Managing the risks to bus safety
Following this step-by-step process will enable you to build a risk register that will help you to manage safety risks by documenting the risks involved and the steps to take to reduce those risks.
Each step includes monitoring and review processes, so that the risk register is continuously improved and adapted to match your circumstances.
Risk management process
- Establish the context
- Identify risk sources
- Describe risks arising from the sources
- Identify risk causes
- Identify risk consequences
- Identify risk likelihood
- Evaluate risks
- Understand and decide on risk treatments
- Assign risk treatment responsibility (if appropriate)
- Show how safety risks have been eliminated or reduced so far as is reasonably practicable (SFAIRP)
An important part of each step is communication and consultation. Section 13 of the Bus Safety Act 2009 (Vic) (BSA) highlights the importance of including all people involved in the provision of a bus service in planning and carrying out risk management processes. Stakeholder consultation with affected parties will help you to obtain a proper understanding of the risks.
Establish the context
By establishing the context, an organisation documents the risk environment in which it operates. To establish the risk context:
- describe what the operation does
- define any relationships with other stakeholders
- describe any standards and guidelines adopted by the organisation
- document any inclusion of risks outside risk owner’s legislative obligations, for example, occupational health and safety legislation, financial risks
- describe how changes affecting the bus industry are considered, including seasonal physical changes
- document the process to be followed when managing risk.
An easy way to record how the context has been established is to use a table like the one below.
Risk management context | |
|---|---|
Business description | This organisation uses (number) buses to provide (description) services to a number of private schools in regional Victoria. |
Stakeholders |
|
Standards and guidelines |
|
Inclusions outside the BSA | Occupational health and safety risks which have been incorporated into the risk register. |
Consideration of change |
|
Risk management process | I have adopted and amended the TSV safety risk management guidance material. See later pages for the parameters I have adopted for risk consequence and likelihood. |
Identify risk sources
Step 2 requires you to identify and document elements which have the potential to give rise to a risk, for example, the environment in which the activity is being conducted, and record them on the risk register.
Ideally, a risk should be identified in the following terms: (Something happens) leading to (outcomes expressed in terms of impact on objectives)
For example: A spill of oil in the creek damages our reputation with the local community.
It is important to consider all things that could occur, not just the likely ones.
The obligation to ensure safety SFAIRP is not avoided because a risk source has not been identified. If it is considered reasonable for anyone to be aware of a risk source, then a person may not have demonstrated that they have ensured safety SFAIRP.
This step can be achieved by gathering as many people with appropriate knowledge as possible and discussing what could give rise to safety risks.
The following is a sample list of risk sources:
The operating environment
This may include:
- road conditions
- weather conditions
- other road users
- speed limits
- temporary or permanent changes to the way that activities are conducted (for example different routes, replacement buses, new bus stop placement).
The mechanical environment
This may include:
- maintenance processes
- bus manufacture
- bus equipment.
Driver fitness
This may include:
- driver medical condition and use of medications
- alcohol and drug considerations
- driver qualification
- fatigue.
Driver behaviour
This may include:
- distraction avoidance
- appropriate assertion
- obedience to applicable rules (for example road rules, company policies).
Emergency management
This may include abnormal operations/incidents.
The sample risk register, at the end of Step 2, looks like this.
Item | Risk source |
|---|---|
1 | Operating environment |
2 | Operating environment |
3 | Mechanical environment |
4 | Mechanical environment |
5 | Driver fitness |
6 | Driver fitness |
7 | Driver behaviour |
8 | Driver behaviour |
9 | Emergency management |
10 | Emergency management |
Describe risks arising from the sources (events)
To describe what event may eventuate from a risk source, think about what could go wrong at each of the risk sources identified and record them on the risk register.
The following is a list of events arising from the sample risk sources.
Note: a risk source may lead to more than one event.
The sample risk register now has a third column, headed Event, and looks like this.
Item | Risk source | Event |
|---|---|---|
1 | Operating environment | A child is struck and injured by a vehicle a child is struck by a vehicle when getting on or off a bus at a bus stop |
2 | Operating environment | A child is struck and injured by a bus when getting on or off a bus at a bus stop |
3 | Mechanical environment | A bus catches fire, resulting in passengers being injured |
4 | Mechanical environment | A bus runs out of fuel at a safety critical location and is struck by another vehicles which injures passengers |
5 | Driver fitness | A driver is unfit to drive by being fatigued and loses control of a bus |
6 | Driver fitness | A driver is unfit due to alcohol or drug consumption and loses control of a bus |
7 | Driver behaviour | A driver fails to pick up a child at a bus stop and the child is struck by another vehicle |
8 | Driver behaviour | A passenger’s limb becomes trapped in bus doors, resulting in an injury to the passenger |
9 | Emergency management | A driver is unable to contact the responsible person after an emergency and the operator does not report the incident to TSV or liaise with emergency services |
10 | Emergency management | A bus incident is not reported to TSV |
Identify risk causes
As its name implies, a risk cause is something that causes a risk event to be realised.
There are many potential risk causes, including equipment faults, people making errors and environmental conditions.
There are also many ways to identify potential risk causes, including:
- reviewing internal/external accidents and incidents
- reviewing TSV documentation, including bus newsletters and safety alerts
- analysing failures and investigations including failure of technical components as well as human errors/violations. For example:
- a) the inspection/maintenance schedule may also identify a component (treatment) which regularly fails
- b) a certain situation can make people prone to making mistakes or encourages them not to comply with rules and procedures
- analysing near miss situations
- analysing audits and inspection results.
Risk owners should identify and record on the risk register what will cause the risk event to happen.
The following is a sample list of risk causes that follow on from the example events and risk sources given above. Risk causes should be recorded on a risk register.
Item | Risk source | Event | Risk cause |
|---|---|---|---|
1 | Operating environment | A child is struck and injured by a vehicle when getting on or off a bus at a bus stop | Road users do not see a child getting on or off the bus |
2 | Operating environment | A child is struck and injured by a bus when getting on or off a bus at a bus stop | Bus driver does not see a child approaching or getting on or off a bus |
3 | Mechanical environment | A bus catches fire, resulting in passengers being injured | A component fails |
4 | Mechanical environment | A bus runs out of fuel at a safety critical location and is struck by another vehicles which injures passengers | A bus has insufficient fuel to complete the service |
5 | Driver fitness | A driver is unfit to drive by being fatigued and loses control of a bus | A driver works for long periods during the day without a break |
6 | Driver fitness | A driver is unfit due to alcohol or drug consumption and loses control of a bus | A driver does not leave sufficient time after drinking alcohol to allow his blood alcohol level to return to zero prior to a duty period |
7 | Driver behaviour | A driver fails to pick up a child at a bus stop and the child is struck by another vehicle | The driver believes that the maximum number of passengers is reached and decides he/she cannot carry any more |
8 | Driver behaviour | A passenger’s limb becomes trapped in bus doors, resulting in an injury to the passenger | The driver does not see that a passenger is not clear of doors prior to their operation |
9 | Emergency management | A driver is unable to contact the responsible person after an emergency and the operator does not report the incident to TSV or liaise with emergency services | The bus has an emergency and the driver’s communications mechanisms do not work |
10 | Emergency management | A bus incident is not reported to TSV | A bus incident occurs |
Identify risk consequences
Consequences with respect to safety relate to the degree of harm to people (passengers, workers, members of the public) and may involveinjuries or fatalities.
Identify and document on the risk register all potential outcomes, should they occur, of an event which has been seen as a risk.
Identify a consequence rating by using, for example, the sample consequence matrix shown.
Note: An event can lead to a range of consequences.
Consequence ratings matrix
Rating | Description |
|---|---|
1 - Insignificant | Minor injuries or ailments not requiring medical attention |
2 - Minor | Minor injuries requiring medical treatment but not requiring hospitalisation or a major injury requiring hospitalisation |
3 - Moderate | Multiple major injuries requiring hospitalisation |
4 - Major | A fatality |
5 - Extreme | Multiple fatalities |
Be careful not to underestimate the consequence as this may lead to ranking the risk lower than it actually is. If you are uncertain into which category a risk source falls, you should choose the most serious consequence.
It is also important that risk owners consider all potential outcomes, for example. a low speed collision may result in minor injuries, but there is still a potential for multiple fatalities and injuries in certain circumstances.
If risk owners rank a consequence with treatments in place, make sure that these treatments are actually in place and are working as expected. The reliability of the control should be tested/proven, to ensure the ranking is not underestimated.
The following is a sample list of risk consequence (C) scores drawn from the sample events. Risk consequence scores should be recorded on a risk register.
Item | Risk source | Event | Risk causes | C |
|---|---|---|---|---|
1 | Operating environment | A child is struck and injured by a vehicle when getting on or off a bus at a bus stop | Road users do not see a child getting on or off the bus | 4 |
2 | Operating environment | A child is struck and injured by a bus when getting on or off a bus at a bus stop | Bus driver does not see a child approaching or getting on or off a bus | 4 |
3 | Mechanical environment | A bus catches fire, resulting in passengers being injured | A component fails | 3 |
4 | Mechanical environment | A bus runs out of fuel at a safety critical location and is struck by another vehicles which injures passengers | A bus has insufficient fuel to complete the service | 3 |
5 | Driver fitness | A driver is unfit to drive by being fatigued and loses control of a bus | A driver works for long periods during the day without a break | 3 |
6 | Driver fitness | A driver is unfit due to alcohol or drug consumption and loses control of a bus | A driver does not leave sufficient time after drinking alcohol to allow his blood alcohol level to return to zero prior to a duty period | 3 |
7 | Driver behaviour | A driver fails to pick up a child at a bus stop and the child is struck by another vehicle | The driver believes that the maximum number of passengers is reached and decides he/she cannot carry any more | 4 |
8 | Driver behaviour | A passenger’s limb becomes trapped in bus doors, resulting in an injury to the passenger | The driver does not see that a passenger is not clear of doors prior to their operation | 4 |
9 | Emergency management | A driver is unable to contact the responsible person after an emergency and the operator does not report the incident to TSV or liaise with emergency services | The bus has an emergency and the driver’s communications mechanisms do not work | 2 |
10 | Emergency management | A bus incident is not reported to TSV | A bus incident occurs | 1 |
Identify risk likelihood
The likelihood of a risk is the chance or frequency that the event may occur.
Identify the chance that something may happen for each identified risk by using, for example, the sample likelihood ratings matrix below.
Likelihood ratings matrix
Rating | Description |
|---|---|
1 - Rare | Theoretically possible but not expected to occur |
2 - Unlikely | Have heard of something like this happening elsewhere |
3 - Likely | The event has occurred several times or more in this company |
4 - Definitely | The event will occur |
Do not underestimate the likelihood, as it may lead to ranking the risk lower than it actually is. If risk owners are not sure which category a hazard falls in take a more conservative approach.
When determining likelihood:
- use knowledgeable people
- get advice and use technical experts if needed
- use categories that make sense to you
- be consistent with ratings.
The following is a sample list of risk consequence scores drawn from the sample events. Risk consequence scores should be recorded on a risk register. Likelihood ratings (L) should be recorded on a risk register.
Item | Risk source | Event | Risk causes | C | L |
|---|---|---|---|---|---|
1 | Operating environment | A child is struck and injured by a vehicle when getting on or off a bus at a bus stop | Road users do not see a child getting on or off the bus | 4 | 2 |
2 | Operating environment | A child is struck and injured by a bus when getting on or off a bus at a bus stop | Bus driver does not see a child approaching or getting on or off a bus | 4 | 1 |
3 | Mechanical environment | A bus catches fire, resulting in passengers being injured | A component fails | 3 | 2 |
4 | Mechanical environment | A bus runs out of fuel at a safety critical location and is struck by another vehicles which injures passengers | A bus has insufficient fuel to complete the service | 3 | 1 |
5 | Driver fitness | A driver is unfit to drive by being fatigued and loses control of a bus | A driver works for long periods during the day without a break | 3 | 2 |
6 | Driver fitness | A driver is unfit due to alcohol or drug consumption and loses control of a bus | A driver does not leave sufficient time after drinking alcohol to allow his blood alcohol level to return to zero prior to a duty period | 3 | 2 |
7 | Driver behaviour | A driver fails to pick up a child at a bus stop and the child is struck by another vehicle | The driver believes that the maximum number of passengers is reached and decides he/she cannot carry any more | 4 | 2 |
8 | Driver behaviour | A passenger’s limb becomes trapped in bus doors, resulting in an injury to the passenger | The driver does not see that a passenger is not clear of doors prior to their operation | 4 | 1 |
9 | Emergency management | A driver is unable to contact the responsible person after an emergency and the operator does not report the incident to TSV or liaise with emergency services | The bus has an emergency and the driver’s communications mechanisms do not work | 2 | 2 |
10 | Emergency management | A bus incident is not reported to TSV | A bus incident occurs | 1 | 2 |
Evaluate risks
The purpose of risk evaluation is to assist in making decisions (based on outcomes of a risk analysis) about which risks need treatment and the priority for treatment implementation.
A risk evaluation is the translation of an assessment of likelihood and the consequence. This step allows risk owners to understand the risk score of an event and prioritise risk management activities.
Risk owners should determine a score for each risk by using a sample risk rating matrix. This is done by establishing where the likelihood row and the consequence column meet, for example, a risk with a consequence of 2 and a likelihood of 3 results in a risk score 6.
In our example, we have elected to allocate the following number ranges to group risks into priority categories.
- A score of 1 – 3 = low risk.
- A score of 4 – 6 = medium risk.
- A score of 8 – 12 = high risk.
- A score of 15 – 20 = extreme risk.
Risk owners should use a matrix that best suits their purposes and understanding. Risk owners can adapt the risk matrix to suit their own needs.
Each risk must have an appropriate amount of effort expended on it to eliminate or reduce it so far as is reasonably practicable.
For example, a risk owner may decide on the following risk criteria position:
- Extreme: immediately stop the activity that gives risk to the risk
- High: the attention of a senior person in the business is needed and action plans and responsibility for completion of action must be specified
- Medium: can be managed by specific monitoring or response procedures, with responsibility specified
- Low: can be managed by routine procedures. Low risks are unlikely to need specific additional application of resources.
A basic risk evaluation matrix would have consequence as the top row with five columns underneath with their numeric value - insignificant (1), minor (2), moderate (3), major (4) and extreme (5).
Likelihood consists of four stages listed in the left hand columns – rare, unlikely, likely and definitely.
The consequence value is multiplied by the likelihood value and the resulting risk criterion is entered in the square where the row and column intersect to give a risk rating (R).
Tip: Colour coding the low priorities green, the medium yellow the high orange and the extreme red gives a quick visual representation of where the risk sits.
Risk evaluation matrix
| Likelihood | Consequence | ||||
|---|---|---|---|---|---|
Insignificant = 1 | Minor = 2 | Moderate = 3 | Major = 4 | Extreme = 5 | |
Rare = 1 | L | L | L | M | M |
Unlikely = 2 | L | M | M | H | H |
Likely = 3 | L | M | H | H | E |
Definitely = 4 | M | H | H | E | E |
Risk ratings should be recorded on a risk register.
Item | Risk source | Event | Risk causes | C | L | R |
|---|---|---|---|---|---|---|
1 | Operating environment | A child is struck and injured by a vehicle when getting on or off a bus at a bus stop | Road users do not see a child getting on or off the bus | 4 | 2 | H |
2 | Operating environment | A child is struck and injured by a bus when getting on or off a bus at a bus stop | Bus driver does not see a child approaching or getting on or off a bus | 4 | 1 | M |
3 | Mechanical environment | A bus catches fire, resulting in passengers being injured | A component fails | 3 | 2 | M |
4 | Mechanical environment | A bus runs out of fuel at a safety critical location and is struck by another vehicles which injures passengers | A bus has insufficient fuel to complete the service | 3 | 1 | L |
5 | Driver fitness | A driver is unfit to drive by being fatigued and loses control of a bus | A driver works for long periods during the day without a break | 3 | 2 | M |
6 | Driver fitness | A driver is unfit due to alcohol or drug consumption and loses control of a bus | A driver does not leave sufficient time after drinking alcohol to allow his blood alcohol level to return to zero prior to a duty period | 3 | 2 | M |
7 | Driver behaviour | A driver fails to pick up a child at a bus stop and the child is struck by another vehicle | The driver believes that the maximum number of passengers is reached and decides he/she cannot carry any more | 4 | 2 | H |
8 | Driver behaviour | A passenger’s limb becomes trapped in bus doors, resulting in an injury to the passenger | The driver does not see that a passenger is not clear of doors prior to their operation | 4 | 1 | M |
9 | Emergency management | A driver is unable to contact the responsible person after an emergency and the operator does not report the incident to TSV or liaise with emergency services | The bus has an emergency and the driver’s communications mechanisms do not work | 2 | 2 | M |
10 | Emergency management | A bus incident is not reported to TSV | A bus incident occurs | 1 | 2 | L |
Understand and decide on risk treatment
Risk treatment strategies
There are several treatment strategies available to manage risks once they are identified and evaluated including:
- accept - in circumstances where a risk is insignificant and there are no reasonably practicable risk treatments available
- mitigate: there are two ways to mitigate risk:
a) preventative action reduces the likelihood of an event occurring
b) mitigative action reduces the consequence of an event that actually takes place and can also reduce exposure to an event. - transfer - move responsibility for management of the risk to another area or organisation either internally or externally, for example, insurance. Risks may be partially or, less often, completely transferred.
Risk treatment methods
Each risk treatment adopted will stem from one or a combination of the strategies described.
A treatment is a process, device, practice or other action that changes a risk by eliminating or reducing it. Possible treatments include physical equipment, management processes and personnel actions.
There are several treatments for reducing risk.
- Eliminate the underlying risk source. This is the most effective control measure and should be preferred over others if reasonably practicable. An example of elimination is changing a bus route to avoid a hazardous situation, for example, a passive level crossing or an unsealed road.
- Substitute the risk source with a less hazardous one, for example, substituting a dangerous substance for a safer one.
- Isolate or separate the risk source, for example, isolating or limiting bus operations in areas of high pedestrian traffic.
- Use engineering treatments, for example, provide automatic sensors to detect obstructions in the door space.
- Use administrative/education treatments, for example, providing driver training.
- Use personal protective equipment, for example, provide specialist clothing.
- Use standards treatments, for example, applying the appropriate standard when deciding on the location of a bus stop.
- Use maintenance controls, for example, maintaining buses appropriately and in accordance with company requirements and standards specified.
Good risk management involves ensuring a number of key factors are in place.
- Competent people – ensure that persons are aware of and understand what they are required to do. Things to consider include experience, knowledge, motivation and whether they need supervision.
- Safe work practices – ensure that activities such as procedures and work instructions are documented and correctly reflect the actions required. Again, ensure that the persons are aware and understand what they are required to do.
- Fit for purpose equipment and materials – provide the right tools and equipment so activities are performed safely. This also includes warning devices if the equipment has limitations.
- A controlled work environment – control the physical conditions of the work location, for example, noise, temperature, vibration, as well as management activities including work schedules and how things are communicated.
The number and integrity of treatments should reflect the level of risk. For example a high risk source should have a number of effective controls in place to manage the risk.
When considering controls you should:
Document those controls already in place for every cause and consequence identified.
It makes sense to stop a risk source becoming an event, so people should aim to identify and use ‘preventative controls’ first. Risk owners will also need to consider treatments if the event has occurred. These are called ‘mitigative controls’ which are needed to manage the consequences.
Consider how effective the treatment is. Risk owners should use the control checklist to evaluate treatments. Remember that treatments should be:
- effective at reducing the risk
- reliable, for example, is it likely to be available on demand
- suitable to the climatic conditions or operating environment.
Note: TSV may, in an audit, ask for evidence to see that these treatments are in place, and they are effective. For example, reliability of treatments could be proven in maintenance records.
Identify any other alternative controls available.
Consider best practice, current standards and industry knowledge, including engineering equipment and latest managerial actions, to identify new treatments. Examples of additional measures include more frequent inspections, changing the staff roster to reduce fatigue. Again, use the control checklist to evaluate these new treatments and consider how effective they are.
Remember when any new equipment is to be constructed or included, the design and construction should always meet the current best practice code/standard if this is reasonably practicable in light of all the circumstances.
Note: If risk owners rank a consequence with treatments in place, make sure that these treatments are actually in place and are working as expected. The reliability of the treatment should be tested/proven to ensure the ranking is not underestimated.
Risk treatment checklist
The following questions should be considered and notes kept on the responses and solutions.
- Is the treatment effective at reducing the risk? If it is not effective, it could be argued that this is not a good control.
- Is the treatment reliable? It is likely to be available on demand, for example.
- Is the treatment suitable to the climatic conditions or operating environment? For example, the tyres fitted are not suitable for snow conditions.
- Is the treatment compatible with the existing systems or operating requirements? For example, a treatment may distract a driver from other duties, or it may interfere with the operation of the vehicle.
- Does the employee understand the procedure and can it be shown that they follow it correctly?
- What happens if this treatment fails? For example, if a component on the bus that fails or an individual does not apply procedure properly.
- If the treatment relates to a referenced standard, for example, AS/NZS Standard or Code of Practice, has it been applied in the right way?
- Do any treatments rely on other systems? For example a component may not function if it does not have a power supply, and the component does not fail in a safe position (fail-safe).
- Is the treatment needed to prevent other causes of hazards? For example, if this treatment fails, could it lead to the realisation of another hazard?
- Are new hazards introduced if the new treatment is implemented? For example, introducing an automated system may affect the competency of the bus driver who may become less alert.
- Are there new standards/codes, systems or technologies that offer new ways to treat risks?
- Is the treatment a relevant good practice? For example:
- is it established practice in Victoria, or another comparable jurisdiction in Australia or internationally, in terms of scale and operation of the Victorian system
- does it demonstrably improve safety in its current application?
Note: What is good practice changes over time, for example, due to increased knowledge from hazards or changes in technology. Regularly review what is current good practice and exercise professional judgement to interpret this information.
Identify and document the treatment measures in place or preventative measures risk owners may implement to reduce or mitigate the risk SFAIRP. Treatment measures should be recorded on a risk register.
Multiple risk treatments may be applied for each risk.
Note: In this continuing example of building a risk register the columns between ‘Item” and Risk treatment method’ have been removed due to space and layout limitations. The items numbers down the left hand side correspond to the item number for the previous steps. See the sample risk register at the rear of this document for a clearer depiction of the steps to this point.
Item | Risk treatment methods |
|---|---|
1 | Buses are fitted with lights and signs that meet the requirements specified in clauses 115, 116 and 117 of Schedule 2 to the Road Safety (Vehicles) Regulations 2009 |
1 | The maintenance regime ensures that buses are not used to provide a school bus service unless the complying lights and signs are serviceable and operating. |
1 | Working with school on an education program for students, highlighting risk. The school will commit to provide the education at the start of each year. |
2 | Buses are fitted with the type and number of mirrors required by VicRoads VSI 30 which provide bus drivers with adequate line of sight of pedestrians around the bus. |
3 | Buses have the type and number of fire extinguishers required by VicRoads VSI 26 in each of its buses. |
3 | Fire extinguishers are fitted and maintained in accordance with AS2444. |
3 | This engineering treatment is supported by a maintenance regime which ensures fire extinguishers are serviceable prior to the beginning of school bus services. |
3 | Drivers are provided with education on the use of fire extinguishers. |
4 | Buses are fuelled at the end of each operating day and the fuel level is checked and recorded on pre-service checklists each morning. |
5 | The operator has adopted a process whereby drivers are rostered in accordance with the standard hours framework. The operator also regularly reviews schedules, trip times and contracts etc to ensure the likelihood of driver fatigue does not become an issue. |
6 | There is a regulatory requirement under BSA for accredited bus operators to have a drug and alcohol policy which requires bus drivers to have no alcohol or drugs present in their blood or breath when or immediately before driving a bus. |
6 | A non-punitive policy exists requiring drivers to advise operators should they not feel capable of operating a bus service. |
7 | This operation complies with a regulatory requirement to calculate, communicate and record the maximum number of passengers that may safely be carried. |
7 | Operator to work with school to ensure capacity demands do not exceed the maximum number of passengers that may safely be carried. |
8 | Buses have one door only. |
8 | A documented procedure exists which ensures that the risks associated with doors are understood by drivers who are required to ensure passengers are well clear of doors prior to closure. |
9 | In addition to buses being fitted with two way radios, drivers are issued with a fully charged company mobile phone prior to operating a bus service. The phone is programmed with all appropriate contact and emergency numbers. It is returned to the manager at the end of each shift and placed on a charger in readiness for the next day. |
10 | This operator has developed and communicated an incident reporting procedure with meets TSV’s requirements. |
Assign risk treatment responsibility
Assigning the responsibility for risk treatment completion (if appropriate) enables the risk register to accurately reflect the status and management accountability for risk management.
Document the status of risk treatment methods, the responsible person and either an expected completion date (if a new method) or a review date (for existing measures) on the risk register.
The effectiveness of risk treatment methods should be reviewed regularly to ensure they continue to be fit for purpose.
Item | Risk treatment methods | Current status | Risk owner | Completion or review date |
|---|---|---|---|---|
1 | Buses are fitted with lights and signs that meet the requirements specified in clauses 115, 116 and 117 of Schedule 2 to the Road Safety (Vehicles) Regulations 2009 | Complete | Workshop manager | Annual review 30/06/13 |
1 | The maintenance regime ensures that buses are not used to provide a school bus service unless the complying lights and signs are serviceable and operating. | Complete | Workshop manager | Annual review 30/06/13 |
1 | Working with school on an education program for students, highlighting risk. The school will commit to provide the education at the start of each year. | Contract manager | Due 20/12/12 | |
2 | Buses are fitted with the type and number of mirrors required by VicRoads VSI 30 which provide bus drivers with adequate line of sight of pedestrians around the bus. | Complete | Workshop manager | Annual review 30/06/13 |
3 | Buses have the type and number of fire extinguishers required by VicRoads VSI 26 in each of its buses. | Complete | Maintenance manager | Annual review 30/06/13 |
3 | Fire extinguishers are fitted and maintained in accordance with AS2444. | Complete | Maintenance manager | Annual review 30/06/13 |
3 | This engineering treatment is supported by a maintenance regime which ensures fire extinguishers are serviceable prior to the beginning of school bus services. | Complete | Maintenance manager | Annual review 30/06/13 |
3 | Drivers are provided with education on the use of fire extinguishers. | Complete | Operations manager | Annual review 30/06/13 |
4 | Buses are fuelled at the end of each operating day and the fuel level is checked and recorded on pre-service checklists each morning. | Complete | Operations manager | Annual review 30/06/13 |
5 | The operator has adopted a process whereby drivers are rostered in accordance with the standard hours framework. The operator also regularly reviews schedules, trip times and contracts etc to ensure the likelihood of driver fatigue does not become an issue. | Complete | Operations manager | Annual review 30/06/13 |
5 | A non-punitive policy exists requiring drivers to advise the operations manager should they not feel capable of operating a bus service. | Complete | Operations manager | Annual review 30/06/13 |
6 | There is a regulatory requirement under BSA for accredited bus operators to have a drug and alcohol policy which requires bus drivers to have no alcohol or drugs present in their blood or breath when or immediately before driving a bus. | Complete | Operations manager | Annual review 30/06/13 |
6 | A non-punitive policy exists requiring drivers to advise operators should they not feel capable of operating a bus service. | Complete | Operations manager | Annual review 30/06/13 |
7 | This operation complies with a regulatory requirement to calculate, communicate and record the maximum number of passengers that may safely be carried. | Complete | Operations manager | Annual review 30/06/13 |
7 | Operator to work with school to ensure capacity demands do not exceed the maximum number of passengers that may safely be carried. By liaising with the school regarding capacity demand, the likelihood of a systematically driven excess is reduced. | Complete | Operations manager | Annual review 30/06/13 |
8 | Buses have one door only. | Complete | Maintenance manager | Annual review 30/06/13 |
8 | A documented procedure exists which ensures that the risks associated with doors are understood by drivers who are required to ensure passengers are well clear of doors prior to closure. | Complete | Operations manager | Annual review 30/06/13 |
9 | In addition to buses being fitted with two way radios, drivers are issued with a fully charged company mobile phone prior to operating a bus service. The phone is programmed with all appropriate contact and emergency numbers. It is returned to the manager at the end of each shift and placed on a charger in readiness for the next day. | Complete | Operations manager | Annual review 30/06/13 |
10 | This operator has developed and communicated an incident reporting procedure with meets TSV’s requirements. | Complete | Operations manager | Annual review 30/06/13 |
Show elimination or reduction of risks
Risk owners must summarise why they believe their risks have been eliminated or reduced SFAIRP. If a risk source is well understood because it is an established practice, there is nothing new or unusual and there are no major stakeholder implications, it can be demonstrated or argued that the risk is reduced SFAIRP.
Several things help demonstrate a risk is being managed SFAIRP.
- The treatments in place meet recognised codes and standards, and they have been applied.
Use of engineering, operational or maintenance codes and standards, for example, may form grounds for demonstrating safety is ensured SFAIRP. Ultimately however, this depends on the circumstances of the case and the context in which the code/standard has been applied. - Good practice in terms of considering new or alternative known controls has been adopted or considered.
- The risk source and associated risk have been evaluated by competent persons using appropriate knowledge.
- The effectiveness and availability of the controls can be validated or proven within their company.
If a process or practice involves more complex scenarios or there is some uncertainty about the risk, for example, new engineering practices or management principles that are not well established, further analysis may be required.
Further analysis may include increased reliance on risk based assessments, for example, quantitative risk assessment and cost benefit analysis, although codes and standards, good practices and engineering judgement remain significant.
Company values may also be influential. For very unusual or challenging decisions, consider the values set by a company or society as they tend to have the most influence on the decision basis, with supporting information from risk-based approaches and engineering judgement.
In order to eliminate or reduce safety risks SFAIRP, risk holders must first understand the nature of the risks and the nature of treatment options.
The nature of the risk
This is what the person knows, or ought reasonably to know, about the risk source or event, the likelihood of the risk eventuating and the degree of harm that would result if the risk eventuated. An understanding of the nature of the risk can be gathered by using a risk register or similar tool.
The nature of risk treatment options
This means any ways of eliminating or reducing the risk and the availability, suitability and cost of these.
An understanding of the risk treatment options may be complex and involve:
- learning more about the risk source
- gaining an understanding of applicable established practice, codes or standards
- learning more about new or alternative treatments.
A risk holder must then consider the risk treatment options and satisfy him/herself that he/she has done all that is reasonably practical to eliminate or reduce safety risks, that is, that all those appropriate have been applied to control the risk.
Consideration should include an analysis of their benefit versus. cost. It may be reasonable to reject a treatment option if the cost versus benefit is grossly disproportionate, that is, the cost of treatment implementation grossly outweighs the benefit to be gained by its implementation.
Lessons can be learnt from the occupational health and safety context because that law is relevant to the bus industry, given the similarity in the wording of the legislation and the common principal of ensuring public safety.
Several points are worth noting.
- A measure is not reasonably practicable if the sacrifices or costs grossly outweigh the risk benefit. For example, spending $1 million to prevent five staff suffering bruising is obviously grossly disproportionate.
- If the measure is practicable and the cost of the measure is not grossly disproportionate to the expected benefit, then the measure is considered reasonably practicable and should be implemented. For example, spending $1 million to prevent a major bus crash capable of killing 50 people is obviously proportionate.
- Any assumptions relating to costs or risk benefit must be documented as these significantly affect the robustness of the outcome.
- The lowest risk option should generally be preferred but if this is not the case, it must be demonstrated why the higher risk level is as low as reasonably practicable.
- If risk owners can’t afford to implement a treatment that is reasonably practicable, they should not engage in the activity that gives rise to that risk.
- If there are options available for eliminating or reducing a risk that achieve the same level of reduction in likelihood or consequence, risk owners may choose the least costly option. However, choosing a low cost option that provides less protection simply because it is cheaper is unlikely to be considered a reasonably practicable means of eliminating or reducing risk.
It is recognised however, that until SFAIRP under Victoria’s bus safety legislation is tested directly in the Courts, uncertainty remains as to what would be the precise legal approach.
The documentation on the risk register of SFAIRP decision-making is important to demonstrate that risks have been eliminated or reduced SFAIRP. An example is included in the appropriate column of the sample risk register.
It is reasonable for operators to reject treatments where the cost of implementation of the treatment is grossly disproportionate to the perceived benefit to safety.
Risk holders may reject a treatment if it is considered not reasonable practical but must summarise the reasons for rejecting the treatment. The reason for rejecting a treatment may change in the next review, for example, it may become significantly easier to implement. It is good risk management practice to record when safety treatments have been rejected for any reason.
The comments/SFAIRP Summary of a sample risk register should record any rejected treatments and the justification for rejection.
Item | Risk treatment methods | Current status | Risk owner | Completion or review date | Comments/SFAIRP summary |
|---|---|---|---|---|---|
1 | Buses are fitted with lights and signs that meet the requirements specified in clauses 115, 116 and 117 of Schedule 2 to the Road Safety (Vehicles) Regulations 2009 | Complete | Workshop manager | Annual review 30/06/13 | I have reduced this risk SFAIRP by applying an industry/regulatory code and ensuring the engineering treatments introduced by the code are available at all appropriate times. |
1 | The maintenance regime ensures that buses are not used to provide a school bus service unless the complying lights and signs are serviceable and operating. | Complete | Workshop manager | Annual review 30/06/13 | I have reduced this risk SFAIRP by applying an industry/regulatory code and ensuring the engineering treatments introduced by the code are available at all appropriate times. |
1 | Working with school on an education program for students, highlighting risk. | Contract manager | Due 20/12/12 | I have reduced this risk SFAIRP by applying an industry/regulatory code and ensuring the engineering treatments introduced by the code are available at all appropriate times. | |
2 | Buses are fitted with the type and number of mirrors required by VicRoads VSI 30 which provide bus drivers with adequate line of sight of pedestrians around the bus. | Complete | Workshop manager | Annual review 30/06/13 | I have reduced this risk by SFAIRP by adopting existing treatments which are considered adequate and meet a recognised standard. Bus design provides adequate drive visibility around buses. |
3 | Buses have the type and number of fire extinguishers required by VicRoads VSI 26 in each of its buses. | Complete | Maintenance manager | Annual review 30/06/13 | I have reduced this risk SFAIRP by applying two recognised engineering treatments and two supporting ‘soft’ treatments. |
3 | Fire extinguishers are fitted and maintained in accordance with AS2444. | Complete | Maintenance manager | Annual review 30/06/13 | I have reduced this risk SFAIRP by applying two recognised engineering treatments and two supporting ‘soft’ treatments. |
3 | This engineering treatment is supported by a maintenance regime which ensures fire extinguishers are serviceable prior to the beginning of school bus services. | Complete | Maintenance manager | Annual review 30/06/13 | I have reduced this risk SFAIRP by applying two recognised engineering treatments and two supporting ‘soft’ treatments. |
3 | Drivers are provided with education on the use of fire extinguishers. | Complete | Operations manager | Annual review 30/06/13 | I have reduced this risk SFAIRP by applying two recognised engineering treatments and two supporting ‘soft’ treatments. |
4 | Buses are fuelled at the end of each operating day and the fuel level is checked and recorded on pre-service checklists each morning. | Complete | Operations manager | Annual review 30/06/13 | I have reduced this risk SFAIRP by adopting the following process: Buses are fuelled at the end of each operating day and the fuel level is checked and recorded on pre-service checklists each morning. |
5 | The operator has adopted a process whereby drivers are rostered in accordance with the standard hours framework. | Complete | Operations manager | Annual review 30/06/13 | I have reduced this risk SFAIRP by: |
5 | A non-punitive policy exists requiring drivers to advise the operations manager should they not feel capable of operating a bus service. | Complete | Operations manager | Annual review 30/06/13 | I have reduced this risk SFAIRP by: |
6 | There is a regulatory requirement under BSA for accredited bus operators to have a drug and alcohol policy which requires bus drivers to have no alcohol or drugs present in their blood or breath when or immediately before driving a bus. | Complete | Operations manager | Annual review 30/06/13 | I have reduced this risk SFAIRP as existing treatments are considered adequate. |
6 | A non-punitive policy exists requiring drivers to advise operators should they not feel capable of operating a bus service. | Complete | Operations manager | Annual review 30/06/13 | I have reduced this risk SFAIRP as existing treatments are considered adequate. |
7 | This operation complies with a regulatory requirement to calculate, communicate and record the maximum number of passengers that may safely be carried. | Complete | Operations manager | Annual review 30/06/13 | I have reduced the risk SFAIRP by applying a series of ‘soft’ treatments that reduce the likelihood of the event occurring in the first place and allow bus safety workers some decision-making flexibility to resolve an event should it occur. |
7 | Operator to work with school to ensure capacity demands do not exceed the maximum number of passengers that may safely be carried. By liaising with the school regarding capacity demand, the likelihood of a systematically driven excess is reduced. | Complete | Operations manager | Annual review 30/06/13 | I have reduced the risk SFAIRP by applying a series of ‘soft’ treatments that reduce the likelihood of the event occurring in the first place and allow bus safety workers some decision-making flexibility to resolve an event should it occur. |
8 | Buses have one door only. | Complete | Maintenance manager | Annual review 30/06/13 | I have reduced this risk SFAIRP as existing engineering treatments are considered adequate. |
8 | A documented procedure exists which ensures that the risks associated with doors are understood by drivers who are required to ensure passengers are well clear of doors prior to closure. | Complete | Operations manager | Annual review 30/06/13 | I have reduced this risk SFAIRP as existing engineering treatments are considered adequate. |
9 | In addition to buses being fitted with two way radios, drivers are issued with a fully charged company mobile phone prior to operating a bus service. The phone is programmed with all appropriate contact and emergency numbers. It is returned to the manager at the end of each shift and placed on a charger in readiness for the next day. | Complete | Operations manager | Annual review 30/06/13 | I have reduced this risk SFAIRP as existing treatments are adequate. |
10 | This operator has developed and communicated an incident reporting procedure with meets TSV’s requirements. | Complete | Operations manager | Annual review 30/06/13 | I have reduced this risk SFAIRP as existing treatments are considered adequate. I have developed and communicated an incident reporting procedure which meets TSV’s requirements. |
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