Home> Holden verses Connex South Eastern> Witness Statements> L Holden>                                Paragraphs 53-93: Train Drivers' Hours of Work; Managing for Attendance

Witness Statement of Laurance Holden - Continued

  • Drivers' Hours of Work
  • Drivers' Restructuring
  • Violations of the Safety Critical Regulations
  • Managing For Attendance
  • Sickness Record
  • Driver Only Passenger Operation
  • Charing Cross Signalling
  • Networker Couplings
  • SPADs
  • Time Off for Health and Safety Representatives.

    Drivers' Hours of Work

    53.  Train drivers hours was to my mind the single most important issue relating to health and safety to concern all involved in the railway industry. It was the central plank of my reports to the Railways Inspectorate of 14 January 1999 and 10 October 1999 and my Article for the ASLEF Journal of 23 October 1997. It was also the subject of my reports to the Railways Inspectorate of 13 May 1997, 29 May 1997, 28 October 1997 and the meeting I had with two inspectors on 23 May 1997. It is linked to the issue of inadequate rest periods for train drivers; heat gain in drivers cabs; the lack of air conditioning systems; the incidents of signals passed at danger and the general attitude of Connex Management to these matters.

    54.  To my knowledge there is no legislation that specifically deals with the number of hours that a train driver is permitted to work. It is primarily left as a matter of contract between the train operating company and their employee although the Railways Inspectorate are obliged to monitor the arrangements. The working time regulations specifically do not apply to those involved in the transport industry, but to my mind an analogy should be drawn between the limits opposed by the Regulations and the contracts themselves. I find it bizarre that there are specific limits on the hours that lorry drivers can work through road transport legislation but nothing that caters for drivers of trains containing many hundreds of passengers on monotonous long journeys through some of the most intensive commuter networks in Europe. The Charing Cross and Victoria areas were the most intensive of these systems. The work of a driver is frequently exhausting. Trains rather like aircraft's are placed in a queuing system at busy times and the driver is obliged at all times to stop the train at precisely the correct point on the platform for obvious reasons.

    55.  When I started work for British Rail I was required to work an 8 hour day although the booking on times could be at any hour. Over-time was available but it was always voluntary. Breaks were always for a minimum of 30 minutes and longer periods could be taken. Rest periods always had to be taken between the third and fifth hour of a shift.

    56.  In approximately 1983, the maximum length of a drivers shift was increased to 9 hours and the time that breaks had to be taken was between and the third and sixth hour with either 30 minutes being taken or two lots of 20 minutes during the shift.

    57.  That system remained until June 1997 with no driver ever being required to work more than 9 hours. In 1997, restructuring took place across the whole industry. This was essentially an initiative to modernise what was declared to be outmoded working practices. One of the objectives of drivers restructuring was stated to be to achieve a 37 hour week. A package was put together after negotiations which was approved by ASLEF. A postal ballot of all drivers was conducted and ballot slips were submitted with literature from both Connex and ASLEF in support of the restructuring package.

    58.  It is my view that the drivers were misled about the true effect of the package on offer. At meetings arranged to explain the package, the drivers were assured that they would not be required to work more than 9¾ hour shifts during suburban duties. However, this limit did not include rest periods, time spent walking or travelling to the depot and time spent preparing the trains for the journeys. These are significant times. It can take 25 minutes to prepare a train for a journey and during night shifts, the driver sometimes would have to prepare up to three trains per shift. Time spent walking to the depot is variable, but for example, to walk to the depot from Grove Park would take something between 20-30 minutes.

    59.  I was asked by many of those that I represented about the shift patterns and I explained that it was my understanding that 11 hour shifts could be required of the drivers. None of the shift patterns were published prior to the ballot. I understand a Foreman at Slade Green did print some shift patterns out shortly after the ballot and he received a warning about this conduct. When in due course the diagrams were published many of the drivers were extremely angry and felt they had been misled.

    60.  The Article that I produced for the ASLEF Journal dated 23 October 1997 was never published but I distributed the Article amongst those that I represented nevertheless and the feed back that I received from that Article from the drivers was extremely positive and supportive.

    61.  I was concerned that the package may infringe the Safety Critical Regulations namely, Railway (Safety Critical Work) Regulations 1994 particularly Regulation 4, which states that (i) every Employer shall ensure so far as reasonably practicable that no employee of his undertakes any safety critical work for such number of hours as would be liable to cause him fatigue and could endanger safety; and in determining whether he would be so liable, regard shall be had to the length of time between periods on duty
    (ii) for the purposes of paragraph 1 the person shall be regarded as undertaking work throughout the period that he is on duty
    .

    62.  The approved code of practice made under the Safety Critical Regulations states that the employer should carry out a suitable and sufficient assessment of the risks of fatigue associated with hours of work before increasing existing limits or introducing a material change to existing working time patterns. The regulations also require that a risk assessment be recorded and that accounts should be taken of the views and experiences of the staff effected either directly or through their representatives and that adequate arrangements are in place to monitor the safety performance of the staff effected.

    63.  My letter to the Managing Director of Connex South Eastern of 28 April 1997 highlights in more detail the concerns about these issues. In particular I asked for disclosure of the risk assessment that had been carried out. I felt that as a Health & Safety Representative particularly for the Charing Cross area, I was more than entitled to view this document.

    64.  The reply that I received from the Managing Director dated 23 July 1997 was very general, confirming that a risk assessment was carried out 'in order to comply with the relevant legislation', but it was fairly clear from that letter that the risk assessment was not to be disclosed.

    65.  I have constantly maintained that the Safety Critical Regulations were breached by Connex. I believe they have been breached in the following ways:
      (a) Risk Assessment

      My understanding of how the Risk Assessment was conducted was that a group of Connex Managers met at a hotel in Tonbridge and drafted one. Neither myself nor any of the other Health & Safety Representatives to my knowledge have ever been shown it. We understood that the Risk Assessment dealt with previous shift patterns rather than future shift patterns but due to the fact that I have never seen it, I can only speculate as to its contents. Not only did I request a copy of the assessment from the Managing Director but I have also requested it from local Managers on numerous previous occasions. On 23 December 1997 I met with the Production Manager, Mr Goff and the Safety Standards Manager, Mr O'Neill and again requested a copy of the Risk Assessment. My request was refused.

      (b) To take account of the views and experiences of effected staff.

      The Health & Safety Representatives were not consulted about this Risk Assessment. The only consultation that took place was through the Drivers Functional Council who were members of ASLEF. However, none of the drivers were Health & Safety Representatives nor were they trained in health and safety issues and I would be surprised if they were aware of the Safety Critical Regulations.

      (c) Monitoring of the changes

      This did not occur.

      (d) Measures to counteract fatigue

      If a driver were to ask for relief due to fatigue, the Local Drivers Standards Manager would record it in a book. As far as I am concerned, that was the extent of measures put in place. Fatigue was never counteracted at all. In fact the effect of having a formal record of these complaints was that drivers would be concerned about raising the issue in case it was in some way to be used against them subsequently. Speaking only anecdotally my view as that incidents of fatigue were quite rare prior to restructuring. Following restructuring I received a huge number of verbal complaints from drivers who felt more and more tired. None of these drivers would have been prepared to put this into writing although I do have two written reports from drivers and indeed I submitted one myself.

      (e) Inadequacy of rest periods

      All I can say is that the period of breaks after restructuring made fatigue more likely.

      (f) Requirement for the Induction of gradual changes

      This did not occur. A change in the shift patterns occurred overnight in June 1997.

      (g) Consideration of reverting to previous shift patterns.

      In reality the way the package had been agreed with the industry was such that this was never going to happen. Everyone was telling Connex that drivers restructuring was endangering safety but I am not aware that they ever considered reverting to the previous system. I would refer to the following matters all of which should have brought this to the attention of Connex:

        (i) HMRI Survey of 1997.

        This Survey was unprecedented and the conclusion that it reached was critical of the restructuring arrangements. The survey results were only circulated to Health and Safety Representatives. An earlier report by Dr Lucas of the Health and Safety Executive's Health Directorate was very critical of a number of aspects of Connex's approach.

        (ii) Circadian Technologies Report

        Circadian Technologies carried out a survey for Thameslink and other train operating companies into drivers hours. They were commissioned by Connex South Eastern to do one for them after the Railways Inspectorate suggested that one should be undertaken. This took place at the end of 1997. The Health & Safety Representatives were never consulted. I understand that the general results of the Circadian Technologies Survey and a number of other surveys that were reviewed appeared in a Sunday Times article in the context of the rail industry overall. Circadian Technologies made certain proposals but I have never seen the Report and it was never circulated. I do not know what the proposals were and I have requested a copy of this Report on numerous occasions. To date it has never been disclosed to me or made public.

        (iii) Halcrow Transmark

        This Report was commissioned by Connex after the Circadian Technologies Survey and presumably because Connex did not like the Report that they received. Halcrow Transmark relied upon data provided by Connex which to my mind was flawed and again virtually no consultation with the drivers or their representatives took place.

        (iv) Loss Control Reports

        When a signal is passed at danger, the driver is required to complete a report of the incident. He would then sit down with a Driver Standards Manager to complete a more detailed document. The DSM would insert his own conclusions and this Report would then be submitted to the Safety Standards Department at Head Office.

        As Health & Safety Representative I would only get to see the overall summation by the DSM in the Lost Control Report. Even then we would only receive them intermittently. In 1998, I barely received any Lost Control Reports and I would constantly have to pester Management for them. It was my view that this monitoring system was inadequate because the Representative would only get the gloss put on the incident by the Driver Standards Manager rather than the explanation by the driver himself.

        I carried out my own survey on Lost Control Reports from June 1997 to the end of 1998 in the Metro area. I found that out of the signals passed at danger that occurred 11 out of approximately 20 could be attributed in the main part to tiredness or fatigue brought on as a result of drivers restructuring. This survey featured in my report to Her Majesty's Railways Inspectorate in January 1999.
    66.  The way that shift patterns worked after restructuring was that drivers would work a week of morning starts and a week of afternoon starts. The maximum number of hours that a driver could be required to work was 11 but this may not include travelling back to the drivers own depot. The minimum hours I believe was 6. If a driver worked 6 hours he would not be entitled to a rest break. Sundays were no longer optional and rest breaks were no longer obliged to be taken between the third and sixth hour of a shift.

    67.  Although this did not happen all of the time. It was possible to work 9 or 10 days in a row, each day comprising of an 11 hour shift. It follows that when drivers come to the end of a period of those sort of shifts they are extremely tired. I know of one Ashford driver who did 77 hours in a 7 day shift and at my depot the highest was 70½ hours in a 7 day period.

    68.  The problems identified with the shift patterns led to a second restructuring in March 1999. This resulted in the maximum shift being reduced to 10½ hours with a shorter aggregate working week. The number of hours in charge of a train in intensive suburban areas was reduced to 8¾ hours which projects to a maximum of 66 hours per 7 days. They also prohibited the taking of rest periods in the first or last hour of the shift but this still meant that some drivers could be on duty for 9 hours with only a twenty minute break.

    69.  Mark 2 restructuring had been a wonderful opportunity to overcome the culture of long hours for train drivers but it was an opportunity missed and many of the drivers were severely disappointed. This has almost certainly led to the industrial action that took place at the beginning of the year 2000.

    Illness/Managing for Attendance

    70.  In my opinion Driver Restructuring led to a large increase in the number of drivers reporting sick in the Connex Metro area. I believe I reported figures in my Article for the ASLEF Journal.

    71.  The problem was that drivers were genuinely becoming fatigued after working long hours intensive driving. Not only would they go sick with fatigue, the stress they were under would increase which led to sickness for other reasons as well.

    72.  Frequently on long night turns, drivers would ask to be relieved from their duties in the cab. The driver would then have to report to a Manager and explain why he was tired. The driver would then have to prepare an Incident Report which was to be placed on his Personnel File which meant that frequently the problem would go unreported.

    73.  Many drivers would approach me as their Health & Safety Representative in confidence saying that they would be making errors of judgement as they were so tired and something simply had to be done about the problem. I would estimate that at my depot 30 out of the 70 drivers complained about this issue to me at one time or another. Drivers would also say that the stress was effecting their home life making them irritable, etc. That would be hardly surprising with long days that sometimes start at 2.30 am and therefore disturbed the whole household. I too suffered from fatigue and a lack of sleep. This problems was noticeably at its worse when restructuring came in but the problems have mainly gone unresolved and many of the drivers still have real problems coping. If Connex point to improvement in the sickness levels amongst drivers this will be because of the introduction of the Managing for Attendance Scheme. This Scheme was introduced to monitor absence levels amongst staff and to encourage attendance. The systems is triggered if a member of staff has two instances of sickness or absence within any 13 week period or 5 instances of sickness or absence within a 52 week period. A 5 stage approach is envisaged. This is as follows:

      Stage 1  When an absence is triggered under the above criteria, a Supervisor will call the employee in for a meeting and warn that employee that the level of absence has given rise for concern and that they will be closely monitored and that they should maintain their fitness for work. They are told that if their absence within the next year exceeds prompt levels formal action will be taken. There does not seem to be any discretion given to the Supervisor.

      Stage 2  If absence exceeds the prompt levels, the employee will be called in for an informal interview by the local Manager and asked for an explanation. It is suggested that consideration be given to referring the employee for an OHS Assessment and that no further action be taken until the Report is received. If no good reason can be found for the poor level of attendance, the employee must be warned that further action may be taken which could result in dismissal.

      Stage 3  Where absence continues as before a further interview with the Line Manager should occur whereby the employee will be told that unless their attendance improves they will be dismissed. A final warning will be administered.

      Stage 4  In the absence of mitigating circumstances the Contract of Employment should be terminated.

      Stage 5  Is the Appeals procedure to be considered by a Senior Manager.
    74.  Given that there is little room for the exercise of discretion and no room at all under Stage 1. These procedures are triggered after only two days absence in any thirteen week period, many employees were too concerned to either go sick or report fatigue. This had the knock on effect of them trying to cope with their own tiredness and their stress levels were increased. This is what happened to me.

    75.  Prior to 1997, I had a minimal sickness record. In 1996 I had four days off sick. In 1997 I had seventeen days off sick. The Chronology of my Sickness Record for that time is as follows:

    14 May 1997Migraine
    14-15 June 19972 days off suffering with stress
    22 July 1997Stage 1 Letter and Meeting with Foreman under the Managing for Attendance Procedure
    20-21 August 1997Fatigue. I had been up at 3.45 am for most of that week on a shift of earlies getting home at 4.40 pm extremely tired and making mistakes at work. I needed some rest.
    24-29 August 1997I was diagnosed by my GP with Labyrinthitus which was an ear infection affecting my balance. I was put on a drug course which meant that I was unable to be in charge of a train during that time.
    4 October 1997Migraine after the inhalation of environmental tobacco smoke at work.
    16-17 November 1997Fatigue and tiredness. I was leaving my home at 9.40 am, getting back home at 10.50 pm. With eating and sleeping I had no spare time and found that I was making a number of mistakes at work.
    14 February 98Admitted to hospital after inhaling environmental tobacco smoke at work
    18-19 February 1998Fatigue. I was up at 2.20 am to be home at 2.45 pm.
    3-4 April 1998Fatigue. I was up at 2.20 am getting home at 3.20 pm.
    18-19 May 1998Migraine.
    9 June 1998Stage 2 Interview under the Management for Attendance Procedure with Line Manager. I was concerned about how this interview may go and decided to record the conversation. During this interview I pointed out the problems that I was experiencing with fatigue and that I wasn't being given any time off by Connex to carry out my Health & Safety Representatives duties. Consequently, I was doing much of this work in my spare time and often working late into the night. I pointed out that this was a breach of the Health & Safety Regulations to the Manager. His response to me was that I should just get more sleep
    24-25 July 1998Fatigue. I was up at 6.00 am and working until 4.30 pm, getting home at 5.20 pm.
    20-21 September 98Fatigue for the 5 days previously, I had worked getting up at 2.30 am, booking on at Charing Cross at 5.19 am and booking off at 2.18 pm, arriving home at 3.20 pm. After 5 days of those shifts I was suffering from fatigue and took two days off.
    27 October 1998I had a Stage 3 Meeting under the Managing for Attendance Procedure with Local Manager Gollop. On that particular day I was shattered having got up at 3.30 am and worked the first part of my shift. The meeting itself did not start until 1.00 pm when we went through the sickness that I had taken. We also went through two days when I had booked on late. I had an Observer at that meeting and I was put on a Final Warning which meant that if I had any sickness at all within the next 12 month period I would have been sacked pending appeal. The problem then was that I was on this Final Warning and daren't take any time off sick. Both myself and a number of other drivers would then come in on a number of occasions when we were simply unfit to drive trains because we had no alternative. An example of this was an incident at Albany Park on 29 November 1998. I was on my last trip down to Dartford towards the end of a long duty. I was completely exhausted and braked fractionally too late. The sharp braking was compounded by a problem with wheel adhesion and the train slipped past the platform by one coach. The wheel slip protection cut in and overrode my braking system. I had to report this incident to the Driver Standards Manager at London Bridge and was interviewed by him afterwards and had to provide a urine sample. I mentioned at this meeting that I was exhausted and I complained about the long hours to him but he seemed completely disinterested.
    8 July 1998I saw my GP Dr W [name withheld]. I mentioned that I was feeling really tired and finding it hard to concentrate. She took a blood sample to see if I was suffering from anaemia which I wasn't. I was diagnosed as suffering from depression. I told my GP all about the duties and hours that I was working and that I was finding it extremely hard to cope especially on early turns. I was offered counselling which I didn't take up simply because I didn't have enough time to go and see the counsellor.

    76.  I have found that since I've left the employ of Connex I have had a new lease of life and all of the old problems of fatigue and depression seem to have left me. I have seen a counsellor twice since I left Connex but I find it hard to find anything to talk about, probably because the main source of my anxiety was my working conditions.

    77.  The problem of time off was made worse by the inability to take accrued leave that was due. We were entitled to four weeks leave, two weeks in the Summer and two one week periods at other times. However, it is possible to gain extra days leave by working bank holidays. I had accrued a number of days to take as leave. I had applied for leave on a number of occasions and on well over 50% of the occasions that I wanted off, my Application was declined. To make matters worse in 1999, I received a letter from Management pointing out that if I did not use my accrued days up, they would be forfeited. This was a point that I had raised with the Manager at my Stage 2 Meeting.

    78.  In order to cut down on the amount of travelling that I was doing and the type of urban intensive work that was increasing my stress levels I put in an Application to move to the Tonbridge depot. I submitted my Application for a move on 31 December 1996. That Application was acknowledged and at that time I was told that I was something like 7th in line for a transfer. In fact I raised my pending move at my Stage 2 interview in June 1998. There were vacancies at the Tonbridge depot but they were not allowing moves from drivers in the Metro region and were filling the Tonbridge depot with relief drivers. I believe this issue was being pursued by the Functional Council but I never heard that it had been resolved. When I came to leave in January 2000 my move to Tonbridge had still not been processed. This was unfortunate because it would have cut my working hours considerably and I am sure improved my sickness record. It was very difficult to get into Charing Cross to book on at say 4.38 am which was the earliest booking on time.

    79.  I remained on a Stage 3 warning for 15 months, from 27 October 1998 to January 2000. It was due to be until June 2000, a period of 20 months. On 21 September 1999 I did have to take one day off suffering from a severe migraine. The medication that I took Migril is mildly hallucinogenic and extremely potent. It was prescribed to me by my Doctor. It would have been grossly irresponsible and probably criminally negligent for me to have driven a train whilst on this medication. The mere fact of having to take the day off sick with the prospect of being dismissed caused me great concern and increased my stress level which of course increased the intensity of my migraine.

    80.  Fortunately, the only action that was taken was for me to receive a reminder letter that I was on a Final Warning. There were two breaches of the Managing for Attendance Procedure as far as I can tell. Firstly, despite the improvement in my attendance in 1999 I never received any letter congratulating me as is required by the procedure. Secondly, after the Stage 2 interview and certainly after the Stage 3 interview, I should have been referred to an Occupational Health Specialist. This was not carried out. If it had of been carried out I am certain that the stress and fatigue issues would have been highlighted.

    81.  I also believe that as a Trade Union Sponsored Representative, the Union must be notified by Connex of any action under the Managing for Attendance Procedures but to my knowledge this was not carried out.

    82.  I was disciplined in December 1999 (which I will return to later) and after that Hearing a Final Warning was administered. I was told that I would remain on Stage 3 of the Management for Attendance Procedure until June 2000, which is the equivalent of a final warning.

    83.  The amount of work that I had to do as a Health & Safety Representative was extensive. The failure of Connex to engage with me in any meaningful way increased the burden upon me to highlight their failings. If they had sought a dialogue and a constructive approach to the problem, the situation would have approved not only for me but for all of the other drivers. There was a singular failure to consult in any meaningful way, with the Health & Safety Representatives, in breach of the 1997 Regulations on a number of different areas. I have already referred to the problems created by a lack of consultation over driver restructuring.

    84.  The introduction of Driver Only Operated Trains (DOO'P') between 1992 and 1994 was imposed upon us again with no consultation. This had a significant impact on the working conditions of drivers who were often isolated and at risk of assaults from the public.

    85.  There were significant problems with the signalling at Charing Cross. The trains going into Charing Cross were due to be extended to 12 coaches and the intention was to extend the length of the platforms which meant that a new signalling system was necessary. Again there was no consultation on the new signalling system which was imposed. The signals were very unclear and ambiguous and caused a danger. It took three versions before the signals were up to any sort of safety standard and the final version was still far from perfect. The driver went through a red light at Charing Cross, just before Christmas 1999. Had there been consultation with the driver themselves, they would have been able to point out the problems before money was spent installing the systems.

    86.  A weakness was identified by Connex in the networker trains in the couplings between the carriages. Some of the couplings failed during service. To overcome this problem and without any consultation with the drivers Connex unilaterally decided to lock all of the doors between the carriages. This created a potential and obvious fire hazard. I spoke to the Railways Inspectorate and ascertained that they were not aware of the practice. A meeting was then organised in January 1996 but the Charing Cross and Slade Green Drivers Representatives were not booked onto this meeting. The reasons given by Connex were 'exigencies of services'. I didn't find out about this meeting until after it had started.

    87.  I constantly sought consultation on the individual incidents of signals passed at danger and this was constantly refused. I asked local Managers for copies of the forms that the drivers completed after a SPAD. The local Managers always refused my request and it was not until shortly before I left that I saw my first SPAD form. There is even a SPAD Group Meeting which is held quarterly but no Health & Safety Representatives are ever allowed to attend. The Railways Inspectorate explained this to me at a meeting in May 1999 when he was extremely critical of the ways that these meetings were conducted. Each SPAD was read out without any form of analysis and the drivers that did attend these meetings had no health and safety training and were not from the Metro area. I would ask that if signals passed at danger are not health and safety issues, then what on earth is?

    88.  There was never any consultation over the improvements sought to the Charing Cross Drivers Accommodation.

    Time Off for Health & Safety Representative Duties

    89.  As I stated in my Health & Safety Report of 9 November 1997, Connex were in virtually permanent breach of Regulation 4 that provides for time off with pay and facilities to carry out these duties. This state of affairs continued through the latter years of my employment with Connex. The fact is that local drivers Health & Safety Representatives were forced to carry out the vast majority of their duties in their own time. Other than specific events, meetings and inspections, Connex rarely allowed local drivers Representatives to be released for duty to carry out the wide range of work that we were involved in. Up to 9 November 1997, I had been permitted one days release from duty in that year. In the Autumn of 1996 as I pointed out in my report, we were also allowed one days release but the Local Manager changed his mind at the last minute without giving any explanation. I referred to the sort of work that I had to do in my role which includes consulting with my members and taking their views on matters, taking up issues that they raised, investigating incidents, gaining access to Connex and the Health & Safety Executive Libraries, researching and writing Reports to the Union, the Railways Inspectorate, Local and Senior Management, etc. The Regulations estimate that there should be one Health & Safety Representative per 35 employees. For Connex Representatives at depots of 70 to 120 drivers involved in 'front line' safety related work with an accident rate above the national average, the burdens upon those Representatives were quite intolerable and the fact that it was virtually impossible ever to get any time off.

    90.  Notwithstanding my Report of 9 November 1997, the last day off I was given for health and safety business up until the time that I left was at the end of 1997. During 1998 I requested time off in writing twice and never received a response from Management.

    91.  We were allowed time off to attend the Area Safety Committee Meetings. The last time that we actually got through the Agenda of one of these meetings was in 1998. The Local Manager would organise the times of these meetings and would deliberately coincide with the networker meetings which did not deal with safety issues. Normally the Area Safety Committee would meet at 9.00 am with the Networker User Group scheduled to start at 11.00 am, thereby curtailing the Safety Committee's discussions.

    92.  At no time have I ever been allowed a room, office, accommodation or furniture to carry out any of my tasks. I am not aware of any rooms in the London area available to me. The only telephone that I can use is in the mess room. It follows that when drivers consult me they wish to do so on a confidential basis, particularly when they talk about stress related matters. I have never been able to afford them any sort of privacy when they consult me.

    93.  Another part of my duty is to carry out inspections and prepare Inspection Sheets for my area. These sheets are supposed to be completed in conjunction with Management and I get one day off for these inspections. There are supposed to be four Inspection Sheets completed a year, yet I have not had a form fully completed by Management since 1997.


    Holden verses Connex South Eastern> Witness Statements> L Holden >
                                                                                                        Paragraphs 94-117: Disciplinary Procedures


    Paragraphs 1-52: Health and Safety Issues; Cases of Negligence> L Holden>
                                                            Witness Statements
    > Holden verses Connex South Eastern > Home