Submission on draft Australian Standard AS 7531 – Rolling stock lighting and visibility
Steve McGuire, President WAFarmers
17 February 2026
Introduction
The Farmers Federation of Western Australia welcomes the opportunity to provide comment on the draft Australian Standard AS 7531 – Rolling Stock Lighting and Visibility.
WAFarmers represents primary producers across Western Australia, including thousands of grain, livestock and mixed farming businesses operating in the Wheatbelt and South-West. Our members rely on both road and rail networks daily and are directly exposed to safety risks at the road–rail interface.
For farmers, rail safety is not an abstract regulatory topic. It is a practical issue that affects:
- regional freight movements,
- heavy vehicle and farm machinery transport,
- level crossing safety, and
- the everyday reality of driving in low-light rural conditions.
The visibility of rolling stock is therefore a matter of public safety and regional infrastructure responsibility.
The regional context: Rural roads are not metro roads
Much of the national rail safety discussion assumes metropolitan conditions: well-lit crossings, modern warning systems, consistent road geometry and high maintenance standards.
In regional Western Australia, the reality is different:
- Many crossings are passive or minimally protected
- Road approaches are narrow, uneven or poorly maintained
- Dust, fog, crop stubble smoke and glare are common
- Farm machinery moves slowly and has limited maneuverability
- Drivers are often travelling long distances under fatigue pressures
The Wheatbelt is not a controlled environment. Safety standards must reflect the real operating conditions of rural Australia, not idealised urban assumptions.
Visibility is a shared responsibility
WAFarmers supports the intent of AS 7531 in improving the conspicuity of trains, particularly in low-light and high-risk conditions.
However, we stress that visibility must be treated as a shared system responsibility, not a matter of simply placing the burden on road users.
Governments and rail operators have a duty to ensure rolling stock is as visible as reasonably practicable, because:
- trains cannot stop quickly,
- crossings remain a high-risk interface, and
- regional road users often have fewer safety controls available.
If governments are serious about road safety in regional Australia, they must start by addressing the infrastructure and rolling stock standards that contribute to preventable incidents.
Support for strong minimum lighting requirements
WAFarmers supports the inclusion of clear and enforceable minimum requirements for:
- forward lighting intensity and beam spread
- reflective markings and conspicuity treatments
- side visibility for long freight consists
- maintenance standards to prevent degradation over time
In rural WA, long freight trains moving through darkness are a regular occurrence. Visibility is not optional — it is essential.
A train that cannot be clearly seen at distance in dusty or low-light conditions is a safety failure, not a driver failure.
The rail–road interface must be considered holistically
WAFarmers urges Standards Australia and regulators not to treat AS 7531 as a narrow rolling stock specification divorced from broader safety realities.
Rolling stock visibility is only one part of a neglected regional transport system that includes:
- under-investment in level crossing upgrades
- poor regional road maintenance
- ageing freight corridors
- unclear responsibility between State and Commonwealth agencies
Farmers are often told rail is the “efficient freight future,” yet the infrastructure supporting that future is not being maintained to match the rhetoric.
Safety standards must not become a substitute for actual investment.
Recommendations
WAFarmers recommends that AS 7531:
- Explicitly recognises rural and regional operating environments, including dust, fog, glare and passive crossings.
- Sets strong mandatory minimum conspicuity standards, particularly for freight rolling stock operating at night.
- Requires that visibility treatments are maintained over the life of rolling stock, not only at commissioning.
- Encourages alignment with level crossing safety policy, ensuring standards contribute to measurable reduction in incidents.
- Is implemented alongside renewed government commitment to upgrading regional rail crossings and associated road approaches.
Conclusion
WAFarmers supports improvements to rolling stock lighting and visibility under AS 7531, particularly where they enhance safety outcomes for regional road users.
But we emphasise that rural Australians already carry a disproportionate burden of infrastructure risk. Standards must be practical, enforceable, and matched by government investment in the crossings and freight corridors that underpin regional productivity.
Safety at the rail–road interface is not just a technical matter. It is part of the broader obligation to provide a transport system that does not ask regional communities to do more with less.
WAFarmers welcomes continued engagement on this important issue.
