View the feedback we have received on the Consultation Report - Review of the National Standard for Health Assessment of Rail Safety Workers paper.

• File
  • Draft Revised National Standard for Health Assessment of Rail Safety Workers -Marked Up version of NTC doc.pdf
• Are the proposed changes to Part 1 appropriate?

  Marked up copy under 1.1 which starts with As part of a rail transport operators accreditation: Remove paragraph, unnecessary, or reworded to become Health and Fitness standard is managed in accordance with NTC requirements or RSNL requirements. Similar wording is also under 1.3.1 which would also make this paragraph unnecessary.

• Do you have any further comments on this issue or other issues to be considered in Part 3?

  Please see attachment

• Do you have any comments on the changes to the cardiovascular chapter or other issues that need to be considered?

  Criteria in Table 18 is not listed, please see comment on page 167 on the table under sleep apnoea: What is the compliance criteria? Is it the same as commercial drivers? i.e. “Minimally acceptable adherence with treatment is defined as four hours or more per day of use on 70 per cent or more of days Also, unfinished benchmark? AHI > or = to ?? Highlighted yellow , same under Moderate sleep apnoea unfinished? 3.5.8 General considerations: comparison of road crash data(risk taking behaviours) see marked up attachment The effects of specific drug classes: same as above comments - road data/percentages taken out of context from road to rail. Antidepressants same as above comments

• Do you have any comments on the changes to the diabetes chapter or other issues that need to be considered?

  If the comments/studies are based on someone who has had diabetes for more than 10 years, what about less than 10 years? Also now use of STOP-Bang which can provide skewed results for non-male participants

• Do you have any comments on the changes to the dementia chapter or other issues that need to be considered?

  No

• Do you have any comments on the changes to the epilepsy chapter or other issues that need to be considered?

  No

• Do you have any comments on the changes to the neurodevelopmental disorders chapter or other issues that need to be considered?

  Marked up copy attached

• Should new criteria and guidance be included regarding psychogenic non-epileptic seizures as per changes to AFTD?

  N/A

• Do you have any comments on the changes to the psychiatric conditions chapter or other issues that need to be considered?

  N/A

• Do you have any comments on the changes to the sleep disorders chapter or other issues that need to be considered?

  Yes, see marked up copy of with comments on Table on page 167 Page 164 under Referral for polysomnography: While the gold standard test for ......Poor wording. Suggest change to preferred method, or best practice? Pg 167-Criteria: What is the compliance criteria? Is it the same as commercial drivers? i.e. “Minimally acceptable adherence with treatment is defined as four hours or more per day of use on 70 per cent or more of days-see marked up comments Use of standards outside of Australia or rail industries

• Do you have data (highlighted in bold in Table 3) to support the cost benefit analysis for the proposed changes to the sleep criteria?

  No

• Do you have any further comments on this issue or other issues to be considered in Part 1?

  Thanks for the opportunity to provide feedback. Of primary concern to Aurizon is the impacts of the changes to testing benchmarks. Whilst not yet quantified, there will be significant cost to rail operators, as well as potential constraints in the availability of testing providers in regional areas to manage the increase in volume for example the proposed hearing test criteria. The benchmarks have not been justified with any risk-based argument that would support the significant impact to operators. Aurizon also provides a marked-up PDF document (attached) with comments noted against relevant sections. Of note, Aurizon believes the strong references made to road safety data are misleading, as there has been no correlation made to the way those risks present in a rail environment. Aurizon would appreciate changes to these sections being considered, in particular where road crash data is used to justify changes. Judi Mewhinney on behalf of Brendan James

• Do you have any comments on the changes to the hearing chapter or other issues that need to be considered?

  Yes, please see marked up copy. No evidence to substantiate changes. Why do we not use Aust standards? Could not locate actual evidence to back up changes for rail?

• Do you have data (highlighted in bold in Table 4) to support the cost benefit analysis for the proposed changes to the hearing criteria?

  Aust standard for Aust rail. OR UK legislation also. Link in marked up doc.

• Do you have any comments on the changes to the vision chapter or other issues that need to be considered?

  No

• Are the proposed changes to Part 5 appropriate?

  Not sure about suggesting a gang supervisor touch someone, especially if its a female without further clarification i.e. on the shoulder? 5.2.3 table 23 suggest we use Aust standards data or provide evidence to support the changes?

• Do you have any further comments on this issue or other issues to be considered in Part 5?

  See marked up copy

• Are the proposed changes to Part 6 appropriate?

  Exception is the STOP-Bang questionnaire, which can skew results for non-male workers

• What transitional arrangements should the Standard allow for? How much time would rail transport operators need to transition to changes to the fitness for duty criteria?

  36 months - additional staffing etc

• Do you have any further comments on this issue or other issues to be considered in Part 6?

  Please see marked up copy attached

• What are your preferences as to how implementation of the Standard should be investigated and assessed going forward?

  Further review needed for criteria and reference material.

• Are the proposed changes to Triggered Health Assessments appropriate in clarifying the nature and application of such assessments (section 2.2.6 of the Standard)?

  N/A

• Do you see any risks emerging as a result of the proposed changes to the fitness for duty categorisation (section 2.3 of the Standard)?

  Categorisation no, just the criteria as in the marked-up copy that is attached.

• Do you have any suggestions as to how the risk assessment process could be strengthened in the Standard (section 2.4 of the Standard) or as part of implementation?

  By providing rail studies perhaps that gives direct correlation to rail as opposed to using road crash data

• Are there any implementation issues that should be addressed in the out-of-scope section?

  Not that i am aware of

• Do you have any further comments on this issue or other issues to be considered in Part 2?

  Please see marked-up doc attached for comments in each section: 2.4 Risk assessment and categorisation process: under Documentation, add in CMO as well as AHP Hearing Risk Assessment pg 53, noisy environment definition appears to be slightly out of context to what is written by Worksafe Aust? Consent for disclosure: is this compliant with Australian Privacy Principles? Retention and security of health information: same as above, does this comply with APP

• Have any of the proposed changes introduced any gaps in Part 3?

  3.5.1: would the CMO have a better idea of understanding rather than the AHP with rail experience? See marked-up comments