifts worked by our employees are less than 12 hours (maximum of 10 hours preferred) and rarely exceed seven continuous days. Per all of our combined policies, when compiling rosters, consideration is given to above matters. As a company we value 'homework-life balance' and endeavour to ensure our workers are able to spend adequate quality time with family.

We were engaged recently to undertake a significant project over an extended two week period, during which some staff did work 12 hour shifts over a maximum of seven days; however this is a rare occurrence in our history. A full risk assessment of this decision was included as part of the project planning.

Staff were fully briefed on the project requirements and activities and alerted prior to commencement of the project of the potential for fatigue. Mitigations were in place throughout the duration to ensure staff maintained fitness for duty and were well supported at site with 24 hour supervision and Management present on site.

2.2 Competencies

In keeping with national safety requirements, all staff are permitted to undertake only those activities for which they are fully trained and qualified having regard to the specific competencies defined by the track owner. Currently, these competencies are identified and logged using the rail safety worker card scheme (Pegasus) introduced by Australian Rail Track Corporation (ARTC) and now administered through the Australasian Railway Association (ARA). This is a rigorous process requiring all qualifications to be verified and validated. Complete records are held on file.

An occasion did occur recently where staff were stood down from a project after a query was raised concerning competencies for a new client. In this instance the client had initially validated our staff competencies (reflected in their own systems as well as Pegasus), before changing its position internally; the error therefore was with the client processes.

Subsequent to this occurrence, management has written to that particular client suggesting they need to undertake an internal review to strengthen and clarify their internal systems to avoid potential future incidents. At no time has any correspondence been received by us, either internally or externally, reflecting the concerns raised in the REPCON.

Based on the above, our Executive is satisfied that we are complying with all safety requirements and provide a safe working environment for all workers and contractors.

Nevertheless, per our comments at the beginning of this letter, we welcome all opportunities to review ourselves and strengthen our commitment to safety.

As a result of this Report we intend to:

• Re-issue and bring to attention of all staff both the Safety and Fatigue Policies.
• Remind all staff of their responsibilities to maintain a safe work environment.
• Re-emphasise to staff that they are empowered to act if concerned about any safety hazard; regardless of the nature.
• Review our recruitment processes to place further emphasis on these policies.
• Review our sub contract arrangements to place further emphasis on these policies.

Any other associated documents will be furnished to the Rail Regulator as required.

We support any mechanism to achieve 'Zero Harm' in our industry and would welcome any further discussions deemed necessary.