The reporter has raised the following safety concerns in relation to non-compliant shift rostering resulting in high levels of fatigue and seconded driver training.
The reporter states that forward rostering is not always provided, instead a reverse roster is also provided to Rail Safety Workers (RSWs). RSWs are also rostered to commence a late shift post-rostered days off which is very fatiguing.
The reporter states seconded drivers only have basic traction qualifications with little-to-no route qualifications. A risk assessment process is not completed prior to seconded drivers commencing. The reporter further states electric consists are operated in [Location 1] whereas the seconded drivers are qualified on different classes of diesel locomotives.
The reporter has previously raised the following queries with the rail regulator.
- If a person has been deemed qualified as a shunt driver (not for mainline and no exposure to the mainline) only for the confines of a yard, does the [x] hour shift limit apply when not accompanied by another driver'?
- [Fatigue document 1]. When operating over three depots on a common network and a common manager, RSWs are performing the same tasks with the same risks. Does there have to be three [Fatigue document 1]'s or can one cover all depots?
- Qualified drivers are working with seconded drivers from other networks (mostly from interstate) that have only done classroom safe working for the new network and very basic traction qualification training and have had no other exposure to their new network. Does the [xx] hour shift length still apply when paired with a seconded driver or is a reduced shift length applicable? We have drivers being rostered with seconded drivers for their entire shift block and are having to do all the driving, resulting in high levels of fatigue. We operate on a mentor-driver policy. Trainees acquire their different levels starting out 'three up' before progressing, while also gaining track knowledge before going to the next level. This is also done on a reduced shift length for the main driver until they are qualified as a driver. The last three signal passed at danger (SPAD) incidents have all happened with a seconded driver on board.
- Does the training for seconded drivers comply with ONRSR requirements?
- What training should seconded drivers have aside from safe working?
The reporter states 'all drivers have major concerns working with seconded drivers and whether the level of training that they're given complies with the requirements of the law. This coupled with shift rostering that does not comply with the operator's SMS is creating high levels of fatigue. The last SPAD that occurred only had [length] of clearance to another train'.
In relation to the concern with shift rostering that does not comply with the operator's safety management system (SMS) and subsequently creating high levels of fatigue, and the standard of training for seconded drivers, [Operator] offers the following:
The reporter states forward rostering is not always provided, instead a reverse roster is also provided to Rail Safety Workers (RSWs). RSWs are also rostered to commence a late shift post-rostered days off which is very fatiguing.
[Operator] has reviewed the [Operator] management system documents below and they do not state that forward rostering must be provided. We have reviewed our controls within the SMS.
Adherence to [Operator] Safety Management System:
- [Fatigue document 2] specifically – [Fatigue document 1] which outline controls, scheduling arrangements and work rosters (which outlines rosters and FAID)
- [Fatigue document 3] – [Operator] use this guidance document to create our fatigue risk profiles reviewing controls in consultation with HSE committees.
- [Fatigue document 1] – controls and consultation with HSE committees (including HSRs)
- A [Fatigue risk assessment tool] or (approved tool) must be used in the event of:
- A confirmed [Engineered fatigue system] event in vehicle
- FAID threshold breaches – if worker is conducting rail safety work or safety critical tasks
- Shift limit breach / limitation of hours breach – if worker is conducting rail safety work or safety critical tasks.
- Automatic Train Protection (ATP) failure (driver assessment tool to be used)
- Self-reporting events
- Fatigue rooms in all [Location 2] depots.
Additional circumstances where a [Fatigue risk assessment tool] may be completed include:
- Triggered assessment (supervisor/peer concerned about worker fatigue)
- Following an incident to assist in the determination as to whether fatigue may have contributed to the incident
- Overtime shifts
- Emergency working / call out shifts.
When [Operator] seconds a driver, the seconded driver is kept on the same work group (home depot) roster.
'Late shift post-rostered days off' - without further information [Operator] is unable to investigate this point however note that some drivers request a late start on their first shift back.
The reporter states seconded drivers only have basic traction qualifications with little to no route qualifications. A risk assessment process is not completed prior to seconded drivers commencing. The reporter further states electric consists are operated in [Location 1] whereas the seconded drivers are qualified on different classes of diesel locomotives.
All [Operator] [Commodity] [State] seconded train drivers are Cert IV-qualified train drivers. If we engage a Driver Under Instruction (DUI) under secondment, these personnel are aligned with mentors and limited to [x] hr shifts.
Within [Commodity] [State] all train drivers are [State] safe working qualified which has a theory and practical performance assessment.
If a seconded driver does not hold traction qualification – the shift length is altered – reduced to [x] hrs.
As part of our labour planning, [Operator] review the suitability of a secondment to ensure that we are sending the right level of classification (i.e., Level 4 – qualified train driver) and also review their competencies when it comes to different locomotive class i.e., [number] and [number] class.
[Operator] is working through learnings from recent investigations to understand if our processes can be improved when utilising train drivers across regions via secondment.
ONRSR confirms receipt of ATSB REPCON report RR2024-00004 regarding shift rostering/fatigue and the training of seconded drivers. ONRSR has reviewed the reporter’s concerns and operator’s response.
ONRSR will schedule a regulatory activity to evaluate the systems the operator has in place to manage the competencies of seconded drivers as part of the National Work Program. The activity will include locomotive types, route competency and rostering principles.
In relation to risk management of fatigue, the operator has committed to an enforceable voluntary undertaking (EVU) in response to a previous notifiable occurrence which includes improvements in management of fatigue. Details of the EVU are available on the ONRSR website. ONRSR will continue to monitor the operator’s implementation of the EVU.
ONRSR also has additional guidance material and fact sheets available on the ONRSR website including a fact sheet titled Interpretation of [State] Specific Fatigue Requirements: FAQ’s