Rollingstock Maintenance
Who can do maintenance work / Must they be a rail safety worker / Medical Category?
Can replacement products be used in lieu of original products?
Who can do maintenance work / Must they be a rail safety worker / Medical Category?
Firstly, any individual working on or about the rail network including rollingstock maintenance is classified as a rail safety worker. The tasks being undertaken by the individual will dictate the minimum medical category that individual must meet, in addition to specific and special competency standards required. The following expanded extract from the July Safety & Accreditation report details this along with some examples.Risk Categorisation of a Rail Safety Worker (Medical Categories & Competency Standards)
The question has been raised with regard to what Medical Category & Competency Standards under the Rail Safety National Law are required of persons (members, employees and contractors) with respect undertaking maintenance work in a railway workshop / maintenance facility.Scenario
The activities of four (4) workers takes place in a railway workshop / maintenance facility that is both indoors & outdoors. It consists of rail tracks, hand operated points, drop pits, overhead cranes and other equipment generally found in a rail repair facility. There are controls in place with regard to the movement of rollingstock to ensure there are no persons is on or about the vicinity of rail track where and when a movement of any railway rollingstock is to take place. Correct WH&S measures are adhered to for the varying activities that are taking place with respect to both the work environment and personal where the work is being undertaken, e.g. restricted access area warnings, working at height scaffolding & safety harnesses, welding shields, gloves, hard hats, and other PPE, worker trade certificates (welding, electrical) etc. Several railway workers are undertaking the repair and restoration of an item of rollingstock:Rail worker 1 – is undertaking the welding repair to a bogie using the written instruction of a suitably qualified rollingstock engineer, rail worker 1 is a qualified welder for the type of work he is undertaking.
Rail worker 2 – is undertaking repairs to the exterior including the roof using alternative products that have been deemed suitable for the purposes, rail worker 2 is not qualified, but is undertaking the work under supervision from a suitably qualified person.
Rail worker 3 – is undertaking electrical repairs to the interior lighting and other general power supply, he is not working under supervision as he is a qualified electrician.
Rail worker 4 – is undertaking repairs to the general interior, he is not working under supervision as he is experienced in restoration work.
Question
With respect to the requirements of the:- Rail Safety National Law,
- Rail Safety National Law National Regulations,
- National Standard for Health Assessment of Rail Safety Workers, refer to the attached Extracts from the National Standard for Health Assessment of Rail Safety Workers.
- The four rail safety workers requiring a medical clearance of Category 3 or greater?
- Competency levels do these workers require?
- Assessments of the proposed materials to be used?
ATHRA Response
Prior to any maintenance task being undertaken on a railway, it is imperative that a risk assessment be undertaken in relation to the proposed task, noting that any individual working on or about the rail network including rollingstock maintenance is classified as a rail safety worker.
The risk assessment must include, but is not limited to, the following:
- Minimum medical category requirement for an individual undertaking the task,
- Competency requirements of individuals undertaking the task,
- Can replacement products be used in lieu of original products, material assessments of the proposed materials to be used in performing the task.
Minimum medical category – Using the National Standard for Health Assessment of Rail Safety Workers extract and flow charts on the following pages,
- figure 6 Risk Categorisation of a Rail Safety Worker
- figure 9 Steps in risk assessment process
these rail safety workers are deemed as Non-Safety Critical Workers, meaning they can be classified as medical Category 4, where the following has taken place:
- Comprehensive workplace risk assessments have been undertaken and
- Appropriate control mechanisms are in place for the identified risks, including for the protection of all persons, including all workers, in the vicinity of rollingstock movements.
Note
This does not preclude a rail operator from exceeding these requirements by having a higher medical requirement, although it should be reflected in the risk analysis as to why a higher medical requirement has been chosen for the rail safety worker position and expected tasks to be undertaken.
Extracts from the National Standard for Health Assessment of Rail Safety Workers
Part 2 – The health risk management system
- Risk categorisation of rail safety workers Safety Critical Work/Workers
Category 1 Safety Critical Work/Workers
Category 1 workers are the highest level of Safety Critical Worker. These are workers who require high levels of attentiveness to their task and for whom sudden incapacity or collapse (e.g. from a heart attack or blackout) may result in a serious incident affecting the public or the rail network. Single-operator train driving on the commercial network is an example of a Category 1 task.Category 2 Safety Critical Work/Workers
Category 2 workers are those whose work also requires high levels of attentiveness, but for whom fail-safe mechanisms or the nature of their duties ensure sudden incapacity or collapse does not affect safety of the rail network. For example, in many cases signallers are classified as Category 2 because fail-safe signal control systems protect the safety of the network in case of worker incapacity.Non-Safety Critical Work/Workers
These are workers whose action or inaction will not lead directly to a serious incident affecting the public or the rail network. These workers require health assessments to ensure their own safety while working in or around the network. Non-Safety Critical Workers are also further categorised based on whether their health and fitness will impact on their ability to protect their own safety and that of fellow workers around moving rolling stock. Around the Track Personnel (ATTP) is the term used to describe workers who perform Non-Safety Critical tasks on or near the track as defined. Workers who do not work around the track are not at risk from moving rolling stock and are not required to have health assessments under this Standard. They are classified as Category 4. ATTP who operate in a Controlled Environment are also classified as Category 4 (see red pathway in Figure 6 from the standard below). A Controlled Environment is defined in this Standard as a rail workplace where a risk assessment has been performed to identify hazards and implement controls to ensure that any person working in or transiting the area is not placed at risk from moving rolling stock trains so far as is reasonably practicable. ATTP who operate in an Uncontrolled Environment may be at risk from moving rolling stock. They are classed as Category 3 and are required to have health assessments to identify relevant health risks.
Competency requirements of individuals undertaking the tasks:
Rail worker 1 – is undertaking the welding repair to a bogie using the written instruction of a suitably qualified rollingstock engineer, rail worker 1 is a qualified welder for the type of work he is undertaking. This would be satisfactory, noting it is particularly import in relation to any rail safety related equipment, that both the engineer and the individual undertaking the procedure are appropriately qualified and experienced, it is not unreasonable to check the;
- qualifications with the organisation that issued the engineering degree and certificate of competency, and
- previous places of employment where the same type of welding was
Rail worker 2 – is undertaking repairs to the exterior including the roof using alternative products that have been deemed suitable for the purposes, rail worker 2 is not qualified, but is undertaking the work under supervision from a suitably qualified person.
This is satisfactory on the basis that adequate supervision and inspections are performed prior to commencement, during and on completion of the task.
Rail worker 3 – is undertaking electrical repairs to the interior lighting and other general power supply, he is not working under supervision as he is a qualified electrician.
This would be satisfactory, noting it is particularly import in relation to any rail safety related equipment, that the individual undertaking the procedure is appropriately qualified and experienced, it is not unreasonable to check the
- qualifications with the organisation that issued the trade certificate, and
- previous places of employment where the same type of work was
Rail worker 4 – is undertaking repairs to the general interior, he is not working under supervision as he is experienced in restoration work.
This would be satisfactory, noting no maintenance of rail safety equipment is involved nor items such as electrical and gas equipment is in the scope of works, noting it is not unreasonable to check the previous places of employment where the same type of work was performed.
Can replacement products be used in lieu of original products? of the proposed materials to be used:
Where an alternative product is proposed to be used instead of the original, as part of the risk assessment process that is undertaken prior to commencing the task, a full engineering assessment must be made of the proposed change and in some cases a change notice must be submitted to the ONRSR for approval prior to making the change.
ONRSR Response to medical
The following was the ONRSR response to the specific question on medical requirements.
Based on the info in your email, a Category 4 would seem to be sufficient as the workers appear to be ‘Around the Track Personnel who operate in a Controlled Environment’ (if ‘uncontrolled environment’ they would be Category 3).
Here is the relevant section from the Standard for reference:
Section 5.1. Risk categorisation of rail safety workers (page 29)
Around the Track Personnel (ATTP) is the term used to describe workers who perform Non-Safety Critical tasks on or near the track as defined. Workers who do not work around the track are not at risk from moving rolling stock and are not required to have health assessments under this Standard. They are classified as Category 4.
ATTP who operate in a Controlled Environment are also classified as Category 4. A Controlled Environment is defined in this Standard as a rail workplace where a risk assessment has been performed to identify hazards and implement controls to ensure that any person working in or transiting the area is not placed at risk from moving rolling stock trains so far as is reasonably practicable.
ATTP who operate in an Uncontrolled Environment may be at risk from moving rolling stock. They are classed as Category 3 and are required to have health assessments to identify relevant health risks.
When analysing the risk to ATTP and classifying the tasks into Categories 3 or 4, the features of a Controlled Environment need to be carefully considered regarding their adequacy. If workers may move between Controlled and Uncontrolled Environments, then the higher level of risk assessment should be
applied. Irregular visitors to the track, such as office workers, are not generally classified as ATTP. When they do visit the track, their safety should be ensured by other means—for example, by escort. Further information about assessing Controlled and Uncontrolled Environments is included in Section 6.5. Step 5: Analyse and categorise tasks. Note that workers who access the track receive track safety awareness training on a regular basis, which is another key aspect of their ability to protect their own safety and that of fellow workers.