The RTBU is unequivocal in its belief that strict standards of fatigue management must be consistently applied across all states and territories. However, these standards must be consistently high, not consistently low.
The RTBU has prepared this response to the Office of the National Rail Safety Regulator's Fatigue Risk Management Review Consultation Paper.
Australia’s risk-based, co-regulatory and non-prescriptive approach makes us the odd country out when it comes to rail transport safety. Hours of work and rest limits form part of fatigue risk management systems worldwide in rail and other transportation sectors
The RTBU has many reservations about a purely risk-based approach to fatigue management and any attempts to downgrade prescriptive hours of work regimes. These include reservations about the lack of involvement of rail safety workers in risk assessment, and whether they have the requisite skills to comply with a combined approach to risk; reservations about the maturity of many accredited parties to understand and apply a risk-based approach; and reservations about regulators’ ability to pro-actively manage risk.