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Rail staff fatigue – the GB regulator’s perspective on managing the risks

Jeremy Mawhood

Office of Rail Regulation, Manchester

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Session content

Why fatigue’s important

Some links with culture

Recent GB fatigue experience

ORR fatigue guidance

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Why control staff fatigue?

Perceived weariness from reduced sleep, extended time awake, disrupted sleeping/waking periods or heavy workload

Factors:

Work related

Individual

environment

Increases risk of errors

Hard to detect (self & others)

May be unaware of lapses, “micro-sleeps”

Serious high profile accidents worldwide e.g. nuclear, chemical, aviation, maritime, rail

Makes dangerous, expensive mistakes more likely!

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Links with culture

Management, staff/union interests may conflict

Pay systems long hours, suppresses fatigue reporting

Staff may like fewer, longer shifts for long blocks off work

Pressure to keep working may suppress fatigue reporting

Staff won’t raise fatigue concerns if perceive will be “punished”

Staff personal responsibility to use sleep opportunities

Openness, trust, honesty: a “just” culture

Collaboration – joint management & staff fatigue group?

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Recent GB fatigue experience

From prescriptive working hours limits to…

goal-setting law : ensure no-one works if so fatigued they could injure selves or others – company decides how

Inspections & discussions:

Some over-reliant on “hours” limits

Some using mathematical fatigue tools, but again over-reliant

Struggling with links to pay / time-off, industrial relations, culture

Fatigue from travel to / at / from work neglected

More guidance on expectations please

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ORR guidance “Managing Rail Staff Fatigue”

on ORR website Jan 2012

Not “compulsory”, can take other effective action, but

Regulator may reference as good practice guidance

Proportionate approach to fatigue - controls in proportion to risk

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Proportionate “three-tier” approach

Type of work 

Likely significance

of risks from fatigue

Relevant sections of the guidance

No shift-work,

no significant overtime,

no safety- critical work

Low Basic fatigue controls

Some shift-work and/or

significant overtime, but no safety-critical work

Medium to

high

A comprehensive

Fatigue Risk Management System

Safety critical work 

High Fatigue Risk Management System

and Safety-critical work controls

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“Triangulating” fatigue?

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Fatigue Risk Management System (FRMS)

FRMS concept e.g. civil aviation

Identifies & draws together dispersed fatigue controls

Science & hard info rather than custom & practice

Tailored to own operation

Integrated with wider risk controls

Continuous, adaptive process, continually monitoring & managing fatigue risks, WHATEVER their causes

Many descriptions of FRMS contents, but many common features so…

ORR guidance summarises key FRMS features for GB rail companies

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“POPMAR” risk management cycle?

Health & Safety ExecutiveSuccessful Health & SafetyManagement : “POPMAR” cycle

P olicy

O rganise

P lan & implement

M easure

A udit &

R eview

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An FRMS Checklist?

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Fatigue - some key points in POPMAR approach…

Policy:

Leadership, commitment?

Collaboration, culture?

Resources / workload / fatigue / stress links?

Organising:

Joint management / staff / union fatigue group?

Employment Terms & Conditions, pay systems fatigue-friendly?

Travel time to / at / from work controlled?

Planning & implementing:

Triangulate from good practice guidelines, fatigue tool, feedback from reality?

Fitness-for-duty arrangements consider fatigue through to end of shift?

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…key points continued…

Measuring:

Deviations from planned patterns monitored?

Staff experiences sought e.g. fatigue surveys, rating scales?

More progressive e.g.

On Train Data Recorder (black-box)?

Sleep logbooks?

Actigraphs (sleep wristbands)?

Auditing & Reviewing:

Are Key Performance Indicators for fatigue established & tracked?

Overall FRMS effectiveness reviewed?

General:

Fatigue controls proportionate, integrated into wider systems?

An FRMS “signposting”document?

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Conclusions

Fatigue contributes to dangerous, costly incidents

No single, simple solution, so…

Multi-layered defences : a collaborative Fatigue Risk Management System

ORR guidance : key FRMS features, checklist helps compile “signposting” document skeleton FRMS

Thank you