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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.
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
Categorisation no, just the criteria as in the marked-up copy that is attached.
By providing rail studies perhaps that gives direct correlation to rail as opposed to using road crash data
Not that I am aware of
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
3.5.1: would the CMO have a better idea of understanding rather than the AHP with rail experience? See marked-up comments
Not that i am aware of
Please see attachment
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
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
Marked up copy attached
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
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?
Aust standard for Aust rail. OR UK legislation also. Link in marked up doc.
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?
See marked up copy
Exception is the STOP-Bang questionnaire, which can skew results for non-male workers
36 months - additional staffing etc
Please see marked up copy attached
Further review needed for criteria and reference material.