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

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

3. 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. 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. 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. 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. 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 LowBasic 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 HighFatigue Risk Management System and Safety-critical work controls

8. 8 “Triangulating” fatigue?

9. 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. 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. 11 An FRMS Checklist?

12. 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. 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. 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