Feb 21, 2008

Hours of service issues on the railroads: part I

As I was looking for a reference on the Congressional website and found something that I think is worth posting. It's long so I'll break it into a few pieces. In 2002, Congress considered changes to the hours of service regulations governing railroads. Martin Moore-Ede, M.D., Ph. D., and CEO, Circadian Technologies, Inc. testified before the the U. S. House of Representatives Transportation & Infrastructure Committee Railroads Subcommittee. Here is what he said:

I am Dr. Martin Moore-Ede, CEO and President of Circadian Technologies, Inc., a research and consultancy firm which has extensive experience in developing and implementing fatigue management programs for railroads and other round-the-clock industries in the USA, Canada and internationally. Prior to founding Circadian Technologies, I was a Professor of Physiology at Harvard Medical School and led the initial research efforts to identify the biological systems that control human cycles of alertness and sleep.

Since founding Circadian Technologies in 1983, my colleagues and I have
published extensive scientific research on human fatigue in the 24/7 workplace.
In recent years, we have applied this research in close collaboration with
several major railroads including Amtrak, BNSF, Union Pacific, CSX, Conrail,
Canadian National, and Canadian Pacific as well as the unions that represent
their employees, including the Brotherhood of Locomotive Engineers and the
United Transportation Union. Together we have developed, implemented and
scientifically evaluated a wide variety of fatigue countermeasure strategies,
including the scheduling of regular predictable call schedules for irregular
unscheduled train service.

Today I will focus on the evolution of practical and effective alternatives to Hours of Service Laws for addressing the issue of fatigue. While I fully endorse the intended goal -- namely fatigue risk reduction -- of Mr. Oberstar’s Railroad Safety Reform Act of 2002, I unfortunately cannot agree with its substance.

As I will discuss, there is abundant evidence that current Hours of Service laws, or the proposed modifications, offer little hope for preventing fatigue, and furthermore they risk unduly restricting the business operations of the railroads and negatively impacting the lives of rail employees. In contrast, I believe there is much more promise in a Risk-Informed Performance-Based Fatigue Management approach as a creative and effective tool for addressing this vital safety and security issue.

I wish to propose that this Sub-Committee consider lending its full support and endorsement to a process which requires every railroad and their unions to jointly work towards developing, implementing and filing Fatigue Management Plans with the Federal Railroad Administration.
These should demonstrate that each American rail operator is reducing fatigue risk through a process which is “Risk Informed” and “Performance Based.”

By “Risk Informed,” I refer to the continuous objective assessment of fatigue risk across all operations; by “Performance-Based,” I mean holding management and employees personally accountable for achieving measurable fatigue risk reduction.

In my testimony today, I will address the following specific questions:

1. Does sleep deprivation and fatigue significantly impair railroad employee alertness and vigilance in our railroads?
2. Does this loss of vigilance pose a safety threat?
3. Has the risk improved or worsened since 1998?
4. What is the most effective way of reducing the risk?

  • Revision to the Hours of Service laws?
  • Train control technology?
  • Alertness monitoring technology?
  • Risk-Informed Performance-Based Fatigue Management?

5. What comparable models should we examine?
6. How should we proceed?

[Editor's Note: We'll be posting the text of this testimony in subsequent posts.]

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