1. Jeremy Mawhood Office of Rail Regulation, Manchester
Rail staff fatigue – the GB regulator’s perspective on managing the risks
Jeremy Mawhood
Office of Rail Regulation, Manchester

2. Session content Why fatigue’s important Some links with culture
Recent GB fatigue experience
ORR fatigue guidance

3. 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!

4. 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?

5. 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

6. 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

7. 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

8. “Triangulating” fatigue?

9. 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

10. “POPMAR” risk management cycle?
Health & Safety Executive Successful Health & Safety Management : “POPMAR” cycle 
P olicy
O rganise
P lan & implement
M easure
A udit &
R eview

11. An FRMS Checklist?

12. 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?

13. …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?

14. 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