Multiple reporters have raised a safety concern regarding the lack of training and competency records for train drivers at [Operator].
The reporters collectively state when they requested a copy of their competency checks and qualifications, they were told that no records existed.
One reporter states that when they commenced with [Operator] after working for many years with another operator, no training records were transferred to [Operator], meaning [Operator] effectively had no way of verifying that the reporter was a qualified driver, or when the reporter's next competency check was due. The reporter further states that on request, a train driver certificate was provided by [Operator] however there were no authorised signatures on the certificate to prove authenticity.
Another reporter states that drivers at [Operator] are required to complete four blocks of continuation training every two years to remain qualified. However, the reporter advises they have only ever completed two blocks in over [number] years of employment with [Operator] and there are no records of these completed blocks.
The reporter queries how [Operator] is assured that all their drivers are appropriately qualified when training and competency records are not maintained. The reporter believes that the Rail Safety Act requires all operators to maintain training records for at least seven years.
One reporter further states they had previously been threatened with refusing duty from supervisors when they declared they had not been trained to do a task.
The reporters collectively state when they requested a copy of their competency checks and qualifications, they were told that no records existed.
Driver training records are captured in [Operator]’s Learning Management System (LMS). Records are made available to drivers on request.
One reporter states when they commenced with [Operator] after working for many years with another operator, no training records were transferred to [Operator], meaning [Operator] effectively had no way of verifying that the reporter was a qualified driver, or when the reporter's next competency check was due.
Trainee drivers recruited to [Operator] as already holding a driver qualification are assessed by gap analysis to determine the level of training required to become an [Operator] driver. After completing the required theory and practical training, drivers are assessed on both theory and practical competency to operate as a qualified [Operator] driver.
The reporter further states that on request, a train driver certificate was provided by [Operator] however there were no authorised signatures on the certificate to prove authenticity.
Upon qualification, drivers are issued with [qualification] in train driving from our registered training organisation (RTO). Prior to [Operator] becoming an RTO on approximately [date], [Operator]-only local certificates were issued. Certificates were issued as acknowledgement of qualification to the [Operator] driver competency.
Another reporter states that drivers at [Operator] are required to complete four blocks of continuation training every two years to remain qualified. However, the reporter states they have only ever completed two blocks in over [number] years of employment with [Operator] and there are no records of these completed blocks.
The requirement to attend ‘continuation training’ (refresher training) is an enterprise agreement requirement and the process is documented within [Operator]’s safety management system (SMS). The requirement is for a driver to attend one block (two days duration) of continuation training annually. Currency of the training is monitored and reported on weekly.
The reporter queries how [Operator] is assured that all their drivers are appropriately qualified when training and competency records are not maintained.
Refer to previous item relating to learning management system records. Drivers also undergo annual practical checks, carried out by our driver supervisors. This process is documented in our SMS and records maintained in the competency management system.
The reporter believes that the Rail Safety Act requires all operators to maintain training records for at least seven years.
RTO training documents are maintained for 30 years.
One reporter further states they had previously been threatened with refusing duty from supervisors when they declared they had not been trained to do a task.
Drivers are trained to meet the operational requirements of the roster for their home depot and task rotation.
The ATSB notes multiple reporters have stated the operator has not specifically addressed how authentic train driver qualifications obtained prior to 2013 are recorded and provided if requested by the employee. The ATSB requested a further response of the operator to address this specific concern. The operator response to this further request follows:
- Following the privatisation of the [State] public transport system, [Operator] established a partnership with [training provider] in [year] to provide all our driver and shunter training and meet a significant proportion of our safeworking training needs.
- In [year], [training provider] notified [Operator] of its intent to cease providing training services to the rail industry on [date].
- During this time [Operator] relied on [training provider] to meet all of our driver training requirements and the majority of our safeworking training requirements. This reliance on [training provider] presented a major risk for [Operator] because both driver and safeworking training are critical to the sustainability of the business. Driver training is also an integral part of the driver workforce planning framework, which ensures that [Operator] has the driver capacity to deliver rail services.
- [Operator] reviewed and evaluated available options for the ongoing delivery of the driver training program. This analysis identified that there were no suitable alternative Registered Training Organisations (RTOs) in [State] with the vocational expertise to provide driver training to [Operator] on a fee for service basis. An interstate-based private RTO was identified as a possible alternative option; however, this RTO did not have the capacity to meet [Operator]’s needs.
- [Operator] decided to deliver an internal driver training program, as training our employees and maintaining and developing their skills are a key strategic element of our business. This enables us to deliver driver training that is contextualised to our business and supported by the expertise of our operations standards team. It also enables us to achieve greater quality control of the training program, resources and materials.
[Operator] maintained internal training for drivers while RTO accreditation was applied for in the period 2010-2012. During this time, the training was to a Cert IV equivalent standard, but effectively ‘in-house’ and suitable for [Operator] purposes only. During this time, [Operator] began issuing ‘Train Driver Certificates’ to newly qualified trainee drivers as a token of their efforts, these certificates were generally not given to conversion drivers as they already held a qualification.
Once our RTO accreditation was attained, [Operator] reverted to Cert IV certificates.
While the historical training files passed on to [Operator] were not complete, our processes for record keeping have evolved significantly and will continue to improve as systems that support training develop.
Every endeavour is made to supply drivers with historical training data/evidence when requested. However, if a given file is not available (due to age of file, different a training course/topic or there is no file) then alternate forms of evidence of competency is provided, such as continuation (refresher) training results and annual assurance checks.
Driver training history timeline provided to the ATSB and ONRSR.
The first group to complete driver training in the student management system we use commenced on the 2/7/2012.
The [Operator] RTO Pty/Ltd was formally registered in [State] 8/12/2011 and it would have taken the RTO a good six months to get their documents in order to start the first class.
ONRSR confirms it received ATSB REPCON report number RR2023-00026 regarding lack of train driver training records and documentation. ONRSR has reviewed the reporter’s concerns and operator’s response. In mid-2023 ONRSR received information regarding similar matters and made further enquiries with the operator and received additional information. ONRSR will consider additional information received from the operator and the contents of this REPCON report in the planning of further regulatory activities involving driver competencies as part of ONRSR’s national work program.