RTBU

Safety, Standards & Regulation

RTBU criticises fatigue management guidelines

The Rail Tram and Bus Union (RTBU) is pushing back against a draft fatigue management guideline that it argues undermines regulated maximum shift hours, which apply in Queensland and NSW.

The draft Fatigue Risk Management Guideline, published by the Office of the National Rail Safety Regulator, outlines the steps that rail transport operators should undertake to manage fatigue-related risks of rail safety workers.

The draft suggests that high fatigue risks may be offset through other factors. The draft gives the example of work that must be done at night which increases the risk of fatigue because at these times alertness is reduced and it is not possible to obtain night sleep, which is most efficient for recovery. These factors could be offset by shortening the total length of night shifts, minimising consecutive shifts, or implementing a reset break between sequences of night work to allow time for recovery.

RTBU secretary Mark Diamond wrote in a submission to the guideline that this approach of “offsets” would undercut safety.

“By taking a non-prescriptive approach, the draft guideline pushes the burden risk management assessment onto operators. Ultimately that means people who are untrained in this field, and/or have little exposure to the needs of the working environment, will be required to make subjective judgments about safe practices.”

Under the Rail Safety National Law, transport operators are required to, so far as reasonably practicable, ensure that rail safety workers do not carry out rail safety work while impaired by fatigue or if they may become so impaired. To meet this requirement, transport operators must have a safety management system that includes a fatigue risk management plan.

In NSW and Queensland, in addition to these requirements there are prescribed hours of work for train drivers. In both states, drivers are largely limited to nine hours in one-person operation and 12 hours in two-person operation where the second driver is a qualified train driver.

ONRSR chief executive and National Rail Safety Regulator Sue McCarrey said that safety risks were not affected by more proscriptive regulation.

“ONRSR’s 2018 review of the fatigue risk management arrangements under the RSNL found no conclusive evidence to demonstrate that jurisdictions operating under a full risk-based framework for all rail safety workers pose any greater rail safety risk than jurisdictions which have prescribed hours for train drivers,” she said.

McCarrey said that the draft guideline was developed with expert input.

“As part of the fatigue risk management review, ONRSR engaged two fatigue experts to develop principles of rest and recovery which address key factors associated with the scheduling of work. An essential element of the fatigue risk management process is how the principles interact. If work schedules have an elevated fatigue likelihood, this can be managed via offsetting principles to manage the risk to safety or by introducing other controls to reduce rail safety risks.”

In a recent review of national rail safety legislation the Productivity Commission highlighted fatigue management as one area where efficiencies could be improved.

Diamond wrote that the national standard should follow the regulations in Queensland and NSW.

“Any application of a risk management approach in the Australian rail sector must be done within the constraints of clear, prescribed minimum standards. The RTBU contends that the strict standards regulating hours of work for traincrew in NSW and Queensland should be considered as industry best practice when it comes to fatigue management.”

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 Below Rail Infrastructure, Freight Rail

WA to progress business cases for reopening three Tier 3 grain lines

The Western Australian government has committed to developing three business cases for the reopening of three Tier 3 grain lines in the state.

The three lines to be looked at for reopening at, Quairading to York, Kulin via Yilliminning to Narrogin, and Kondining via Narembeen to West Merredin.

The combined cost of upgrading the three lines to narrow gauge standard is $486 million. As part of the investigation the WA government will consider upgrading the Kondinin to West Merredin line to standard gauge at an extra cost of $27.41m.

The three lines were chosen based on an engineering assessment released on September 24 which estimated the cost of reopening Tier 3 lines throughout the wheatbelt.

WA Transport Minister Rita Saffioti said that the report found that certain lines could be reopened.

“While the engineering report confirms restoring the entire network would involve significant costs, there are arguably specific lines where the cost of investment could be offset by ongoing commercial and community benefits such as reduced truck volumes on local roads and cost savings to farmers.”

Arc Infrastructure, which manages the WA freight rail network, said it would support the government and grain growers cooperate CBH Group in the submission of business cases to Infrastructure Australia.

“Arc acknowledges that the government has identified an opportunity for the development of business cases to be submitted to Infrastructure Australia, for rail freight investment proposals on the Tier 1, 2 and 3 rail networks. Arc will support government and CBH in this process,” said an Arc Infrastructure spokesperson.

CBH Group, which represents grain growers throughout the state, said it would also support the efforts to make grain transport economically viable.

“We will work with the state government to progress those business cases, including providing information on any impacts of re-instating those lines on the grain supply chain or grower freight rates,” said a CBH Group spokesperson.

“CBH supports grain transport by rail where it is economically viable and the least cost pathway to port.”

The government announcement was also welcomed by the Rail, Tram and Bus Union (RTBU), with WA secretary Craig McKinley calling on the federal government to support the reopening of these lines.

“The Western Australian government is supportive of the need to rebuild key sections of track, and the commitment to undertaking business cases is very heartening,” he said.

“We hope that the business case stage can be completed quickly, so we can move on to securing funding and getting construction underway.

“The reconstruction of Tier 3 lines is exactly the sort of project that the Australian government should be investing in.”

Saffioti said the business cases will be developed in consultation with CBH Group and Arc Infrastructure before being submitted to Infrastructure Australia for potential federal funding.

“Significant funding contributions from the federal government – as per other major regional infrastructure projects – would be required for any potential Tier 3 restoration work in the future.”

The Tier 3 grain lines were closed by Arc Infrastructure in 2014, then known as Brookfield Rail. The Tier 3 lines were seen at the time as not commercially viable. With the resultant shift of grain volumes to road, road maintenance costs have increased, and safety concerns have been raised by the local community. These factors led to the WA government investigating the viability of reopening the lines earlier in 2020.