ONRSR Fatigue Risk Management Review

As Members may be aware, ONRSR, the National Rail Regulator, have undertaken a Fatigue Risk Management Review at the request of Ministerial Council.

The Regulator states that their objectives in undertaking the fatigue risk management review are to:

• Examine current fatigue risk management legislation and policies to determine the appropriateness and effectiveness of different requirements prescribed within the RSNL.
• Consider leading practice approaches to the regulation of fatigue risk for all rail safety workers, particularly within a co-regulatory model.
• Assess options for fatigue risk management in terms of safety and regulatory burden on industry.
• Recommend a consistent national regulatory approach.

Of concern for Locomotive Division Members is that any changes to implement risk based fatigue management could see the removal of prescribed outer limits for hours of work currently in place within New South Wales and Queensland. These prescribed outer limits sit within schedule 2 of the Rail Safety Nation Legislation and apply specifically to rail safety workers driving trains.

Schedule 2 currently prescribes the following for NSW train drivers:

• Maximum shift lengths depending on the type of train driven (freight or passenger) and whether it is a single manning or two person operation.
• Minimum break length between shifts depending on whether taken at, or away from, the home depot.
• Maximum numbers of shifts and hours in any 14 day period.
• Requirements in relation to the maximum amount of time allowed between signing on for a shift and reaching the home depot or barracks when travel is involved in getting to the home depot or barracks.

We believe these limits play an important role in the safe operation of trains within New South Wales and Queensland any potential removal should concern all Members. Your Union is also concerned that rail operators may see these potential changes as an opportunity to further water down rostering protections and industrial agreements.

Any outcome that removes current Schedule 2 minimum standards and leaves Employers to opportunity to govern shift limits through Company Fatigue Risk Based process would be like putting Dracula in charge of the blood bank!

The Locomotive Division encourages all Members to read the attached discussion paper and provide any feedback or concerns to the National Rail Regulator or directly to the Locomotive Division.

Click here to download the paper.