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January 24, 2012

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Exhausting the issue for rail employees

The Office of Rail Regulation (ORR) has issued revised guidance for rail companies about managing fatigue among staff.

The ORR points out that some organisations appear to view fatigue as being relevant only to staff carrying out ‘safety-critical work’, as defined in the Railways and Other Guided Transport Systems (Safety) Regulations 2006 (ROGS). In reality, however, there is a much wider group of workers who fall outside the strict ROGS definition but, nevertheless, could be subject to significant fatigue risk from their work.

In addition, the Rail Accident Investigation Branch (RAIB) estimates that between March 2000 and November 2010, fatigue was a factor in 111 rail-industry accidents and incidents for which shift information was available.

Since the publication in 2006 of its original guidance, ‘Managing fatigue in safety-critical work’, the ORR has received suggestions on how its content and usefulness could be enhanced, and the regulator’s experience in applying the guidance has identified areas where improvements could be made.

For staff carrying out ROGS safety-critical work, the nine-stage approach adopted in the 2006 guidance is retained in the updated publication. A small number of additional guidelines have been added, reflecting recent research. For instance, there is now a recommendation that fatigue controls are reviewed when weekly hours exceed 55, rather than the current figure of 72 hours.

Significantly, the new guidance makes explicit that risks from fatigue are not confined to ROGS safety-critical work, and provides practical guidance on the elements of an over-arching system for managing fatigue for all rail employers whose staff may be exposed to, or create, significant fatigue risk. 

The guidance also makes the link between existing legal requirements and the POPMAR risk-management cycle, outlined in the HSE’s guidance, ‘Successful health and safety management’. The ORR document provides suggestions on reducing risks from fatigue under the POPMAR headings of policy; organisational arrangements; planning and implementation; monitoring; audit; and review. Also included is a checklist, which provides a possible structure to help employers assess the adequacy of their existing fatigue controls.

The updated guidance, ‘Managing rail staff fatigue’, is available to download at

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