The reporter has raised the concern that the [Operator] fatigue risk management plan (FRMP) train services procedure [for a metropolitan passenger service] is not being observed in roster shift planning at [Location]. This is consistent across almost all published rosters, slipped shifts and day of operations allocations.
The reporter states drivers are routinely rostered on shifts without any rest breaks as stipulated in the FRMP which states sufficient and regular rest breaks will be provided during shifts. For example, the FRMP clearly states the driver will be provided with a seven-minute rest break at outstations and 10 minutes at [Location], 13 in the peak. The FRMP states this time is a rest break. A legitimate rest break plus the task times of change of ends/platforms time should be rostered, meaning a minimum of 12 minutes between arrival and departure at outstations, and 16 minutes at [platform numbers], 18 minutes at [platform numbers], and 19-21 minutes in the peak according to their own FRMP.
The times between runs do not allow for the tasks of completing handover of train and changing platforms while also having a legitimate rest break. These times are stipulated in the ‘Train Driver Roster Information Guide’ on [program] and at the front of the roster books. Time is often eroded on top of this by late running (pax loads, wheelchairs, deliberate under timetabling of runs), queuing of trains, and phoning in or reporting late running, which occurs regularly due to timetabling conflicts and other known delays.
The consideration of rest breaks appears to be ignored for time spent on standby trains, where drivers are ready for immediate allocation of work, between runs at [Location], changing ends or changing platforms, walking to sidings/taxi pick up, and travel by train or taxi as part of a rostered shift. These tasks are often rostered back-to-back without any ‘rest breaks’ as stipulated in the operator's FRMP train services. Drivers are put under pressure to complete tasks without any legitimate rest breaks.
The reporter further states that shifts commencing prior to 0300 are routinely rostered in excess of 7.5 hours, which does not comply with the FRMP train services. In addition to commencing these night shifts with an increased risk of fatigue, drivers starting at this time are subject to high workloads such as multiple train preparations in degraded conditions in all weather, docking up delays due to multiple train movements and transposals, passenger loading delays, trespassers, inclement weather, degraded track and yard conditions, multiple trackside distractions from major works and potential track, signal faults, radio calls, etc. Drivers who have raised these matters prior to the shift are told by management that the shift passes the test using [Operator] systems and this clause is 'where practicable'.
The reporter states that [Operator] fatigue assessment scores do not appear to update accurately the actual operational delays on shifts, nor standby shifts to reflect the actual daily running, resulting in fatigue not being accurately
monitored in real time.
There is no mechanism to check on rest breaks for drivers impacted by delay or adverse conditions and situations, which means drivers are left to push through their rostered shift without adequate fatigue management supports.
The reporter believes fatigue reporting is discouraged. The reporter states, 'any driver who complains of fatigue is advised it's their issue to manage and if it repeats, that their fitness for duty is questioned'.
[Operator's] standard roster for train drivers is developed with agreed times such as a meal break, walk times, change ends times, etc. as outlined in the industrial agreement. These times are the minimum times allowed for the task or duty specified. The roster is assessed using the rest and recovery checklist in fatigue risk management guidelines and the FAID model which seeks to minimise the likelihood of fatigue and maximise the restorative effect of rest and recovery.
Roster amendment slips are required where there is a variation to the standard rostered shift, usually as a result of training, occupations or government project deliverables, and are amended in accordance with standard rosters times applicable to the duties contained within.
[Operator's] train driver rostering system has the capability to allocate the agreed times for the duties to be assigned. We acknowledge that with the introduction of a new day of operations allocations solution, there is a gap in our daily rostering when there is an alteration to the shift on the day. Currently the system does not have a validation to guarantee a minimum of five minutes rest break between runs at a termination location, inclusive of change ends and walk time. We are working with the vendor to fix this, but it may take up to nine months to find a solution. In the meantime, we have implemented a manual process to ensure that drivers have been allocated sufficient time between runs at [Location] and at outstation locations. As an additional measure, drivers can notify the Driver Allocation Officer (DAO) team when there is insufficient time allocated, allowing the team to rectify the issue.
Rest breaks between runs includes task times of change ends and walk times. The intent of this allocated time is to allow drivers to change ends, hydrate, use facilities as required and walk to be in position for their next run. The rest break does not include handover of train which has been built into the timetables (i.e. 1 minute handover).
In the current standard drivers’ rosters, the average rest break between runs, including walk time, is 18 minutes at [Location] and 19 minutes at outstations on weekdays. On weekends, the average rest break between runs including walk time is 20-21 minutes at [Location] and 25‑27 minutes at outstations. The minimum rest break including walk time, is 11 minutes at [Location] and eight minutes at outstations. Drivers are getting more rest break than specified in the FRMP (i.e. 10 minutes at [Location] and seven minutes at outstations). We acknowledge that the wording ‘rest break during shifts’ in the FRMP train services can be misinterpreted or is misleading. We will endeavour to make necessary corrections to include walk time as part of the rest time. The FRMP will be reviewed by the end of this year.
The operator provided the ATSB and the regulator with a table outlining the minimum, average and maximum rest breaks including walk times, that have been extracted from the current [Operator] standard drivers’ rosters.\
Drivers have also been given an average of 42 minutes meal break excluding meal prep, wash and walk time - the enterprise agreement allows 20 minutes for meal break. Adequate rest breaks are scheduled during shifts in accordance with the FRMP.
When drivers are tasked to man a standby train or being available, they are untasked until they are assigned a driving duty by the driver allocation team. If a driver needs to leave the train to use the restroom, they can notify DAO. Changing ends, walking to sidings, changing platforms, taxi pick up, and travel by train or taxi. Tasks are rostered back-to-back for the driver to fulfil the job, with each task having a time allowance to make a duty.
The shift duration restriction on early start shifts (prior to 0300) is only applied at the standard roster construct but is subject to change to meet operational demand on a daily basis and drivers are notified no less than 48 hours prior to their shift commencing of the change. [Operator] makes every effort to keep shifts commencing before 0300 to no more than 7.5 hours. A majority of the shifts that commence prior to 0300 and extend beyond 7.5 hours are either full standby shifts or have large portions of time with no duties assigned. When these shifts are adjusted on the day of operation to meet demand, the applicable mandatory break times are applied.
[Operator] uses the FAID model which is based on rest and recover principles and does not take into account duty contained on the shift.
The [Operator] day of ops system updates in real time with delays and can flag if the driver requires a meal break. The driver allocation team will address the issue by uncovering the next runs in order to provide the driver with the
necessary meal break. Occasionally, a driver may be required to stay on a train due to an unplanned operational incident (i.e. trespasser struck, overhead disarrangement, etc.). In these incidents, every effort is made to relieve the driver as soon as practicable if safe to do so or when the service reaches a safe platform to effect relief. Drivers may be released from the rest of their shift or be provided an extended break. Drivers also have the option to report fatigue during shift to the duty manager.
[Operator] proactively monitors driver fatigue on a continual basis and has controls in place to monitor driver fatigue. Planned FAID scores that rise by 30 FAID points or more and are between 90 and 99.99, or scores 100+ are flagged to the driver’s managers via daily reports. The driver’s manager will contact their drivers to conduct fatigue management assessments. The procedure is set out in the FRMP train services and must be followed and fatigue assessment form to be completed.
The report on driver fatigue for the last 13 months is as follows: 5.6% of all shifts had a FAID score of 80 or higher.
ONRSR has reviewed the reporter’s concerns and operator’s response. The information provided will be considered in the planning of upcoming regulatory activities with the operator as part of ONRSR’s National Work Program.