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Procedures for Medical Assessments

Middleton Railway Trust Ltd. (MRT) Policy Directive

Reference: TOP/5 (2/22)

Subject: Procedures for Medical Assessments

For the attention of: Safety Officer, Medical Officer, Traffic Manager, All Train Crew. This Directive forms part of the Safety Management System.

Revision History

Previous versions of this Directive were as follows. Reference 11/01/1 was the initial version.

Reference 8/12/1 replaced this in response to revised guidance from external bodies.

Version 8/12 implemented the revised numbering scheme for directives, but made no other changes to the content. This version incorporates the distinction between the medical questionnaire (previously referred to as self- certification) and medical consultation, the role of the Medical Examiner, the addition of procedures for practical assessments of colour vision and hearing, and other minor updates to ensure consistency with TOP/2 & TOP/6.

Content Summary

This Directive contains the following sections: Introduction

Requirements for Medical Assessments Responsibilities for Medical Assessments Timing of Medical Assessments

Medical Assessment Procedures Record Keeping

Introduction

  1. This Directive defines the requirements for medical fitness for members of staff of the MRT’s staff wishing to undertake certain safety critical duties, and the procedures to be followed in assessing medical fitness, as required by the Train Operating Regulations.
  • The Heritage Railway Association (HRA from now on) has issued guidance note HGA-A0015 on medical assessments. . This was originally published in March 2011, under the reference HGA-P0005 Issue 03 and the title Fitness Assessment for Safety-Critical Workers. It has subsequently been renumbered with no change to its content, and is referred to as “the HRA guidance” from now on.
  • During 2014 the General Medical Council instituted a requirement that medical staff must not practice outside their declared medical speciality, which meant that the MRT’s appointed Medical Officer would no longer be permitted to conduct medical consultations. As a consequence, the MRT needed to make an alternative arrangement, in the form of appointing a separate Medical Examiner who was qualified in the area of Occupational Health. This version of this Directive therefore incorporates the relevant provisions for this, which are not part of the HRA guidance.
  • This Directive defines the duties for which medical assessments are required, the requirements that medical assessments must satisfy, the responsibilities of the Council for appointing a Medical Officer and Medical Examiner, the responsibilities of the Council and of individual officers in respect of the operation of the medical assessment procedures, and the procedures for operating medical assessments and for maintaining records of them.
  • This Directive will be due for review at intervals of 5 years.

Requirements for Medical Certification

  • This Directive applies to the following safety-critical duties which are related to train operation: Diesel Locomotive Second Men; Firemen; Drivers; Guards (both passenger and goods); cleaners; and Shunters.
  • In assessing whether a member of the MRT’s staff is fit to undertake any of the above safety critical duties, the following requirements for medical fitness must be considered. They must all be satisfied if the member of staff is to be deemed fit, allowing for the possible combinations of the adverse circumstances that are indicated.
    • The member of staff must have adequate eyesight to observe signals clearly, and in particular they must be clearly able to distinguish red and green flags or lamps. This applies to all duties.
    • The member of staff must have adequate eyesight to observe possible hazards at a distance, bearing in mind the typical stopping distance of trains on the railway (which can be assumed for this purpose to be 100 metres). This applies to all duties.
    • The member of staff must have adequate hearing to communicate reliably with others, in situations where there may be significant amounts of background noise. This applies to all duties.
    • The member of staff must have sufficient physical strength to operate the controls without discomfort. This applies to all duties, since guards will need to be able to operate handbrakes. In the case of drivers and fireman it also requires sufficient strength to shovel coal without discomfort.
    • The member of staff must have sufficient energy to move frequently between ground and footplate level (approximately one metre vertical distance). This applies to all duties, although the frequency of such movement for guards is significantly less than for the other duties.
    • The member of staff must not be affected by excessive reaction to a smoky atmosphere, or to diesel fumes (in quantities that would normally be regarded as reasonably safe for inhalation), or to conditions that may be hot, humid or both. This applies to all duties except guards.
    • The member of staff must have the ability to maintain concentration on their duties reliably over a normal working period, without suffering distraction from medical causes. This applies to all duties.

Responsibilities for Medical Assessments

  • The Council is responsible for appointing the Medical Officer and Medical Examiner, and for ensuring that the terms of their appointment are documented as recommended in the HRA guidance.
  • The Medical Officer is responsible for preparing the Medical questionnaire, which will be completed by members of staff to provide the required medical information as specified in clauses 17 to 19 below. The Medical Officer is responsible for ensuring that this form is structured in line with the HRA guidance.
  1. The Medical Examiner is responsible for undertaking medical consultations to assess medical fitness where deemed necessary by the Medical Officer or required by the this directive. The Medical Examiner must be familiar with the principles of the occupational health branch of medicine.
  1. The Safety Officer has overall responsibility for the management of the medical assessment procedures, and in particular for ensuring that the details of these procedures are brought to the attention of all members of the MRT’s staff to whom may apply. The Medical Officer is responsible for advising both the Safety Officer and the Traffic Manager if information given by a member of MRT’s staff would affect their ability to undertake their safety critical duties, so that they can take appropriate action.

Timing of Medical Assessments

  1. When any member of the MRT’s staff wishes to volunteer initially for any of the duties listed in clause 6above, a medical assessment must be carried out before they are permitted to undertake those duties. Medical assessments consist of a medical questionnaire which must be completed in all cases, and a medical consultation for certain duties or as requested following review of the medical questionnaire by the Medical Officer.
  1. A medical consultation is required for anyone wishing to undertake the following duties: Diesel Locomotive Second Men; Firemen; and Drivers. For all other duties listed in clause 6 above, the requirement to attend a medical consultation will be determined by the Medical Officer upon review of the member of staff’s completed medical questionnaire.
  1. Once a medical assessment has been carried out, its results will normally be valid for a number of complete calendar years, to be determined by the Medical Officer.
  1. Once a medical assessment has been conducted initially, for all members of staff wishing to undertake any of the duties listed in clause 6 above further medical assessments will then normally be required routinely every five years until the year in which they reach the age of 60, and then in the years at which they reach the ages 64, 66, and 68, and then annually thereafter. Further assessments may be required more frequently at the discretion of the Medical Officer. Further assessments may also be required when a member of staff wishes to take on additional duties which have different medical requirements, as set out in clause 7 above.
  1. A member of staff for whom a medical assessment is due will be notified of the time period within which the assessment must be completed, and the member of staff will be notified that they should make every effort to complete the assessment within that period. If a member of staff is unable to complete the assessment process (either questionnaire or consultation) within this period, then they will be allowed a further period of six months in which to complete this process. If they have still not completed the assessment within this period of six months then the Safety Officer will be notified that the member of staff is deemed to be no longer medically fit to undertake their duties, and must be prohibited from continuing with them.

Medical Assessment Procedures

  1. The medical assessment procedures are based upon the completion of a medical questionnaire, written by the Medical Officer in line with the HRA directive and approved by the Council. A copy of this form will be issued to any member of staff when they initially require a medical assessment to be carried out due to wishing to volunteer for one or more of the duties listed in clause 6 above.
  1. Once completed, the medical questionnaire must be returned directly to the Medical Officer. Members of staff should be made aware that the medical information provided is confidential and will be available only to the Medical Officer. Everyone concerned must observe the requirement that forms in sealed envelopes may only be opened by the Medical Officer.
  1. The Medical Officer will assess the information given on each form, having regard to the safety critical role or roles that the member of staff wishes to undertake. Further clarification will be sought if there are any obvious errors, omissions or ambiguities in the completed form. The Medical Officer may, if necessary, contact a member of staff’s General Practitioner in person to seek further information.
  • Based on the information provided, the Medical Officer may request that a member of staff attends a private medical consultation, where such medical consultations will be routine for those members of staff wishing to undertake the role of Driver, Fireman or Second Man. All members of staff requiring medical consultations will be informed personally of the date and time period when this can take place.
  • At the end of the assessment process the Medical Officer will decide for each member of staff whether that member of staff can or cannot be considered fit to undertake their duties, and additionally whether any restrictions should be imposed on their working practices. Members of staff will be informed of all decisions personally.
  • If a member of staff can be considered fit to undertake their duties, with or without additional restrictions, the Medical Officer or Medical Examiner will complete a Medical Examination Certificate stating any recommendations together with the date of expiry of the certificate. A copy will be retained for the railway’s records.
  • If the Medical Officer decides that a member of staff cannot be considered fit for their duties, or decides that restrictions should be imposed which may affect the running of the railway, the Safety Officer will be informed of the decision and of any restrictions that are to be imposed. The Medical Officer will not pass any information to the Safety Officer about the medical circumstances leading to the decision, unless the Medical Officer considers that this is necessary for the safe management of any activities that may be carried out by that member of staff, and that member of staff gives the Medical Officer permission to pass on this information.
  • It is the responsibility of every member of staff to inform the Medical Officer directly, either by email or in person, of any change in circumstances which may affect their ability to undertake their safety critical role. All

information given by a member of staff about their circumstances, and advice given to a member of staff by the Medical Officer concerning these, will be kept confidential.

  • Under the advice of the Medical Officer or Medical Examiner, a practical colour vision and/or practical hearing assessment may be undertaken in order to satisfy the relevant requirements in clause 7 above. In line with the HRA guidance, the MRT has developed procedures for undertaking such assessments.
  • Medical questionnaires will only routinely be issued to members wishing to undertake any of the duties listed in clause 6 above for the first time. For the duties of guard (passenger or goods), cleaner and shunter, private medical consultations are not routinely required, and so members of staff wishing to continue to undertake these duties will continue to receive a medical questionnaire when their medical assessment falls due. For the duties of Drivers, Firemen and Second Men, where a private medical consultation is required, following an initial medical questionnaire, these members shall then not routinely receive a medical questionnaire, as the private medical consultation fulfils the same purpose. Where a medical certificate is granted for ten years, a medical questionnaire will be required at five years between private medical consultations, in line with clause 15 above.
  • For members of staff who do not require a private medical consultation, upon their initial assessment for a duty (i.e. shunters assessment or guards assessment), local checking of the requirements within clause 6 will be undertaken. This will include eyesight, colour blindness and hearing, utilising the procedures noted within clause 25 above.

Record Keeping

  • All completed medical questionnaires and documents referring to medical information will be confidential and will be held securely by the railway, available only to the Medical Officer. Filed forms and letters will be kept until the relevant member of staff has ceased to undertake the duties to which they relate, and then for the required statutory period thereafter (currently six years). Once this statutory period has elapsed then filed forms and letters will be disposed of by shredding or otherwise destroying as soon after as practicable.
  • A copy of each member of staff’s signed Medical Examination Certificate must be filed securely by the railway along with other operational records, separately from any completed medical questionnaires or other documents referring to medical information. These certificates must be available to the Safety Officer, Traffic Manager and relevant senior staff, so that they can ensure that all working members of staff are properly certified as medically fit for duty.

Drafted by A. J. Cowling, M. Whitaker and D. J. Hebden, and reviewed by R. G. Pike, J. E. Auckland, S. J. Roberts, A. Roberts, M. P. McPeake and C. Campbell and approved on 10th February 2022.