ORR revises fatigue guidance

23 January 2012

The Office of Rail Regulation (ORR) has published new guidance on good practice in managing fatigue within the rail industry.

The union has welcomed it, and its lead officers will raise its content with individual companies, specifically covering 
• the concept of Fatigue Risk Management Systems.
• setting up Fatigue Safety Action Groups with ASLEF reps
• health and safety reps collating information from staff fatigue surveys.

This rail industry-specific guidance builds on the more general guidance applicable to all industries. The ORR guidance advocates a proportionate approach to fatigue, with simple controls where risks are low, but a more comprehensive ‘fatigue risk management’ system (FRMS) approach where risks from fatigue are greater, to help reduce the risk of fatigue-based errors.

The full guidance can be seen at http://www.rail-reg.gov.uk/upload/pdf/managing_rail_fatigue.pdf

ASLEF welcomes the guidance as it contains some useful information and certain new ideas about managing fatigue. In summary:

  • 3.2 Section 4 provides guidance on basic fatigue controls applicable to all employment
  • 3.3 Section 5 covers ‘Fatigue Risk Management Systems’ relevant to rail employers with staff working shifts or significant overtime, including ‘safety critical’ work. It outlines the features of a fatigue risk management system.
  • 3.4 Section 6 replaces, updates and fleshes out ORR’s 2006 guidance on ‘Managing fatigue in safety critical work’. It retains the nine stage approach which many companies have adopted or revised. Companies with staff carrying out safety critical duties under ROGS should review their existing fatigue controls against the updated guidance.
  • 5.21 The report dwells on the usefulness of Fatigue Safety Action Groups that bring together managers and employee representatives. They can ensure that fatigue controls are sensibly prioritised and co-ordinated and help demonstrate the company’s commitment to involving staff. Some organisations may prefer to use an existing joint management / staff group with a wider safety improvement remit. They can involve Operations Managers, ASLEF reps, rostering staff, safety managers and Occupational Health services.
  • 8.7 Fatigue management systems should include arrangements for assessing and controlling risks from travel time - with an absolute ‘worse case scenario’ maximum of 14 hours between leaving home and returning.
  • 5.76 Staff fatigue surveys are a useful supplement to routine monitoring of fatigue both on a regular basis and where there have been reports of particular aspects of work patterns that tire staff. RSSB report T699 outlines a method for a comprehensive fatigue survey. Simply asking staff which turns or links cause problems is a good starting point in identifying problems. Less formal ways of gathering staff fatigue information are also useful.
  • 7.5 Staff should be consulted on proposed working patterns, and their views on fatigue risk aspects considered.
  • 7.7 The general three-part sequence can be summarised as follows, consulting with staff at appropriate stages:

· design the work pattern, maximising good fatigue management practices;

· assess likely fatigue risks from the resulting work pattern, using a fatigue assessment tool;

· ask staff whether the working pattern is in reality controlling fatigue, and any particular features which may need further improvement.

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