A BLET Reference Manual of
Railroad Worker Fatigue
A Report Prepared for the
Brotherhood of Locomotive
Engineers & Trainmen
A Division of the Railway
Conference of the
International Brotherhood of
Teamsters
By
Mark K. Ricci, Ph.D.
September 2004
Executive Summary
This reference manual was produced
for BLET leaders as a resource to use when addressing fatigue issues in the
railroad industry. The reference manual
provides background information for fatigue.
After introducing the utility of
fatigue management plans around the world for reducing railroad worker fatigue,
a BLET fatigue management plan is outlined.
The five major elements of the BLET fatigue management plan include
Education, Medical Aspects of Fatigue, Critical Aspects of Fatigue, Chronic
Aspects of Fatigue, and Evaluation.
The reference manual concludes with
three strategies for resolving railroad worker fatigue. The three strategies are 1) a preferred
non-prescriptive approach using the BLET fatigue management plan; 2) a
prescriptive approach through the FRA RSAC process again using the BLET fatigue
management plan as a template; and 3) a statute achieved through a
Congressional mandate of four elements that addresses the 5 major aspects
envisioned by the BLET fatigue management plan.
A toolbox of fatigue countermeasures
divided into the five major elements of the BLET plan for possible
implementation in receptive railroad operations is provided as an appendix.
Table
of Contents:
Introduction 4
Background
The
Fatigue Problem in the Railroad Industry 5
Fatigue Management Plans 6
Around
the World
In
the
A
BLET Fatigue Management Plan 7
Education
Aspects of a Fatigue Management Plan 8
Medical
Aspects of a Fatigue Management Plan 10
Critical
Aspects of a Fatigue Management Plan 13
Chronic
Aspects of a Fatigue Management Plan 15
Evaluation
of a Fatigue Management Plan 17
Where
to Apply Fatigue Management Plans 18
Computer Modeling of Fatigue 20
Strategies and Timelines for
Resolving Fatigue 21
Appendix: A Toolbox of Fatigue Countermeasures 24
Resources 27
Bibliography 28
INTRODUCTION
The purpose of this reference guide
is to provide leaders of the Brotherhood of Locomotive Engineers & Trainmen
with an update of research, issues, and strategies effecting railroad worker
fatigue. Starting with a short
background of recent efforts to resolve fatigue issues for engineers and
trainmen, the guide goes on to outline the fatigue issue and ongoing efforts to
provide a solution for members of the BLET.
Efforts to resolve fatigue are
explored first and foremost with a focus on non-prescriptive solutions intended
to resolve the fatigue issue without prescriptive intervention by government,
either by regulation or statute.
Non-prescriptive efforts involve cooperation between labor and
management to forge effective fatigue management plans for each railroad in the
A timeline for resolving railroad
worker fatigue using non-prescriptive efforts suggests that the BLET adopt a
deadline for a successful solution of these efforts. At some point in time, the BLET must
determine if a non-prescriptive approach to resolving railroad worker fatigue
is feasible based on:
·
effectiveness---do they work to reduce worker fatigue
·
comprehensiveness---do they address all aspects of railroad worker
fatigue
·
inclusiveness---are all railroads in the
Finally, in the absence of a
satisfactory non-prescriptive fatigue resolution, two prescriptive strategies
are discussed: a regulatory effort
through the FRA and a Federal statute passed by the US Congress. All three prescriptive and non-prescriptive
efforts are focused on mitigating the three “Aspects of Fatigue” that concern
engineers and trainmen: medical aspects,
critical aspects, and chronic aspects of fatigue.
Background: The 2002 BLE Proposal – E.I.E.
In September 2002, the BLET,
formerly the Brotherhood of Locomotive Engineers, proposed a solution to
fatigue in the railroad industry. The
proposed solution was based on a belief that if the railroads, government, and
labor would come together in good faith, the problem of railroad worker fatigue
could be resolved.
More than just a Pollyanna
suggestion, the proposal entitled Education, Information, and Empowerment
(E.I.E.), envisioned using a “systems” approach to mitigate serious fatigue
plaguing the railroad industry. Railroad
worker fatigue results in millions of dollars of damage from accidents each
year and has been identified by the National Transportation Safety Board (NTSB)
as a contributing cause of railroad worker fatalities. Generally, the 2002 BLE fatigue proposal
suggested that if:
1) railroad workers were
educated about fatigue and how to avoid it, and
2) if Management and Labor
would work together exchanging information about improving schedules and other
work practices that contributed to fatigue, and
3) if railroad workers were
permitted to absent themselves from duty if their individual fatigue interfered
with their ability to safely perform their duties;
then fatigue in the railroad industry could be resolved for the good of management and labor. In this suggested proposal, government was seen as an arbiter and a facilitator to ensure success of the overall process, but the solution would be non-prescriptive (no government regulation.)
The E.I.E. initiative met with
indifference from both management of the nations railroads and the government
agencies mandated to address railroad worker safety. Throughout 2003, railroad management
continued to “pay lip” service to resolving worker fatigue and the Federal
Railroad Administration (FRA) acquiesced to railroad management indifference to
the fatigue problem.
However, railroad safety bills
introduced in Congress included sections mandating the Department of
Transportation (DOT) to address railroad worker fatigue by requiring railroads
to institute individual fatigue management plans. In addition, the NTSB is applying pressure to
the railroad industry to address railroad worker fatigue after investigating
recent railroad accidents. Researchers
are nearing completion of computer programs that they argue can be used to
identify railroad worker fatigue in post-accident analysis. The FRA, responding to public and political
concerns, are preparing to support the validation of the computer fatigue
models in order to move toward a resolution of unsafe levels of fatigue in the
railroad industry.
In addition, on
With these pressures, the industry has made tentative
moves toward mitigating the problem of railroad worker fatigue. The industry has begun to re-energize the
Work / Rest Task Force that began looking for an industry solution in the late
1990’s. However, railroad efforts can be described as
tentative, uneven, and at times intended to delay a solution to the railroad
worker fatigue issue.
The Fatigue Problem in the Railroad Industry
Railroad worker fatigue has plagued the industry from
the founding of railroads. Signs and symptoms of fatigue include forgetfulness,
poor communication, a bad mood, poor decision-making, fixating, nodding off,
slowed reaction time, apathy, itchy eyes, reduced attention, lethargy, and/or a
need to sit or rest (5). However, there
is no scientific definition of fatigue accepted by the
Beginning in the late 1980’s, the NTSB identified
railroad worker fatigue in several severe railroad accidents. By the early 1990’s, the NTSB focused on
fatigue as one of its top concerns to improve safety in the railroad industry.
Since that time, several proposals
from labor and management have resulted in minor changes, some successful pilot
projects that were never expanded, and considerable resistance from government,
management, and even some labor to resolve railroad worker fatigue. Attempting to overcome this resistance and
resolve railroad worker fatigue are concerned families, safety experts, and
some government officials.
Understanding the resistance to
change in the most oversimplified terms means addressing the tensions each
group is experiencing. For labor, a
tension exists between earning potential and fatigue from overworking. This tension exists with a host of
qualifications given the individual’s personal experience, but generally
includes family commitments, personal commitments, and social needs. However, in a recent survey by the BLET,
89.1% of BLET members responding said work/rest cycles were important or
extremely important. Also, 88.3% of BLET
members responding identified layoff provisions as important or extremely
important. BLET members are asking with
gusto for a solution to the fatigue problem.
For Management, railroad worker
fatigue exists in a tension between defined employee availability and economic
corporate self-interest. This tension is
mitigated by scientific advances that may result in legal liability for using
fatigued workers in railroad operations.
For example,
For Government, railroad worker
fatigue exists in a tension between addressing railroad worker and public
safety while at the same time avoiding government intervention into the “free
markets” of railroad operations. This
tension exists within a political environment that could potentially change
drastically in the near future.
Within this shrinking acceptance of
railroad worker fatigue, there exists a small window of opportunity to
comprehensively address railroad worker fatigue from a scientific formulation
without government intervention. The
Work/Rest Task force is pursuing this non-prescriptive effort in order to avoid
the mandates of federal regulation. The
Work/Rest Task Force believes that federal mandates will entirely eliminate
options enjoyed by railroad workers and railroads alike. For example, mandated 7 days available for
work followed by 3 days of rest (7 & 3) might be acceptable to workers on
one railroad while at the same time entirely unacceptable to railroad workers on
another railroad. This is one
prescriptive solution advocated by some interests in the railroad
industry. Therefore, in order to provide
a framework that comprehensively addresses railroad worker fatigue in the
FATIGUE MANAGEMENT PLANS
Around the World
In
According to one Canadian railroad
source, railroad workers average 35 hours per week on duty. However, many workers also reach the newly
developed Canadian maximum of 64 hours in a 7 day period.
Fatigue Management Plans in the US
Several US Class 1 and short-line
railroads with operations in
Yet, railroads presently voice a
level of comfort with fatigue management plans having some experience with the
Canadian model. Translating the Canadian
“process model” into the
In order to progress a
non-prescriptive solution to fatigue that will effectively resolve engineer and
trainmen issues, a framework must be designed and a collaborative process
invoked to achieve the results other countries have achieved recognizing that
both labor and/or management may choose to sabotage this non-prescriptive
effort. Sabotage from any quarter might
necessarily invoke action from government as described above.
A BLET Fatigue Management
Plan
An effective fatigue management plan
in the
Success using fatigue management
plans might be measured and incremental, not revolutionary, as many workers,
managers and government agencies may desire.
Yet, successful mitigation of fatigue may produce a process born from
trust that could be advantageous in future management/labor negotiations. An outline of fatigue management that
addressees the scientific, social, and organizational concerns of the BLET is
described below.
Education Aspects of Fatigue a Management Plan
Education to resolve fatigue is
necessary for successful mitigation of engineer and trainmen concerns. However, education needs to be focused for
three different stratums of railroad workers.
For example, the sort of education necessary to successfully mitigate
personal levels of fatigue in an engineer or trainmen is different from the education
necessary to convince a railroad chief executive or chief operating officer of
the necessity of incorporating a fatigue mitigation plan in that executive’s
railroad work place.
Senior
Management Educating Senior Management for effective fatigue management
in the railroad industry requires a focus on the options that a fatigue
management plan provides for a
Yet, management is reporting a need
for 80,000 railroad workers in the next five years. In addition, new workers tend not to accept
the fatiguing schedules the railroads have relied upon for decades.
At the same time, pressure on
Congress from interest groups has heightened the urgency to resolve fatigue
related concerns. Also, accidents that
might previously been attributed to other causes are now including the impact
of fatigue in the accident when completed in a root cause analysis process.
Management has historically relied
on labor to be divided over solutions to resolve fatigue, thereby doing
nothing. Labor has identified several
scientific issues that corroborate longstanding experience in railroad
operations, thus providing new leverage for solution to fatiguing railroad
schedules. In addition, some scientific
advances such as “computer based fatigue modeling” (see below) suggest that an
objective base for legally determining responsibility for fatigued railroad
workers is not far away.
Bringing all of these ideas into a
single education piece that will convince railroad executives to support the
application of fatigue management plans will be necessary before these plans
can be implemented in the industry. At
present, this education piece has not been designed, produced or implemented in
the railroad industry. Both the North American Rail Alertness Partnership (NARAP) and the
Work/Rest group
have discussed this issue, but no action plan has developed.
Railroad
Supervisors
While it is necessary to educate senior managers of the need and efficacy of a
successful fatigue management plan, middle and first line supervisors need to
be educated about the importance of supporting and incorporating the iterative
process of managing railroad worker fatigue into the daily regimen of railroad
operations.
Many railroad managers effectively
argue that workers use fatigue as a method to avoid work. In many cases managers suggest, with
negligible expert experience, that a particular worker is not fatigued because
he/she is returning from vacation or was granted more “rest” than the hours of
service law requires. Inevitably,
management at times choose to interpret limited personal scientific knowledge
about transportation worker fatigue to justify failed scheduling, abusive
working conditions, and unjustified demands by corporate cultures ill prepared
to integrate management school “mental models” (1) into the demanding real
world of railroading.
In addition to certain management
assumptions that contribute to unsafe levels of fatigue in the railroad
industry, some supervisors of engineers and trainmen themselves are
experiencing unsafe levels of fatigue.
The symptoms of fatigue such as irritability, inability to concentrate,
and impaired judgment can lead to unsafe levels of stress in the
supervisor/labor working relationship.
For example, in an actigraph (discussed below) study, one manager was
supervising engineers and trainmen with just 1 hour of sleep in a 24-hour
period.
Clearly, a candid discussion of
educational deficiencies of railroad supervisors on the issue of worker fatigue
as discussed above would be resisted in current railroad operations. Further, it is not the responsibility of
labor to advocate for management working conditions. Yet, in order to address unsafe levels of
fatigue in the railroad industry, fatigue management planners must pay
attention to this group contributing to fatigue in the railroad’s system. Overcoming the issues discussed above in
order to create a culture that encourages fatigue management plans is both
daunting and necessary in order for a non-prescriptive effort to succeed.
At present, this educational piece
of the fatigue management plan process has not been fully discussed, let alone
designed, produced, or implemented.
Considerable effort by the Work/Rest group, with perhaps technical
assistance by NARAP, will be necessary for this important piece of the puzzle
to be integrated into effective fatigue management plans.
Railroad
Workers For
railroad workers, education has occurred for many years about the hazards of
fatigue in the industry and how to mitigate fatigue to reduce those hazards. At the same time, new workers need to be
educated about the effects of fatigue, how to mitigate fatigue in a busy
railroad life, and what to do if mitigation efforts fail. In addition, existing railroad workers must
be kept informed about advances in mitigating fatigue in the work place for
shift workers and unconventional work schedules.
An effective educational tool would
necessarily include recent research around fatigue mitigation, important
lessons from recent sleep research, as well as health and fitness information
designed to mitigate unsafe levels of fatigue.
Further, any education tool must be multifaceted in order to achieve
both goals of easy accessibility and frequently updated information. It does no good to provide Internet access as
a tool to a working population that may be Internet illiterate or too fatigued
to access the information. Yet,
pamphlets, booklets, and posters cannot be relied solely upon to meet the
educational needs of adult railroad workers.
Current adult education techniques
should be employed, as well as, multi-faceted tools integrated into the culture
in order for education to be maximally effective in mitigating railroad worker
fatigue.
At present, both NARAP and the
Work/Rest task force are seeking out options to fully address the concerns
raised above for the benefit of railroad workers. A proposal for a web based education process
accessible to railroad labor and management and managed by the Work/Rest Task
Force is under consideration. Costs
might be shared by the affected railroads and labor organizations.
Individual Responsibility Mitigating
unsafe levels of railroad worker fatigue ultimately relies heavily on
individual railroad workers taking responsibility for their personal work and
sleep habits. However, in order for individuals to exercise personal
responsibility for managing fatigue, those individuals must be provided with
the tools necessary to implement personal fatigue mitigation efforts. These tools include education, information,
but most importantly the time to sleep and recuperate from
fatiguing schedules. Once all of these tools are made available to
the railroad worker, it is necessary to rely on all existing cultural tools
possessed by labor and management to ensure that fatigued workers are absent
from the work place.
Resolving worker fatigue is not just an effort by unions to get railroads to address the numerous issues contributing to the problem, railroad workers themselves must be accountable for using the tools available to become properly rested to perform railroad service. A safer railroad environment requires an effort by all parties to participate as they are able, to ensure a rested railroad work force.
Currently, successful efforts by operation red block/operation stop have been employed by railroad workers to assist each other in the process of eradicating drugs and alcohol from the work place. The E.I.E. proposal offered by the BLET envisioned a peer oversight process to discourage fatigued workers from performing railroad service. History suggests that as part of an effective nationwide “systems” solution to railroad worker fatigue, individual responsibility and peer support may well emerge as integrated aspects supporting the goal of reducing unsafe levels of railroad worker fatigue.
At
present, the Work/Rest Task Force is considering peer intervention as part
of a total solution to fatigue in the railroad industry. It is not logical to suggest that this
element can be incorporated as a stand alone process without the accompanying
tools necessary for individual railroad workers to use to mitigate their
personal fatigue. Toward that end, the
Work/Rest Task force is developing a toolbox of available options to help
mitigate unsafe levels of railroad worker fatigue (see appendix). Ideally, each railroad’s management and on
property labor representatives (General Committees of Adjustment) might draw
from this toolbox to create an effective fatigue management plan. The toolbox is not inclusive however, and
individual railroad management and labor leaders may evolve new ideas from the
toolbox primer.
Medical Aspects of a Fatigue Management Plan
According
to the National Institutes of Health (NIH), in the general population in the
US, up to 40% of adults report at least occasional difficulty sleeping, while
chronic and/or severe insomnia affects about 10-15% of adults. Anecdotal reports suggest that the railroad is
experiencing fatigue from medical aspects at a rate greater than the general
population. There is no confirmative
research providing information about this disparity. However, the NTSB asserted medical problems
resulting in fatigue as a contributing cause in the
Sleep
apnea, a breathing disorder characterized by brief interruptions of breathing
during sleep, affects as many as 18 million people, according to the National
Institute of Health.
Collectively, excessive
daytime sleepiness, insomnia,
sleep apnea,
narcolepsy,
restless legs
syndrome, periodic limb
movements and parasomnias
represent sleep disorders with medically approved treatments. At last count, nearly 90 fatigue related
medical disorders have been identified by researchers. When the medical treatments are observed,
research shows that unsafe levels of fatigue can be removed from the workplace.
The good news is that with proper diagnoses and
treatment, greater than 90% of all fatigue resulting from medical issues can be
effectively resolved without interfering with an employee’s ability to work as
a railroad engineer or trainmen. Getting
the railroads to act upon this information in a sensitive and supportive manner
that will serve to reduce the medical aspects of fatigue in the railroad
industry is the overall goal of this section.
One last note, in September of 2004, the FRA issued
an advisory to the “railroad community” recommending:
·
Establish training and educational programs to inform employees of the
potential for performance impairment as a result of fatigue…and document when
employees have received the training.
Incorporate elements that encourage self-assessment, peer-to-peer
communication, and co-worker identification accompanied by policies consistent
with these recommendations.
·
Ensure that employees’ medical examination include assessment and
screening for possible sleep disorders…Develop standard screening tools…and
provide an appropriate list of certified sleep disorder centers…
·
Develop and implement rules that request employees in safety-sensitive
positions to voluntarily report any
sleep disorder that could incapacitate, or seriously impair, their performance.
·
Develop and implement policies such that, when a railroad becomes aware
that an employee in a safety-sensitive position has an incapacitating or
performance-impairing medical condition related to sleep, the railroad
prohibits that employee from performing any safety-sensitive duties until that
medical condition appropriately responds to treatment.
·
Implement policies, procedures, and any necessary agreements to—(a)
Promote self-reporting of sleep-related medical conditions…; (b) Encourage
employees with diagnosed sleep disorders to participate in recommended
evaluation and treatment; and (c) Establish dispute resolution mechanisms…
Most or all of these recommendations
have been addressed by the Work/Rest Task Force with recommended solutions for
management and labor to act upon.
Implementation intended to respond to these recommendations awaits completion
of the overall Fatigue Management Plans by the individual railroads in
cooperation with the General Committees of Adjustment. As stated above, railroad officers, not labor
leaders are at present delaying resolution of the fatigue issue in the railroad
industry.
Railroad Policies on Medical Aspects of Fatigue Instituting a policy or collective bargaining agreement that
acknowledges and treats fatigue from medical problems just as it would any
other medical issue is necessary for effective implementation and resolution of
fatigue resulting from medical problems.
Succinctly, a policy as
worded below may effectively address the medical aspects of fatigue as
experienced in railroads today and satisfy the concerns of the NTSB and FRA as
outlined in the report noted above.
A sleep
disorder will be addressed similar to any medical condition that may impair an
employee’s ability to safely perform essential job functions, with or without
reasonable accommodation. Sleep
disorders will be evaluated on an individualized basis by a health professional
to determine the employee’s medical fitness for service. (This does not infringe upon an employee’s
rights under an existing collective bargaining provision.)
Supporting a policy like this is the
Family and Medical Leave Act (FMLA).
With FMLA as a safeguard, it may not be necessary to turn the railroad
policy into a collective bargaining agreement.
Each General Committee of Adjustment will need to make this final
determination. Once the policies are in
place on the nation’s railroads, it will be necessary to address logistical
issues.
Medical Provider Education Not all medical doctors are properly trained to
diagnose fatigue related illnesses.
Specialists, particularly in outlying railroad communities that are
distant from specialty practitioners, must be identified and a list of these
specialists must be provided as a necessary tool to the railroad worker. The most effective person for collecting this
information and providing it to the railroad worker is the fatigue management
specialist on the railroads. Other
federal agencies may be sought out to supplement this railroad produced list of
medical providers. Providing a list of
medical professionals for engineers and trainmen to access is not an invitation
for railroad management to interfere with, or unnecessarily intrude into, an
individual’s medically prescribed treatment.
Individual Responsibility Once the policy is in place, labor and management
working together can forge education and/or peer intervention efforts to
encourage railroad workers to receive medical evaluations for possible fatigue
related problems before they result in an accident. With the reassurance that railroads will not
punitively interfere with employees efforts to support their families,
individuals will have the tools necessary to resolve personally with their
private physician a medical intervention that will ensure their ability to work
properly rested and free from medical problems resulting in fatigue.
As discussed above, ultimate
responsibility for addressing fatigue from medical problems reside within the
individual. The railroads have the
responsibility however, to provide the tools to the employee, as discussed
above, in order to ensure “a safe working environment.”
At present, the Work/Rest task force
has developed the general wording for the nation’s railroads to adapt into
company policies. Various class one
railroads are in the process of developing these policies and developing
strategies to address the logistics of implementing these policies. This is an opportunity for General Committees
of Adjustment to input the policy process on the individual railroad
properties. No short-line properties
have reported any movement toward implementing the medical policy stated
above. However, the short-line railroads
are part of and contributing to the progress made by the Work/Rest Task Force.
Critical Fatigue Aspects of a Fatigue Management Plan
Critical aspects of fatigue result from the unique
demands of working in the railroad industry.
For example, working on call 24 hours a day seven days a week often
without reasonable forecasting of schedules or lineups may result in a severe
short term loss of sleep. These
situations can occur immediately following extended rest periods such as
vacation, days off or long layovers.
Often times, they result from the vagaries of the system that fails to
forecast with any effectiveness the movement of trains in the
When attempts to mitigate critical aspects of fatigue
fail and a railroad worker is identified as experiencing a lack of sleep, what
is provided by the railroads to mitigate this safety hazard?
Short Term Sleep Loss Short term sleep
loss research spanning many years and originating in Australia has identified a
correlation between the amount of sleep an individual gets and his/her fitness
to perform certain safety related transportation duties.
In 2004,
Sleep researchers have often advocated eight hours of
sleep each night for individuals. Dinges
(4) suggests that individuals require a minimum of 7.5 hours of sleep per
day. Today Americans average 6.9 hours
of sleep on weeknights and 7.5 hours per night on weekends according to the
2003 poll of the National Sleep Foundation (NSF). From
These calculations contribute to part of the experience
of critical fatigue in the railroad industry.
Circadian Rhythms Short
term sleep loss does not entirely explain the experience of critical fatigue in
the railroad industry. Research dating
back decades have identified biological cycles conforming generally to the 24
hour day. Between 3-5 am and to a lesser degree
between 3-5 pm ,
the human body experiences “down cycles” when our bodies physically demand
sleep. These circadian rhythms exist as
unalterable difficulties in ever changing railroad operations.
During these periods,
shift workers often experience a debilitating need to sleep. Mitigating these biological needs may be
complimentary to mitigating short term sleep loss, or the solutions may involve
separate fatigue mitigation efforts.
However, short term sleep loss coupled with biological down cycles
either individually or together creates a critical fatigue concern in the
railroad industry.
Possible practical solutions to critical fatigue The National Sleep Foundation has identified
the following possible solutions for mitigating circadian sleep loss:
·
Short breaks
throughout the shift.
·
Working in
groups. (Note: Avoid single man
operations.)
·
Try to exercise
during breaks.
·
Try to eat three
normal meals per day.
·
Drink a
caffeinated beverage early in the shift, e.g. before
·
Don't leave the
most tedious or boring tasks to the end of the shift.
While the National Sleep Foundation provides ideas
based on traditional shift worker research, railroad worker experiences,
particularly from short term sleep loss may require making additional
opportunities or mitigation efforts possible for railroad workers. Thus in addition to NSF recommendations to
make opportunities available for the recommended stop gap measures above, other
successful solutions to critical fatigue include:
·
·
Allowing the
worker to absent themselves from duty when they have not gotten the minimal
amount of sleep necessary to safely perform a shift.
·
Creating rest
periods that exceed the minimum eight hours rest provided by federal law and
allowing workers to optionally book these extend rest periods as needed.
Combinations of these tools may effectively mitigate
critical fatigue in the railroad work place.
For a more complete, but not exclusive, list of options see the tool box
in the appendix.
At present, various Class One railroads are experimenting
with various combinations of the above mitigation efforts for critical aspects
of fatigue. However, no railroad in the
Chronic Fatigue Aspects of a
Fatigue Management Plan
Sleep Debt Research While addressing critical fatigue is necessary, it does not
necessarily relieve railroad workers from chronic aspects of fatigue. Chronic fatigue describes accumulated
fatiguing factors that build over the course of a work week. For example, researchers have found that if
an individual sleeps extensively on his/her first rest day, the individual’s
body may be recovering from sleep debt that has accumulated during the work
week. Dinges (4) argues persuasively
that sleep debt research is relevant to addressing chronic worker fatigue.
According to the National Sleep Foundation, working more
than 60 hours a week increases your risk of driving drowsy by 40%. Kraus, at one time researching for the
Association of American Railroads (AAR), reported that engineers “working more
than 50 hours a week have a significantly higher rate of accidents than those
working fewer hours.” This research
raised additional concerns about yard service engineers working the overnight
time frames.
According to the US Department of Transportation
(DOT)(5), fatigue results from “the combination of long work periods and other
non-duty factors that contribute to on-the-job fatigue, by limiting the
available time for recreation, rest, and sleep. Over extended working periods,
repeated inadequate sleep periods can result in accumulated sleep debt and
associated operator fatigue.” While the
US DOT and the railroads may choose to emphasize off duty contributions to
fatigue, all waking hours contribute to the accumulation of sleep debt, since
there are only 24 hours in any day. Therefore,
the railroads requiring 12-23 hours of work in a 24 hour period necessarily
must respond to accumulated sleep loss.
While the federal “Hours of Service” limits work to 12 hours, one
railroad territory reported over 900 times railroad workers were on duty in
excess of 15 hours in a single month in 2004.
Health Aspects contributing to
fatigue In addition to acquired sleep debt from working
extended hours, health aspects may contribute to fatigue. Several health issues are associated with
chronic fatigue in the general population.
Weight issues have been related to interrupted sleep. Exercise, properly scheduled with work and
sleep has been identified as mitigating chronic fatigue, though incorrectly
scheduled can actually contribute to critical fatigue.
For railroad workers, unpredictable schedules can
result in the best efforts by an individual to address health aspects of
fatigue resulting in higher levels of fatigue.
For example, exercise too close to sleep can disturb normal sleep
patterns. Eating too close to sleep is
counter productive. Yet, with eight
hours rest mandated by law, addressing health aspects of fatigue is virtually
impossible without mitigation during work hours.
Possible practical solutions to
chronic fatigue Research indicates that in order to overcome a
sleep debt, workers need time of extended undisturbed rest. In addition, a single sleep episode fails to
restore an accumulated sleep deficit.
Often, a minimum of 48 hours of rest or more is necessary in order for
the individual to experience more than one sleep period that will
satisfactorily restore an accumulated sleep deficit.
Examples used in the industry include work / rest
cycles such as 7 & 3, 8 & 3, or 10 & 5. In other words, a worker on a 7 & 3
schedule is available for duty to the railroad for 7 days and then is provided
the option of up to 3 days of undisturbed rest.
Reports from railroad workers suggest that initially
there is resistance to work / rest scheduling, particularly if the rest periods
are mandatory. However, over time
optional work / rest cycles are accepted and individuals often report
significant relief from fatigue.
Negative reports from railroad workers suggest that the
7-10 day work availability can be excessive for many workers from a fatigue
standpoint. For these, a 4 days
available, 2 days off, 3 days available, 1 day off schedule (4 & 2, 3 &
1) might relieve fatigue concerns and provide another option for railroads and
workers alike.
Other options to address chronic aspects of fatigue may
include:
·
Scheduled meal
periods during work shifts
·
Exercise options
in the work place
·
Scheduling trains
and using assigned crews rather than using extra, pool service, or irregular
service
For a more complete, but not
exclusive, list of options see the tool box in the appendix.
At present, several Class One railroads are experimenting
with various combinations of the above mitigation efforts for chronic aspects
of fatigue. However, no railroad in the
Evaluation of a Fatigue Management
Plan
Once labor and management have agreed to a fatigue plan
on an individual railroad, how will railroad workers know if the efforts are
successful beyond their individual experience?
Railroad workers realize that not just personal or “my” level of fatigue
is hazardous to my safety, but my coworker’s level of fatigue can be even more
hazardous to my safety. Evaluating each
railroad’s fatigue management plan is necessary to move the fatigue issue from
talk into action.
Methods
of evaluation can take two forms: direct
measures and proxy measures. In
addition, no single measuring tool will effectively determine if fatigue has
been reduced in the work place. Further,
the measuring tool will necessarily respond to the solutions implemented by the
various railroads. However, in all
cases, management and labor will be determining whether medical, critical, and
chronic aspects of fatigue have been reduced in the railroad workplace.
Direct Measures of Railroad Worker Fatigue Direct measures of fatigue describe tools that
directly report a variable that has been theoretically related to fatigue. For example, actigraphs are a “wristwatch”
type of device that measures an individual’s activity or inactivity based on
the person’s movement. Extremely reduced
periods of activity are assumed to
indicate the person is sleeping.
Measuring the total sleep accumulated in 24 hours, and using a standard
assumption that a minimum of 5-8 hours of sleep is necessary in that 24-hour
period provide a direct measure of fatigue to the user.
Other direct measures of fatigue include Electro
Encephalogram, Multiple Sleep Latency Test, Stanford Sleepiness Scale, and
sleep diaries. It should be noted that
all of the direct measures of fatigue are fallible. Actigraphs must be constantly worn to be
effective; if removed in any 24 hour period the report is not accurate. Tests that have been developed for the
individual to report their personal level of fatigue have been shown to
“under-report” the true level of the worker’s fatigue. In other words, we are often more fatigued
than we are prepared to admit. Finally,
many direct measures require expert analysis, resulting in a cumbersome or
complicated process that is not suitable for railroad operations.
Proxy Measures of Railroad worker
Fatigue Proxy
measures of railroad worker fatigue measure variables that are assumed to
directly correlate with fatigue. For
example, it might be argued that fatigued workers are less efficient in
handling trains thus causing increased fuel consumption. Thus, by calculating fuel efficiency a
railroad might arguably be able to track railroad worker fatigue. However, proxy measures tend to exist as a
second order or intermediate variable that can be affected by other issues. In this example, personnel issues unrelated
to fatigue, such as attitude, can affect fuel efficiency. Also, fuel efficiency can be affected by
environmental variables such as wind, snow or rain. Finally, mechanical issues such as clogged
fuel filters, continuous wheel slip, or inaccurate train tonnage can affect
fuel efficiency.
Proxy measures can be made
with effort to approximate a level of fatigue experienced by railroad
workers. Generally, direct measures tend
to more accurately address the BLET’s concerns of reducing railroad worker
fatigue.
How to Use Measures of
Railroad Worker Fatigue Either direct or proxy, the measures chosen by management and labor on
the individual railroads provide a tool to initiate a “continuous improvement
process.” Ultimately, each iteration of
the improvement process will contribute to an eventual “best practice” for
consideration or adoption by other General Committees of Adjustment or other
railroad operations.
Finally, a solution to fatigue can
also be a measure of fatigue in the workplace.
For example, if railroad workers are allowed to absence themselves from
railroad service when they are fatigued without interference from management,
the tracking of these requests becomes a valuable tool for measuring fatigue in
the workplace. In addition, the absence
of these requests also is a measure of a work place not suffering from
debilitating fatigue.
At present, no railroad has
implemented a systemic program in cooperation with labor that measures railroad
worker fatigue. Without this effort, it
is difficult for any railroad in the
Where does the Fatigue
Plan Apply?
For the fatigue plans to effectively resolve
railroad worker fatigue in the
Further, the plans must be applicable to all
railroad operations. Figure 1 below
provides an outline of the BLET proposed fatigue management plan as it would
apply on any single railroad in the
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Figure 1 |
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Scientific
Concerns of Fatigue in the Railroad Industry |
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Assigned Service |
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5 Day / 8 hour day |
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Education |
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Medical |
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Critical Fatigue |
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Circadian Rhythm |
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Chronic Fatigue |
Sleep Debt |
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Health Aspect |
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Evaluation |
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Assigned Service |
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5, 6, or 7 days / 8-12
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Critical Fatigue |
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Chronic Fatigue |
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Evaluation |
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Unassigned Service |
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Work Train |
Extr Brd |
Pool Sevice |
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Start Time |
Any Time |
Any Time |
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Critical Fatigue |
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Chronic Fatigue |
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Health Aspect |
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Management |
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Senior |
Middle |
Front Line |
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Any Time |
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COMPUTER MODELING OF
FATIGUE
Finally, it is worth noting that several researchers are attempting to provide the railroad industry with a computer-generated model that arguably identifies fatiguing schedules in the railroad workplace. At present, these models are not a scientifically reliable indicator of railroad worker fatigue. None of the models have demonstrated a level of accuracy necessary to impose restrictions on a railroad worker due to fatigue. Further, none of the models are accurate enough to capture all experiences of railroad worker fatigue. These models are nearly as likely to report a fatigue incident when one did not exist as they are to ignore fatigue as a contributing factor when it is applicable.
Further, the computer models
envisioned by the FRA would provide a scheduling tool for railroads to predict
fatigue. At the same time, NTSB suggests
creating a model that effectively provides reliable evidence of railroad worker
fatigue in a post accident investigation.
At present, the model envisioned by the FRA does not address the issues
important to locomotive engineers and trainmen---namely identifying and
reducing railroad worker fatigue accurately and without capitulation to
railroad’s self interest.
What use are models
Certain railroads have utilized
models to provide workers with a tool to create work schedules that address
fatigue within the constraints of railroad operations. These railroads intend for the models to
provide new ideas to mitigate railroad worker fatigue. These models have been met with mixed results
from railroad workers. However, on
occasion these models have proven successful education tools for work groups to
develop effective mitigation in local work environments.
Predictive Ability
For any tool, such as a computer
model, to be effective it must be able to reliably predict worker fatigue. In this regard, reliability requires direct
measures of fatigue from the individual worker and a scientifically validated
computer model. In this manner, a
predictive model can be implemented to address fatigue predictions for railroad
workers as well as post accident analysis and testing. Current government sponsored research does
not yet appear likely to produce this sort of computer model for fatigue.
Application Suitability based on
reliability
Based on the current level of
research, computer models of fatigue are not ready for wide use in the railroad
industry for mitigating worker fatigue.
As a “toy,” these models can provide a basis for users to understand the
complexity of railroad worker fatigue. Significantly
the models at present are not a
significant threat to BLET interests.
They may actually evolve into a valuable tool at some future date to
progress the interests of BLET members.
STRATEGIES AND TIMELINES FOR
RESOLVING FATIGUE IN THE RAILROAD INDUSTRY
The BLET has participated in ongoing efforts to resolve
railroad worker fatigue using non-prescriptive cooperative efforts for nearly a
decade. At some point, the BLET must
determine if these efforts have adequately met the safety interests of BLET
members. Toward that end, an arbitrary
date might accomplish the goals of the BLET.
It must be remembered, that under the current BLET leadership at least
two major nation wide efforts to forge a fatigue solution in the railroad
industry have been attempted. Without
leadership from the railroads and/or prodding from government, non-prescriptive
efforts to resolve fatigue are doomed to failure.
Non-prescriptive Approach
It is not unreasonable to expect
that by January 1, 2005 , the railroads must
commit to accept the premise that voluntary fatigue management plans created
between individual railroads and the on property representatives of railroad
workers is the desired course of action for resolving railroad worker
fatigue. Failing a commitment by senior
railroad management and senior labor executives by that date suggests that a
non-prescriptive solution to railroad worker fatigue is not obtainable within a
time frame that addresses the safety concerns of BLET members.
Failing a successful non-prescriptive solution of
fatigue, there are two possible avenues for government-imposed solutions to
railroad worker fatigue: a Congressional
mandate and/or a regulatory mandate from the FRA. Each possible solution depends on the events
discussed in the “Problem” section above and the outcome of the 2004
election. A favorable election result may
permit the BLET to seriously consider a prescriptive resolution of the fatigue
issue, if the membership demands it, with a realistic expectation that a
positive mandate may result. Without the
benefit of knowing in advance the results of the election, the following
discussion outlines the possible strategic direction for the BLET failing an
acceptable non-prescriptive solution.
Prescriptive Approach
Using Federal Regulation
If either the US Congress mandates or the FRA chooses to
move toward a regulation to address fatigue in the railroad industry using
fatigue management plans, the strategy and goals outlined above for a
non-prescriptive solution would generally meet the needs of the BLET under a
regulatory solution. This assumes that
the FRA does not approve exemptions to the federal hours of service as current
laws allow. This also assumes that
Congress does not impose changes to the federal hours of service law. This process would be attainable through a
Rail Safety Advisory Committee or RSAC.
The BLET has witnessed several concerns of its members either totally
ignored, or seriously downplayed by the FRA to conform to “Railroad interests”
during RSAC processes in the past. The
BLET may not be any more successful addressing fatigue through regulation than
other issues brought to the FRA for consideration.
Prescriptive Approach
Using Congressional Mandate
Should the US Congress choose to
address fatigue with a federal law that ignores the RSAC process, the BLET
needs four mandates that effectively resolves the issues of medical, critical
and chronic fatigue described above.
1)
Congress would need to address the medical aspects of fatigue either by
using existing federal law or implementing the basic statement proposed as a
principle in the non-prescriptive solution above.
2) In order to address the
Critical aspects of fatigue, a mandate should be included that addresses an
individual’s right to absence him/herself from duty if they are too fatigued to
safely perform their railroad job.
Language can be adopted from the Federal Motors Carrier Act, as was
proposed in the E.I.E. initiative of the BLE in 2002.
3)
In addition to language about railroad workers absenting themselves
from duty if they are fatigue, language should be developed that mandates
immediate transportation to the final terminal upon completion of 12 hours on
duty. This is a necessary step to reduce
the critical and chronic fatigue aspects from the abuse of “Limbo Time.”
4) Finally, in order to
mitigate chronic fatigue, a Mandate that
allows a minimum of 48 hours of undisturbed rest in any 7 day period would afford railroad
workers the option of getting two full sleep cycles in order to relieve
accumulated sleep debt.
With these four mandates,
and the existing federal hours of service, the most difficult fatigue issues
experienced by railroad workers could be addressed in federal law. Again, these efforts would be dependent on a
favorable political environment in
Appendix A
A TOOLBOX OF FATIGUE COUNTERMEASURES
This toolbox is not designed
to be a “best practices” cookbook for safety improvements that will guarantee
elimination of railroad worker fatigue.
Rather, this toolbox is a collection of options for the railroads and
BLET leaders to draw from to address the serious fatigue issues on individual
properties or at specific locations. The
ideas developed below have been tried in either railroad operations or other
modes of transportation and have proven to be successful. However, success in other locations does not
guarantee success in the railroad industry at every location. Only evaluation and continuous improvement
will provide the successful resolution that engineers and trainmen in the
Education Aspects of Fatigue
·
Sleep hygiene
Educating individuals about developing good sleep habits or countermeasures to
employ when sleep habits are compromised
·
Sleep Disorders
Providing useful information about sleep illnesses and opportunities for
medical intervention.
·
Alertness Strategies Providing useful strategies that can mitigate fatigue for railroad
workers short of the need to not performing duty due to unsafe fatigue levels.
·
Focused Education Materials need to be focused for the target audiences of Senior
Management, Middle/Frontline Management, new-hires, and Engineers &
Trainmen generally.
Medical Aspects of Fatigue
·
Policy A statement developed
assuring non-punitive treatment for railroad workers suffering from a fatigue
related illness. On some roads this may
become a collectively bargained agreement.
·
List of
Doctors
Providing a list of specialists capable of addressing sleep disorders
particularly at outlying points on the railroad’s system.
Critical Aspects of Fatigue
·
Book Rest The ability to request 10-14
hours of rest at the completion of a tour of duty provides engineers and
trainmen an opportunity to overcome a critical fatigue situation.
·
Optional Rest Allowing the worker to absent themselves from duty
when they have not gotten the minimal amount of sleep necessary to safely
perform a duty shift.
·
Mandatory Rest
Some
railroads have negotiated extended undisturbed rest at the home terminal. For example, crews are guaranteed not to be
called before 10 hours off duty at the home terminal, but are called out on
their legal rest at the away from home terminal. This increases the quality sleep that many
individuals experience in their own beds and reduces the substandard sleep
experienced by some railroad workers at the away from home terminal.
·
Mandatory Rest Is there a maximum number
of hours that railroad workers can work?
Some railroads argue for a limit to the maximum hours worked, but the
research is not yet conclusive on this question.
·
Alertness Strategies Opportunity napping, employee empowerment, strategic use of caffeine,
three meals per day, short breaks during shifts, exercise during breaks, and
refraining from leaving tedious or boring tasks to the end of the shift have
been shown to be effective countermeasures for worker fatigue in some cases.
·
Undisturbed
Rest Provisions
that restrict the need for contacting or being contacted by the railroads
during legal rest periods serve to lesson the interference with sleep cycles.
·
Managing Rest
Periods
Both at the home and the away from home
terminal, plans that manage rest to maximize sleep opportunities are
preferred. For example, following events
such as “Dead Head” trips, working trips, vacations, and extended absences,
different practices can be invoked to minimize fatiguing schedule starts such
as AM mark-up policies.
·
Discretionary Time-off For Fatigue Occasionally, life’s circumstances such as a sick
baby can result in fatigue. Providing
opportunities to address these issues can mitigate unsafe levels of critical
fatigue.
·
Scheduling
Using schedules for train operations introduces predictability for railroad
workers.
·
Lineups &
Calling times Efforts to improve
lineups and calling practices can also contribute to predictability for
railroad workers.
·
Post Duty Upon
completion of duty, efforts to relieve crews immediately upon expiration of 12-Hours
for those crews expiring under the Hours of Service, crew hauling issues that
can result in delays, and expedited arrival policies at rest facilities can all
contribute to reducing critical fatigue.
·
Work Environment Occasionally, quiet rooms, air conditioned cabs, or improved seating
have helped to reduce critical fatigue.
·
Adequate Sleep In
all cases, efforts to increase the opportunity for getting sufficient sleep is
the goal of mitigation efforts. Some
research describes this as anchor sleep.
·
Work in Groups
Avoid single man operations of trains where practicable.
Chronic Aspects of Fatigue
·
Optional Rest Allowing the worker to absent themselves from duty
when they have not gotten the minimal amount of sleep necessary, or are suffering
a sleep debt, and can not safely perform a duty shift.
·
Mandatory Time-Off Historically, fatigue was addressed using mileage or hour agreements that
limited the number of days or hours in a month an engineer or trainmen could
work.
·
Optional Scheduled Rest Days Railroads have used 7&3, 8&3, 11&4,
10&5, or 4&2/3&1 work/rest cycles in order to provide an
opportunity to mitigate sleep debt resulting in chronic fatigue.
·
Shift Predictability Through scheduling or using lineups, efforts to
increase work predictability may contribute to reducing chronic fatigue.
·
Peer Intervention Program On the job fatigue poses a safety issue and an Operation Red Block – type program could
be used to elevate the importance of mitigating unsafe levels of fatigue
between peers in the railroad industry.
Evaluation
·
Continuous Improvement Review Process This incorporates an evaluation of pre-agreed
to measures of fatigue in an iterative process designed to narrow the large
issue of fatigue into ever smaller issues reaching an effective solution that
meets the needs of the entire group. The
process has been utilized in the railroad industry, as well as many other work
settings outside the railroad industry, to effectively reach an organization’s
goal. Essentially, the process establishes
goals and then measures the success of individuals, groups, and/or
organizations to reach those goals.
·
Physiological
Measures
Electro Encephalogram and Multiple Sleep Latency Tests have been described as
accurate and objective but impractical and expensive for use in the railroad
industry.(6)
·
Behavioral
Measures
The Actigraph has been described as accurate and objective but moderately
expensive.(6)
·
Self Reports The Stanford Sleepiness
scale, Individual Sleep Diaries, or other survey instruments designed to self
report levels of fatigue are fairly inexpensive but are arguably less accurate.
(6) Without a doubt, there is little
argument with an individual that says he/she is tired. There is no basis in science that can dispute
this individual’s assertion without an expensive medical test.
·
Performance
Measures
Performance Assessment Battery (PAB), Psychomotor Vigilance Test (PVT) and the
Denver Fatigue Inventory are indirect measures of fatigue using correlated
variables that require an expert to administer and score.(6)
Resources:
1)
National Sleep Foundation http://www.sleepfoundation.org/
2) National
Sleep Foundation http://www.drowsydriving.org/
3)
4) Associated Professional
Sleep Societies http://www.journalsleep.org/currenttoc.asp
5) American Insomnia Association
http://www.americaninsomniaassociation.org/home.asp
6) American Board of Sleep
Medicine http://www.absm.org/
7) Sleep Research Society http://www.sleepresearchsociety.org/site/
Bibliography:
1) Senge, P. (1990) The Fifth
Discipline. The art and practice of the
learning organization. Currency,
2) Dawson, D. (January, 2004)
Fatigue Risk Management Handout. Director Centre for
3) Dawson, D. (June, 2004) Simulating
fatigue management. Power point
presentation. Director Centre
for Sleep Research University of South
Australia
4) Dinges, D. (2004) Sleep debt
and scientific evidence. Editorial in
Sleep Vol. 27, No. 6.
5) McCallum, M, etal. (July,
2003) Commercial Transportation Operator Fatigue Management Reference. US Department of Transportation.
6) Sherry, P. (June, 2002)
Fatigue Countermeasures in the Railroad Industry: Past and Current Developments.
7) Insurance Journal (August,
2003) Maggies law underscoring importance of corporate fatigue management. Wells Publishing.