Members,
You would have received an email today from the Chief Emergency Officer titled ‘Operational and Safety Improvement Update’ announcing the introduction of two new SOPs related to Driving Procedures and Standards.
It is important to note that while St John did consult with employee representative groups, our feedback on the key areas of concern generated very little movement.
Speed limit
While the AEAWA was not opposed in principle to a safer maximum speed, we did express a preference for a graduated/staggered approach to an upper limit that would reflect the current gazetted speed limit (which clearly already takes into account traffic load, intersections, pedestrians, residences, road surface). Nonetheless, this feedback was ignored, and a blanket 20kh/h rule was implemented whether the ambulance is driving in a 40km/h zone or a 110km/h zone.
As an interesting side note, our members will recall that the AEAWA executive wrote to St John on 9th March 2024 to raise concerns about an inappropriate and dangerous AmbiCAD message sent from a SOC manager. This message appeared to pressure a crew to drive more quickly to a Priority 3 call without awareness or consideration of road conditions. It is, therefore, ironic that the SOP threatens performance management should an employee breach the policy.
Sirens
This initial draft SOP indicated that sirens must be operated continuously at all times when responding to a Priority 1 (except when lights are switched off at a built-up intersection), regardless of day or night or the absence of traffic. The AEAWA objected to this in the strongest possible terms. The mandated continuous use of sirens was, quite frankly, one of the most ill-conceived ideas in the history of St John; an organisation with a rich and diverse history of ill-conceived ideas.
The legislation provides that the driver of an emergency vehicle will not commit an offence under provisions of the Road Traffic Code so long as they are being used to answer an urgent call, exercising ‘reasonable care’ and displaying “a blue or red flashing light or sounding an alarm.” That is, the legislation requires one or the other but does not require both at the same time.
In framing the wording in this way, it is safe to assume legislators recognised that emergency vehicle sirens can cause significant noise pollution, wake residents and distress their pets, startle pedestrians, and (importantly) cause nervous or new drivers to panic and drive erratically and unsafely. In choosing the wording, the legislators sensibly permitted the driver of an emergency vehicle to use their judgement to determine when a siren may be required or beneficial, as long as they exercise ‘reasonable care’ in doing so.
It is self-evident that the intended purpose of requiring an emergency vehicle to display a blue or red flashing light or sound an audible alarm is to ‘warn’ other road users that the emergency vehicle is approaching and may be operating in a manner not in accordance with provisions of the Road Traffic Code. Its purpose is similar to that of a vehicle horn, where s.191 of the Code states (Use of horns etc.) “A person shall not sound the horn or any other warning instrument in or on a vehicle, unless — (a) it is necessary to use the horn, or warning device, to warn other road users or animals of the approach or position of the vehicle”.
Therefore, if there are no other road users in the vicinity or if the vehicle is no longer (for example) exceeding the speed limit, it should be entirely reasonable and sensible to switch off the audible alarm. In such scenarios, there will either be no other road users to hear or act upon an audible ‘warning’ alarm, or the ambulance is not requiring exemption from gazetted speed limits. In such circumstances, the audible alarm serves no purpose. The current wording of the SOPR-1004 would require an ambulance to both display its blue and red flashing lights and operate its siren directly and continuously, right onto the patient’s driveway.
There was minimal consideration given to the noise pollution generated by this new policy for 24 hours each day. This near-constant siren noise from ambulances would undoubtedly affect the sleep and well-being of residents across Perth. Complaints from the public will increase and for no clear or rational safety benefit.
A significant proportion of priority categorisations generated by AMPDS/ProQA are priority 1. This means that ambulances will use the siren for much of their shift. The higher sound levels (decibels) generated by the siren raise concerns for long-term hearing damage to employees, their elevated stress hormone levels, and anxiety. The siren may be counter-productive while travelling in heavy traffic where drivers have limited opportunity to get out of the way. In such scenarios, the siren may actually cause distress and increase the risk to other road users.
Traffic law is directed at the driver, not the operator of the emergency service or the author of an SOP. The driver’s primary obligation while operating the vehicle is not to injury anyone else. In simple terms, his or her primary obligation is not to crash. If following the St John SOP is (in their judgement as drivers) likely to lead to an accident, then the driver has an obligation to depart from the SOP.
The feedback above was partially successful in generating some movement on the issue. Now, employees have the opportunity to perform a ‘dynamic risk assessment’ to determine the safe use of sirens, though clearly, there is still a strong emphasis on the use of sirens (much stronger than we would like or think is necessary), and we believe many of the above concerns still valid.
Driver Training
We believe that the most significant issue that required a ‘review’ in relation to the ‘Driving Operational Vehicles’ and ‘Driving Procedures Standards’ was the delivery of quality, appropriate, and independent driver training to all operational employees. The review of existing policy was clearly the cheapest solution to address training deficiencies, but it did not absolve the organisation of its duty under legislation to provide suitable and appropriate driver training.
The driver training provided by St John in recent years has been negligent in its inadequacy. Our view is that the organisation has failed to meet its obligations under s.19(b) of the Occupational Safety and Health Act 1984 which requires a PCBU to “provide such information, instruction, and training to, and supervision of, his employees as is necessary to enable them to perform their work in such a manner that they are not exposed to hazards;”.
This is for the following reasons:
Being just two days in length, the driver training offered by St John is not only shorter in duration than many services but also lacks sufficient depth and quality.
The training is conducted internally by College of Pre-Hospital Care (CPHC) pool secondments. The secondments themselves will have only completed the same two-day driver training course (or worse, a ‘train-the-trainer’ version of the course from another secondment).
At no stage during the CPHC trainer recruitment process is the driving record of a candidate assessed, nor their capacity to drive to a high standard.
The training may be well-intentioned and enthusiastically delivered, but it falls well short of what a Subject Matter Expert could deliver.
The secondments are not required to hold any nationally recognised qualification in training and assessment and have not completed any advanced driver or defensive driving courses.
The training fails to present any advanced driver theory such as the ‘system of car control’, which is recognised internationally as a way of approaching and negotiating hazards that is methodical and safe, promoting careful observation, early anticipation, and planning. Such a system teaches systematic use of the controls to achieve maximum vehicle stability.
Once a student completes their initial driver training at CPHC, they are placed with a mentor who has not been assessed in terms of driving record, legal and theoretical knowledge of road rules, or good driving standards.
The student cannot drive priority conditions during their initial tutelage, so they may be required to provide clinical care to the sickest patients (those requiring priority 1 transport to the hospital) while the paramedic drives.
Students are then moved between tutors every 8 weeks, so poor driving practice or unsafe driving habits are not consistently managed. Instead, the problem moves on from tutor to tutor.
On-road tutors who raise concerns regarding driving standards are rarely supported, leading to a culture of ignoring issues that will soon move on to another tutor.
Once off logbooks, Ambulance Officers / Interns are frequently made ‘Spare’. Again, this means a lack of supervision per legislation and inconsistent support in driving feedback.
Qualified paramedics may then be seconded or appointed to roles that require a ‘single officer’ response. They receive little to no bespoke training to drive an entirely different vehicle under priority conditions; vehicles that tend to be lower in height and, therefore, less visible at intersections are generally faster than an ambulance and handle differently.
At no stage during the career of a paramedic is their driving standard or ability reassessed. The AEAWA awaits a response to our concerns about driver training.
Finally, we would like to remind our members that St John’s electronic systems record the speed and GPS route taken for all ambulance journeys. The AmbiCAD also transmits when and where the lights and/or siren were activated or deactivated (a marker illuminates on the lower right of the AmbiCAD screen).
On several occasions, St John has accessed this speed data and initiated the performance management process for our members.
Regards
AEAWA Team