When ONRSR began working with the Australian Society of Section Car Operators (ASSCO) the operator freely admitted that its safety management system – and indeed its overarching safety culture – left a lot to be desired.
Julian Hodson, ASSCO’s Safety and Accreditation Coordinator, noted that the need to maintain and monitor the effectiveness of its SMS had slipped through the cracks over the years.
“ASSCO’s SMS was a system that barely changed since its creation in 1999 and had failed to keep up with regulatory change over the years,” he said.
“Compounding this was a safety culture issue within ASSCO where the SMS was something that we had sit in the background, it wasn’t really used by our rail safety workers properly. Paperwork was often incorrectly completed and not appropriately archived by people that just wanted to go out and play trains.”
“Unfortunately, today’s rail networks are different to those that operated even 10 years ago with a big focus now on safety and compliance – this is especially important for a heritage rail operator such as ASSCO that operates on commercial freight and passenger networks – not isolated branch lines”.
A full SMS audit undertaken by ONRSR at the beginning of 2019 confirmed the existence of significant SMS and safety issues at ASSCO. As ONRSR’s Director, Operations in Brisbane Mark Fernan recalls, such was the extent of these issues the initial recommendation made to the not-for-profit heritage rail operator was anything but palatable.
“It was a difficult conversation that we had to have with them about the state of their SMS so much so that we actually strongly encouraged them to cease operations completely so as to focus on its complete redevelopment,” he said.
“We gave them an undertaking that we would support them through that process and help them as best we could to get the right outcome.”
The response was exactly what ONRSR was looking for with the operator making the decision to embrace the recommendation as an opportunity for a fresh start.
ASSCO operates vintage section cars on commercial rail networks such as Queensland Rail and Aurizon, working as a third-party above rail operator only – thereby avoiding ownership and maintenance of below-rail assets and reducing operating costs. It seeks to keep a unique but often forgotten part of Australia’s rail heritage alive while providing economic support to regional small businesses and communities.
While its SMS issues were there for all to see, the first step in correcting the situation did not involve reviewing documentation but rather focused on developing a safety culture amongst the membership. Getting the safety culture right first would ultimately improve the chances of effectively implementing an enhanced safety management system.
Julian Hodson knew the task would not be an easy one, particularly for a heritage operator like ASSCO.
“Getting safety culture right today can be difficult because the general demographic of heritage rail organisations is older and many of the more experienced members have been around for 30 or 40 years,” he said.
“They come from a time where accidents and incidents were simply accepted as part of doing business.”
“So, For ASSCO to establish the culture we needed we had to ramp-up enforcing our safety policy and systems to ensure that we weren’t just paying lip-service to safety and possibly ending up with a serious injury or incident out on the network.”
“We’ve been really lucky that the majority of the membership has been very supportive of the changes made. We have also lost a couple of members that didn’t want to change their old ways.”
The second step to getting ASSCO back on track was to completely redevelop the 29 element SMS from scratch.
The decision to do a complete re-write didn’t come lightly but was something that had to be done after further consultation with ONRSR. It wasn’t just the SMS that had to be looked at but a holistic view of the organisation including updating the constitution and other processes.
“For example, to support SMS processes in rail safety worker competence we realised very quickly, like most heritage organisations, getting people together for training and assessment can be difficult,” Julian Hodson remembers.
“So we had a big focus on online training. The problem with that was we didn’t have the training material and we didn’t have the resources to do both an SMS redevelopment and training packages at the same time.”
“We turned to a third-party RTO rail training specialist to assist us with training requirements. Our members are now able to undertake most AQF training online at a time and pace that suits them and at a price-point a heritage organisation like ASSCO and its members can afford.”
“There is a bit of a myth out there that heritage groups can’t afford to engage an RTO to assist with competency requirements which is simply not true. The first step is getting out there and talking to them to outline your requirements and financial position.”
ASSCO’s members now have the appropriate competency levels and some of its younger members that may be looking to enter the rail industry in a career capacity will get AQF units of competency to assist them along the way.
In addition other Rail Safety National Law (RSNL) elements, like drug and alcohol programs, were set up in-house for as little as $2500 which included competency training and both drug and alcohol testing equipment.
Part of the redevelopment process was to also to draw on the experience, talents and skill sets of existing members.
“We have a member who is a safety manager for a mining company in Townsville. This guy lives, eats and breathes safety so he was an important part in assisting in the development of the risk management framework and safety processes,” Julian Hodson notes.
“Sometimes people lurk in the background and you don’t know what skillset you actually have until you put out a call for assistance”.
From ONRSR’s perspective the overhaul of ASSCO’s safety culture and SMS is a case study in the co-regulatory model used in the Australian rail industry and one that other rail transport operators should consider carefully.
“Where ASSCO is concerned it’s clear there has been a huge effort and some really critical thinking around developing a system that will better support the operation,” Mark Fernan said.
“We certainly didn’t take this matter lightly in making the recommendation we did and their decision to cease operations and focus exclusively on the redevelopment of the safety culture and SMS was a very mature and responsible one.”
“Wherever we can we look to take an educational approach, and all the members at ASSCO will see the benefit of the changes they’ve made. Like any change it will become business as usual in time and they’ll wonder what all the fuss was about.”
For its part ASSCO believe the assistance received from ONRSR during this time was integral in getting it back on the right track.
“The rail safety officers in the Brisbane office have been outstanding in their support and guidance, and it goes to show even the smallest heritage rail operator like ASSCO can fully comply with RSNL, given the right attitudes from all involved.”
“ONRSR’s education approach is a credit to the regulator in that is gives rail organisations confidence that their approach to rail safety is genuine and not simply a ‘big stick’ to RSNL compliance.”
Article originally published by the Office of the national Rail Safety Regulator – February 2020