National Rail Safety Regulations – have your say
The National Transport Commission (NTC) has just released a copy of the complete National Rail Safety Regulations.
The complete version includes all the regulations included in the last draft, which was opened for public comment in November last year as well as new regulations included to support the Ministerial Council’s policy decisions in May 2012.
Among the proposed amendments are areas relating to fatigue risk management, notifiable occurrences, and oversight provisions which apply to the regulator.
Loco Division Secretary Bob Hayden said the RTBU will be putting forward comments relating to a number of key changes to the regulations.
“There are some notable changes to the regulations which could have a real affect on drivers, including the section relating to the NSW Train Driver Shift Limit. Critically, the Fatigue Management program doesn’t apply to shifts beginning in NSW and finishing in another state. For example a driver on an XPT from Junee to Melbourne wouldn’t be covered according to this draft of the regulations.
“That’s a glaring issue and something the RTBU will certainly be highlighting with the NTC.”
Bob Hayden said other areas of concern include the fact that “the minimum” 30 minute personal needs break for driver-only freight trains between the 3rd and 5th hour has been changed to read “the maximum” and wording around the maximum shift limit for a single driver passenger train has also been significantly altered.
“Changing the word ‘minimum’ to ‘maximum’ in relation to the break completely changes the intent of the legislation. We’ll certainly be seeking an explanation as to why this change was included.”
“The wording around the maximum shift limit is also of concern. The current shift limit for single driver passenger trains is 10 hours, which applies to “interurban and long distance passenger trains”. However in this version of the regulations the wording has been changed to say it applies only to “a long distance train”.
“Removing “interurban” from the wording creates a real grey area. We’ll be seeking clarification as to whether Interurban trains are in fact covered by the legislation, which we would strongly suggest they should given the current legislation indicates that’s the case.
“The NSW Government’s commitment was to retain the current prescriptive train driver hour limits and they haven’t walked away from that commitment to our knowledge.”
The regulations are open for public comment until 5th October. Members can submit their own views directly to the NTC, or email firstname.lastname@example.org to have your input included in the National RTBU submission.
You can view the regulations and an explanatory document on the website here – http://www.nrsrproject.sa.gov.au/news.