A Fresh Look at Medical Fitness and Other Health Standards - Full Version
RSSB receive regular queries about the application of the standards by occupational health (OH) professionals and have received examples where OH practice has been unexpectedly varied against the standards. In particular, this relates to the range of checks undertaken to achieve the aim of the standard or where the standard has been misinterpreted or not applied in the way intended.
How are the standards developed and maintained?
RSSB’s standards website provides explanatory notes and an interactive video to demonstrate the context in which RSSB standards are produced and maintained. Additionally, on this page there is a section on how to do something different to what a standard says and how to propose a change. This is important for RSSB members and their OH providers, as their feedback helps keep the standards up-to-date and apply changes which could improve clinical practice and better outcomes for rail employees. Requests for changes to standards must come from an RSSB member, either from the company managing an outsourced OH contract or directly by OH for an in-house service to an RSSB member.
All medical fitness standards are written and reviewed by a wide range of stakeholders which includes the industry OH group (OSHAG) and members (including ARIOPS representation). RSSB encourages individual OH clinicians and providers to register as stakeholders in order to contribute to ongoing improvements when standards are reviewed. RSSB is keen to build relationships with medical advisors to other UK transport sectors including aviation and maritime. These relationships will help the rail sector to benefit from the medical evidence underpinning standards and guidance in other sectors. Having a better understanding of the risks within a job role, and the health risk assessment methodologies that underpin the medical fitness criteria will help to identify when a train driver or safety critical worker does or does not meet medical fitness requirements.
Standards commonly used in railway OH practice
RSSB manage the following medical-related standards on behalf of the industry although others may be relevant when indicated by the duty holder: These can all be accessed from the Standards Catalogue.
- RIS-3451-TOM-Issue 1 - Train driver medical fitness standards - now largely obsolete due to Schedule 1 of the Train Driver Licence and Certificates Regulations 2010 being applicable to all categories of train drivers driving on the UK mainline railway
- RIS-3452-TOM-Issue 1 - Train movements medical fitness standards - for those driving/ moving trains in depots or other railway lines not on the UK mainline
- GOGN3655-Issue 2 - Guidance on medical fitness standards - this document supports RIS-3451-TOM and RIS-3452-TOM and includes guidance on medicines, diabetes, obstructive sleep apnoea and laser eye surgery
- RIS-8070-TOM-Issue 1 - Alcohol and drug testing with additional guidance in GEGN8570
- RIS-3751-TOM-Issue 3 - Train driver selection – this mainly describes psychometric testing requirements but also gives examples of conditions that may be detected by OH that could trigger recommendations for a new formal psychometric assessment by a RISQS-accredited assessment centre
How RSSB standards differ from clinical standards/guidelines
Differences between RSSB standards and clinical and professional standards include the overall format which doesn’t follow the ‘structure, process, outcome’ or similar format of many clinical or professional standards. RSSB standards do not describe or list the underpinning statutory and technical evidence in detail and at first glance the governance around them wouldn’t match the depth that you would expect from NICE (such as the low back pain guideline and quality standard), GMC, NMC or FOM / FOHN / SOM, especially around clinical audit and review.
A good explanation for these ‘missing’ elements is that the duty holder applying a standard will have a safety management system that will address the applicability and implementation of relevant standards using their own internal controls and assurance processes to monitor performance and address any difficulties . OH has an important role in designing internal quality processes such as policies and standard operating procedures that align and feed into those of the duty holder and their individual safety management system. Unfortunately, there isn’t a one-size-fits-all solution to this that could be covered in each RSSB standard document.
Making industry standards work for OH professionals
Essentially, a new approach is needed to help OH professionals get the most out of the standards without jeopardising the integrity of the existing structure of the standard documents. The industry approved rules protecting the standards governance processes allows for supplementary guidance to be produced and published in many forms. These can range from formal guidance note such as GOGN3655 Issue 2 or the fatigue management good practice guide (RS504) through to less formal information sheets, bulletins, presentations, videos, audit protocols or info graphics such as the sample for train driver medical standards shown here.
Without clear evidence of an industry need, RSSB cannot make an investment to develop the resources OH may need to best apply the standards. It is therefore crucial that RSSB receives information about each case where there is a need. Please inform RSSB about the help you and your teams need to make it easier to apply and undertake local audit of the standards in a consistent and efficient manner. And whether there is a case for new resources supported by examples from several OH providers or teams.