Our ref: HSR
Head Office Circular: NP/277/24
15th November 2024
To: The Secretary
ALL BRANCHES
REGIONAL COUNCILS
Dear Colleague
TRAIN DRIVER ALERTNESS MONITORING DEVICES
I write further to circular NP/181/ 24 dated 22nd July 2024, to update you on the current situation in relation to raising this unions concerns about the use of in cab train driver alertness monitoring devices.
At its meeting on 12th November 2024, your National Executive Committee noted and adopted the following report from its Health and Safety Sub-committee, from when they met to consider the issue of train driver attention and alertness monitoring devices, following a meeting they had with RSSB human factors lead on this matter.
“Given RMT concerns previously raised by the General Secretary with RSSB in relation to their RSSB T1193 project, “Understanding the Functional requirements for train driver attention and alertness monitoring devices”, we met recently with the RSSB Human Factors lead to discuss this project and our concerns as regards in cab train driver attention and alertness monitoring devices.
The RSSB project primarily bases the need for a trial of in cab driver monitoring equipment on the findings and recommendations of the RAIB report: ‘Overturning of a tram at Sandilands junction, Croydon’ https://assets.publishing.service.gov.uk/media/5de79643e5274a06dee23a10/R182017_201022_Sandilands_v2.2.pdf. An accident took place in November 2016 when a tram travelling in poor weather and at three times the speed permitted, overturned approaching Sandilands junction. Seven people died and many were injured, 19 seriously. The driver of the tram was charged under the Health and Safety at Work etc. Act 1974. The prosecution alleged that he was ‘microsleeping’. The driver was found not guilty.
In placing such focus on the tram derailment at Sandilands Junction and subsequent RAIB recommendations, one of which was for research of systems which are capable of detecting driver attention, RSSB ignores the principles of Health and Safety at Work Regulations 1999, Regulation 4. This requires employers to adopt preventions that adopt a hierarchy of control approach under which engineering controls which reduce exposure by preventing hazards (for example installing measures to automatically reduce speed as per the RAIB report recommendation) must be placed above administrative controls such as warning alarms (such as that which the driver monitoring device being trialled by RSSB is designed to provide).
RSSB explained that on completion of the trial the system would be shut down and would not be used without industry agreement.
Given the above, and arising from our meeting with RSSB, we instruct the General Secretary as follows:
To write to RSSB as regards their failure to consult with RMT on their T1193 project both in respect of RMT Signallers and other Network Rail operations staff impacted by the trial and in respect of RMT Drivers and operational train staff
To write to RSSB to establish which data will be kept separately for the purposes of the trial (to understand the causes of loss of alertness and consequences of fatigue in train drivers) and the distinctions between the trial and operational/organisational learning
To write to RSSB to inform them that we do not agree that the ‘Guardian’ Train Driver Alertness Monitoring Device, or similar monitoring systems constitute an appropriate control measure for loss of alertness or consequences of fatigue in operational rail staff including train drivers
To write to RSSB to inform them that their trial objectives are contradictory; RSSB claim the trial is about learning causes of loss of attention etc and encouraging fair culture approach in addressing this, but then state the objective is to reduce consequences of loss of attention by physically warning drivers
To write to RSSB to accept their offer (made at our recent meeting with them) of a seat on the project steering committee
To write NWR, as regards their failure to consult with RMT in relation how the trial will impact our signaller members and other Network Rail operations staff impacted by the trial
To write to ASLEF, to ascertain their view on the trial and if possible, to come to a joint union position on the use of this equipment
Branches and Regional Councils to be advised accordingly”.
I am acting in line with these instructions. Please bring this circular to the attention of all relevant members.
Yours sincerely
Michael Lynch
General Secretary