Personal View on Vision Standards and Data
If it isn’t recorded it didn’t happen!
Since my student nurse days, some 25 years ago and throughout my career I have been reminded that “if it isn’t documented it didn’t happen”. Any healthcare professional would recognise this, or a similar phrase as would, I suspect, professionals in other fields. This July, I discovered the impact not sticking to this principle can have for our industry – a possible removal from driving duties for dozens, if not more passenger and freight train drivers causing an operational nightmare from unexpected driver shortages.
What caused this? Simply that documents held by some companies after a driver medical did not explicitly show that eye test results met the new standard that would legally permit an existing driver to drive on domestic and cross-border routes after 29 October this year. This is when the transition phase of the Train Driver Licensing and Certificates Regulations 2010 was due to end. Compounding this, it was not possible for some of the medical providers to easily extract data from their systems that could have shown the legal standard had been met. There are no standardised medical request or outcome report templates across the industry that could have prevented this uncertainty.
By all accounts, the industry was largely on target to have these drivers tested and licensed by 28 October 2018, a remarkable achievement given the complexity of organising tests without disrupting normal work operation. The July discovery that many records did not give enough evidence of the standard used meant that fears arose that in some cases the new standard had not been applied during the medicals after all. By this time, rail companies faced repeating driver eye tests if they had not been re-tested and certified as passing the new standard. Thankfully, no new risks arose because of this problem and on 7 August 2018 ORR agreed with this and announced a temporary exemption from the application of the higher vision standard averting the need to re-test.
Why getting it right matters
What’s the big deal? Consider this, what if the doctor or nurse hadn’t screened a driver to the correct standard, and had allowed a pass at a level that should have resulted in a fail? Clear and accurate vision is critical to help drivers spot trespassers, workers, debris or damage on the line in time to act to avoid an incident that could profoundly change their own lives and others’. This can make the difference between a close-call and a tragedy as the ITV video of such an incident shows as does a British Transport Police photograph published in this month’s Railnews showing 8 children playing on a 60mph speed line. Significant near-misses have been reported where drivers spotted something wrong just in time to take action according to the Rail Accident Investigation Branch (RAIB).
Time to check your information management systems and processes
An incident investigation is likely to reveal where OH records or company data on medical fitness activities and outcomes do not give enough information on whether the right health checks have been conducted on the right employee according to the applicable regulatory requirements of applicable RSSB standards and your company standards, policies and procedures. Naturally, it is best to make sure the records you create or hold for employees are clear and detailed enough to provide that assurance and that relevant information is easily accessible should the need arise. If there is any doubt, maybe it’s time to review your documents, systems and processes now rather than letting an incident, inspection or claim control when and how you do this.
Coming together to find solutions for the industry and our professions
This single issue has revealed a potential systemic weakness in current quality assurance processes across our industry, thankfully one that has not resulted in any incidents. I issue a plea for my fellow occupational health professionals and local operations managers to work better together on measuring clinical and OH operations quality in our industry and to collaborate further in not only promoting effective care but also publishing key clinical and operational quality findings to help push further improvements across the industry.
RSSB’s work in supporting our members includes assisting with understanding and applying our standards and guidance and we are planning work to make these more accessible and user-friendly. If OH needs support in improving capabilities for data capture and reporting for clinical and other health measures for railway employees, or you want to get involved in helping us improve our medical standards and guidance I will be delighted to hear from you.