Safety concerns regarding fatigue management
Multiple reporters have raised a concern regarding fatigue management of driver only operations at [Location] depot.
The reporters advise that [Operator] fatigue management system requires drivers to have a FAID score of less than 80 to perform driver only operations. Drivers may continue to operate with FAID scores of up to 100; however, the operation is required to be two driver.
The reporters advise that many drivers from [Location] in recent weeks have recorded FAID scores in the high 80's/low 90's. When this occurs, often a trainee driver is being rostered as the second driver. The reporters state that the trainees are not yet route or even locomotive qualified. The reporters believe the practice of rostering trainees as the second driver does not mitigate the risks associated with driver fatigue and may actually increase the risk of an incident occurring. The potentially fatigued driver must maintain a higher level of vigilance while conducting not only their own duties, but also when monitoring another unqualified person.
Another reporter stated that when a driver's FAID score reaches 80, it is meant to be flagged, and any further shifts for that driver must be constructed as two driver shifts, which permits the driver to continue working and for their FAID score to progress up to 100.
However, one reporter provided examples where drivers had FAID scores of 82, 86, 86, 92 and 83 and were rostered on driver only shifts without flagging the heightened scores with rostering or depot supervisors. The reporter advises that these specific incidents were all manually constructed as two driver shifts in the rostering system by rostering personnel - which avoided any fatigue alerts, but were subsequently manually entered on to the roster as driver only shifts. The reporters advise that the fatigue management issues appear to be limited to the [Location] depot and not other depots across the state.
The reporters are unsure if the rostering of drivers with heightened fatigue as driver only operations is an individual error or if this is a deliberate attempt to ensure driver only operations continue without alerting heightened fatigue scores. Regardless, the reporters believe there should be a systems solution implemented to ensure that these breaches are not able to occur.
In response to the REPCON, at no stage have either the [Location] depot Superintendent or [Operator] supervisors been contacted by any train crew at the end of any shifts regarding high fatigue concerns.
[Operator] operational leaders have noted that there was one instance where a fatigue level was at 103 on [date] at sign off, this is currently being investigated.
The following points were made in your email to us.
1. Driver’s may continue to operate with FAID scores of up to 100; however, the operation is required to be a two driver.
Response: The operation is required to have one driver and a person that is a qualified driver’s assistant; not two drivers.
2. Often a trainee driver is being rostered as the second driver.
Response: Trainee drivers are rostered as a two up configuration and utilised as a qualified driver’s assistant.
3. One reporter provided examples where drivers FAID scores of 82, 86, 86, 92 and 83 and were rostered on driver only shifts without flagging the heightened scores with rostering or depot supervisors.
Response: All these driver jobs were rostered as two up driving roles from commencement of shift. This was done to mitigate safety concerns and operate the service as a two person crew.
Extracts from fatigue documents contained within [Operator's] Safety Management System were provided.
ONRSR has considered details in this report in the scope of a regulatory activity that was scheduled and has been undertaken in January 2022. The outcomes of the regulatory activity will be communicated to the operator and managed in accordance with ONRSR procedures.