RSSB’s medical standards are being revised

The standards are RIS-3451-TOM Train Drivers – Suitability and Medical Fitness Requirements; RIS-3452-TOM Train Movement – Medical Fitness Requirements; and GOGN3655 Guidance on Medical Fitness for Railway Safety Critical Workers.

In response to a query from the ORR, some of the work currently in progress to aid the revision of the standards is detailed below.

Vision

The Train Driving Licences and Certificates Regulations 2010 (TDLCR) Schedule 1, Reg 2(b) allows doctors to issue a derogation as follows:

‘maximum corrective lenses: hypermetropia + 5/myopia -8 (derogations may be authorised in exceptional cases and after having obtained the opinion of an eye specialist; the recognised doctor then takes the decision)’.

To assist doctors when making derogations, the review of the standards will aim to provide guidance on:

• how and when a doctor may seek an opinion from a specialist ophthalmologist
• the rationale for the specified maximum corrective lenses in Schedule 1
• how to assess train drivers to decide if a derogation may be suitable
• how to draft a derogation if the doctor is confident that a driver remains fit to drive with their corrected vision
• the importance of a consistent approach across recognised doctors in the assessment of vision
• understanding of what is meant by the ‘exceptional cases’ reference in the TDLCR Schedule 1, 2(b).

Colour vision

TDLCR Schedule 1 2 (e) requires train drivers to have normal colour vision tested using a recognised test. Schedule 1 suggests the use of the Ishihara test. However, it is not mandated.

Schedule 1 also mentions the use of ‘another recognised test if required’. While this can be interpreted in various ways, in other industries, common practice is to administer a secondary test if an individual does not pass the initial screening test. This approach can be adopted in the rail industry.

If the occupational health or ophthalmic specialist determines any of the available colour vision screening tests are suitable, it can be used as a primary or secondary test.

New research is being scoped to define the minimum thresholds of colour vision for safety-critical railway staff. The exact timescales of the research are not yet confirmed, but it is estimated the results will be published during the summer of 2024.

It is not RSSB's intention to mandate what the secondary test should be; however, if appropriate the standard may contain guidance that highlights existing tests which may be suitable. By defining the minimum thresholds for colour vision and providing appropriate guidance for when secondary testing should be carried out, RSSB will be able to support the industry in approaching the issue in a fair and consistent manner.

Implantable cardioverter defibrillator

New research is being scoped which looks to provide an assessment of the likely effects on the performance of conditions of:

• the sudden loss of consciousness
• a reduction in attention or concentration
• sudden incapacity
• a loss of balance or coordination
• a significant limitation of mobility for an agreed range of safety-critical workers.

This will be used to analyse the risk of these incapacitation events to the operating railway.

This new research will replace T663 Managing the risk associated with sudden incapacity in safety-critical occupations (2009). The research will benefit industry by providing more information to make a robust risk-informed decision about managing safety-critical workers, which could include those people with implantable cardioverter defibrillators. For example, recognised doctors working to Schedule 1 of the Train Driving Licencing and Certification Regulations (TDLCR) 2010 could benefit from the research through subsequent railway-specific guidance about drivers with these devices. Whilst non-railway standards for people with ICDs currently exist for some other industries (for example from the Driver and Vehicle Licensing Authority in relation to lorry, bus or coach drivers), these may not necessarily be appropriate for a railway context and sit outside of the TDLCR regulatory regime and industry standards. Currently, recognised doctors undertaking medical examinations of licenced train drivers with ICDs should seek specialist cardiac advice, as appropriate.

The exact timescales of the research are not yet confirmed, but it is estimated the results will be published during the winter of 2024.

When both research projects have been completed, learning from the research findings that may assist industry will be published as soon as it is available, in a suitable format. The guidance in the medical standards may also need to be updated. If that is the case, RSSB will consider the best way forward and will consult with stakeholders including Traffic Operations and Management Standards Committee. Depending on the outcome, this may be within the timescale for the current revision.

Medical frequencies

Background

On 14 March 2024, London North Eastern Railway raised a report of Urgent Operating Advice in Rail Notices (reference NIR 3350/228). The report highlights a discrepancy in the requirements for medical frequencies for some grades of staff between the Operation and Traffic Management National Technical Specification Notice (OPE NTSN) and Rail Industry Standards (RIS-3451-TOM and RIS-3452-TOM).

The report also suggests that this discrepancy is the result of an unintentional change made when the Operation and Traffic Management Technical Specification for Interoperability (OPE TSI) was redrafted into the OPE NTSN, in anticipation of the UK leaving the European Union.

Immediate advice

The discrepancy in frequency between RIS-3451-TOM, RIS-3452-TOM and the OPE NTSN is a known one, and has been acknowledged for some time.

Clause 2.63.3 of GOGN3615 states that ‘Further work is being carried out in Europe regarding medicals. Pending the outcome of this work, railway undertakings and infrastructure managers on the GB mainline railway will continue to apply the requirements set out in RIS-3451-TOM and RIS-3452-TOM.’

This guidance remains valid, and RSSB intends to include this in updated medical standards, which are due to be published in early 2025.

History of the differing medical requirements

Report NIR 3350/228 suggests that the differing medical requirements arose due to an error during the drafting of the OPE NTSN, published on 1 January 2021. This suggestion appears to be incorrectly based on analysis of the 2012 OPE TSI. The OPE NTSN is based on the OPE TSI, which was in force when the OPE NTSN was published. This was the 2015 OPE TSI. The relevant scope clause in 2.2.1 of the OPE NTSN is identical to clause 2.2.1 in the 2015 OPE TSI. As such, the same requirement has applied in GB since 2015.

Long-term solution

We will note this discrepancy on the OPE NTSN issues log. RSSB will discuss the issue with relevant industry groups to gather industry views on how the discrepancy might be resolved. Possibilities include:

• an industry recommendation that the OPE NTSN is updated to align with the RISs
• updating the RISs to align with the OPE NTSN
• taking a different approach.