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#1 Posted : 27 September 2006 15:54:00(UTC)
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Posted By Carl I work for a geotechnical consultancy who qualified via proof core audit for the Link-up scheme in 2005. As we are relatively new to the rail industry I require some advice in making ‘practical’ sense of the requirements and limits imposed by Management and Monitoring of Hours of Work Policies adopted throughout the industry. Our Engineers work in green zone only, mostly at weekends under a line possession. My question is as follows: Does the 12 hour shift have to be uninterrupted i.e. worker drives to site of work and returns home again all within a 12 period? Or could for example (given that travel time is included within the 12 hour working limit), a worker drive for 4 hours, sign of for 2 hours (effectively not working - to organise a hotel, take lunch, etc.) and then sign on at the site (place of work), again including any travel time to and from the site, and work for 8 hours thus not exceeding the 12 hour limit? Thanks in advance.
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#2 Posted : 27 September 2006 21:03:00(UTC)
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Posted By Raymond Rapp Carl Even if you could work the abnormal hours you have suggested there is the problem of 12 hours rest between shifts. I am not convinced you can overcome that problem. Nice try though. Ray
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#3 Posted : 28 September 2006 08:13:00(UTC)
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Posted By Bob Youel Beware re the comment - 'effectively not working' - as even sleeping and looking for 'digs' etc is deemed a work activity in some circumstances
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#4 Posted : 28 September 2006 09:51:00(UTC)
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Posted By John Caboche Carl, under the ROGS regs you are now required to manage fatigue rather than working time. "replace the Safety Critical Work Regulations 1994 (SCWR): and implement new requirements on the management of fatigue of safety critical workers (arising from recommendations from Lord Cullen’s inquiry into the collision at Ladbroke Grove)." Source: http://www.rail-reg.gov....rver/show/ConWebDoc.7964 You can download the regulations from: http://www.rail-reg.gov....rver/show/ConWebDoc.7964 And you need to look at section 25. It may be permissable to include travelling time outside of shifts, but only an hour for example - this is our policy, we also have to monitor travelling distance of the work gangs, shift times - actual start and finish times rather than duration. Management of fatigue is a lot more tricky than just managing working hours, you have to take into account many more things, and also to an extent factors that may affect your employees outside of work. In a lot of ways it is best to err on the side of caution - we place dedicated drivers in our work gangs who sleep for the shift and then drive the guys home fior example after a long night shift. In answer to your original question the instances you cite of driving and sourcing accomodation would almost certainly be counted as "working time" for the purposes of the regs. Feel free to e mail me if you require further info. John
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#5 Posted : 28 September 2006 09:52:00(UTC)
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Posted By John Caboche Sorry Carl, that second link should be: http://www.opsi.gov.uk/s...006/uksi_20060599_en.pdf John
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#6 Posted : 30 September 2006 19:22:00(UTC)
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Posted By Mick Day Carl, The whole issue of the working hours within the rail industry is somewhat "GREY". The key issue to address first is are you and your staff classed as Safety Critical. There is guidance on the the classification of what roles are deemed Safety Critical. Railway Group Standard - GO / RT 3260 Being link up accredited you should have reference to these standards. If not type in RSSB and it will take you to the website. The best advice I could give you is treat all staff as Safety Critical for the purpose of working hours. If something does happen upon the Railway Infrastructure that affects the safe passage of trains of could potentially affect the safe passage of trains you would need to demonstrate a satisfactory level of staff management. You will find throughout the industry that this issue is a major bone of contention that has never been satisfactorily answered. Dont also lose sight of the basic issue of the HASAWA and Management Regs. Railway Group Standard - GH / RT 4004 Changes in Working Hours - Safety Critical Work - Dated 1996 refers . Railway Group Standard - GO / RT 3260 - Competence Management for Safety Critical Work - Dated 1998 sets out clarification as to what functions are deemed as Safety Critical. Good Luck in your quest. Regards Mick
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#7 Posted : 01 October 2006 12:14:00(UTC)
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Posted By Bob Shillabeer Hi Guys, Just logged on and noticed this thing about management of working time on the Railways. Just cut out this nonsence about how to manage it. Go to the RSSB website and look it up there. RSSB sets the standards for the industry through standrds committees made up of industry players with knowledge of the issue concerned. If you need definitive guidance you can contact the Head of Delivery Unit Train Operations and Management who controlls the specific standards governing working hours. he can give you the true facts.
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#8 Posted : 01 October 2006 16:21:00(UTC)
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Posted By Ian G Hutchings Bob I think you are being a bit harsh as people are trying to offer advice and have already mentioned the RSSB. The people in question are not train operators and may need some more specific guidance as to where they fit in with the safety critical work requirements. The RSSB is the right direction to look but people must also remember that complying with a railway industry standard does not absolve you from further risk assessment, other legal requirements and duty of care as a company. I think it is often better to think through your own scenario and not just default to generic compliance with railway group standards on paper (e.g. LinkUp) without ensuring that proper controls are applied in the reality of the work concerned. Regards Ian
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#9 Posted : 02 October 2006 09:45:00(UTC)
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Posted By Bob Shillabeer Hi Thanks for the rebuke but it really annoys me when people ask for advise and when given the real specialist organisation which can give real information and guidance there seems to be a great reluctance on some peoples part to take that advise instead continue to prattle on about a subject that is quite easyto manage when the right info is available. Just ask the experts.
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#10 Posted : 02 October 2006 09:51:00(UTC)
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Posted By Bob Shillabeer Sorry got me on the wrong foot; back trip into work today. I attended a briefing some months ago on the ROGS Regulations by the HMRI (Fat load of use that was) The ROGS are the new version inter alia of the Railways (Safety Critical Work) Regulations and very little has changed. The need to manage working hours comes from Sir Anthony Hidden's recomendation 18 from the Clapham rail accident and has been considered by RSSB for many years now and they are very expert in them. If you need any help in interpreting them contact RSSB the Head of Train Operation and Management delivery unit is a very approachable person and WILL give help
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#11 Posted : 02 October 2006 11:44:00(UTC)
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Posted By Carl Thanks for the Information everyone. Can I just comment on Bob’s response - if this matter is so easy to manage, then why are there so many different interpretations of the 12 hour rule? I have received personal emails through this forum stating as such, because as they view it, some companies are interpreting the 12 hour rule to suit there own needs. I was looking for practical measures and working practices used during T3 possessions to ensure that workers; a) do not exceed limits and more importantly b) avoid fatigue causing or contributing to errors While these measures may be well practiced by people already in the rail industry, as newcomers, we are experiencing difficulties mainly relating to travel arrangements – sites are often 2 - 4 hours away. As I see it this may only be overcome by ensuring there is provision for hotel/B&B stays. We have invested a great deal of time and effort to qualify for Link-up which comes at a considerable cost to small organisations (25 employees – sponsoring 10 people only) such as ours, so we need to get it right. PS I will be contacting the RSSB as advised. Regards Carl
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#12 Posted : 02 October 2006 12:20:00(UTC)
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Posted By Bob Shillabeer The Railway (Safety Critical Work) Regulations stated that people should not undertake safety critical work whilst fatigued; this is repeated in the ROGs Regulations. It is not the time spent doing safety critical work that counts its the state of fatigue the individual displays. E.G. if someone drives 200 miles to bet to a worksite then does a period of safety critical work its the fitness of the individual that has a direct bearing on that person ability to undertake the task correctly and without risk. So in short it is wrong to consider the travelling time outside the work time before undertaking safety critical work. All I am saying is get the advise of the experts in this field; they have lots of experience and knowledge about monotoring safey related/critical working not just in train operators but accross the whole range of activities undertaken in the rail industry. Horses and water seem to come to mind.
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