National Shiftwork Information Center: railroad

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Apr 20, 2008

Railroad engineer files suit over work-induced circadian rhythm disorder

Steve Rennels, a former Norfolk-Southern engineer, has sued his employer claiming the irregular work shifts he was required to work caused a disruption to his circadian rhythms, negatively affecting his health and quality of life.

There's a brief article about this in The Madison St. Clair Record (Madision, Wisconsin, USA) -- Railroad engineer claims sleep disorder in $50K suit.

Feb 21, 2008

Hours of service issues on the railroads: part X, how to proceed

[Our series on Dr. Martin Moore-Ede's testimony before Congress continues]

6. How should we proceed?

There is now an opportunity to make substantial gains in transportation safety, but the achievement of this will not be without its challenges. 175 years of railroading tradition, and a complex thicket of regulations and collective bargaining agreements can sometimes make progress forward difficult. However, I know all parties view fatigue reduction and rail safety as important, so there is support for the overall goal.

This Subcommittee can do much to stimulate and motivate this process. I would propose that the House Railroad Subcommittee encourage railroad companies, and the railroad labor unions, to make the development of a formal process for Risk-Informed Performance–Based Fatigue Management a priority. An overall strategy should be developed that is sensitive to all stakeholders that could form a framework for future reform of rail safety legislation. A timetable for reporting back progress to this subcommittee might be helpful in ensuring that addressing this key railroad safety issue is maintained as a priority.

In summary, I have today discussed how sleep deprivation and fatigue significantly impairs train crew alertness and vigilance in our railroads, and that this loss of vigilance poses a safety and security threat. Moreover, FRA safety statistics suggest that this risk has worsened since 1998. However, making the Hours of Service regulations more restrictive is clearly not the best answer to fixing the problem.

While train control and new alertness monitoring technologies hold promise as future complements to existing capabilities, they are not yet ready for deployment and are likely many dollars and years away from providing practical utility. Faced with today’s challenges, a Risk-Informed Performance-Based Fatigue Management approach is best positioned to provide immediate benefits in a timely and efficient manner. I appreciate the opportunity today to share my thoughts and suggestions with this Sub-Committee, and I would be delighted to answer any questions.

Source: http://www.house.gov/transportation/rail/06-06-02/mooreede.html

Hours of service issues on the railroads: part IX, parallel models

[Our series on Dr. Martin Moore-Ede's testimony before Congress continues]

5. What parallel models should we examine?

I have recently had the opportunity to work with the Rail Association of Canada (RAC) and a group comprised of the Canadian Railroads, the Brotherhood of Locomotive Engineers (BLE) and the United Transportation Union (UTU), which have developed and proposed to Transport Canada an innovative alternative to restrictive Work-Rest rules (i.e. the equivalent to the US Hours of Service).

In return for preserving more liberal outer limits on hours of work and rest than in the USA, the RAC committee has submitted a plan for ministerial approval which mandates that every railroad prepare - working in consultation with their unions - a Fatigue Management Plan. I participated in the public hearings where the proposed work-rest rules were presented and defended. Important to their credibility was the promise that the Fatigue Management Plan was not a document to be put on a shelf, but instead a living active process for ongoing fatigue management. It is anticipated that this new rule will be approved by Transport Canada by June 16, 2002.

In addition railroads operating in Canada can apply for waivers that extend beyond the outer work-rest limits to meet operational flexibility requirements, provided they prepare additional special fatigue management plans for those special circumstances.

My colleagues and I have had direct experience in how effective Risk-Informed Performance–Based Fatigue Management processes can be. In the trucking industry both in Australia and in the United States, we have seen truck accident rates and severity cut by more than 50% when systematic fatigue management following these principals has been implemented.

Source: http://www.house.gov/transportation/rail/06-06-02/mooreede.html

Related Posts:
* Hours of service issues on the railroads: part I
* Hours of service issues on the railroads: part II, sleep deprivation and alertness
* Hours of service issues on the railroads: part III, safety threat?
* Hours of service issues on the railroads: part IV, increasing risk?
* Hours of service issues on the railroads: part V, hours of service rules
* Hours of service issues on the railroads: part VI, train control technology
* Hours of service issues on the railroads: part VII, alertness monitoring technology
* Hours of service issues on the railroads: part VIII, risk-informed fatigue management
* Hours of service issues on the railroads: part X, how to proceed

Hours of service issues on the railroads: part VIII, risk-informed fatigue management

[Our series on Dr. Martin Moore-Ede's testimony before Congress continues]

4. What is the most effective way of reducing fatigue risk? (continued)

Risk-Informed Performance-Based Fatigue Management?
The method of choice to immediately and effectively address the issue of railroad employee fatigue, which I propose that this committee actively encourage and endorse, is a process of Risk-Informed Performance-Based Fatigue Management.

Significant advances have been made in the development and validation of effective fatigue countermeasures in railroad operations in the past 10 years. Railroads, more than any other transportation mode, have expended considerable resources to advance the science of fatigue management. These include the development of training programs, work-rest scheduling systems and crew scheduling software, napping policies and sleep disorder screening programs, each of which in scientific studies has been shown to reduce fatigue.

However, the full benefits from this fatigue research have not yet been obtained because the application of these fatigue countermeasures across the railroad industry has to date been limited and inconsistent. Furthermore adequate measures have not been implemented for documenting results and effectiveness on an ongoing basis, or for holding managers accountable.

What has been missing is a disciplined approach which includes the following essential elements:

1. Development of Fatigue Management Plans
Every railroad operating in the US should develop with their unions a detailed Fatigue Management Plan and file this with the Federal Railroad Administration. This plan should address the objective quantitative assessment of fatigue risk across all of its different operations, the development and implementation of specific tailored countermeasures in each type of operation to minimize fatigue risk, and a process by which managers, supervisors and employees will be held accountable for measurable reduction in fatigue risk.

2. Risk-Informed Process
The plan must be risk-informed. Systematic data collection and risk modeling tools should be introduced so that the risk of fatigue can be calculated for each type of operation. Trends in fatigue risk should be tracked and reported, so that managers, supervisors, crew callers and employees can get the necessary feedback on what actions are effective and what are not.

It is essential to determine the extent, location and root causes of the risk, so that company resources can be focused most effectively. It may also be helpful to benchmark the company against others in the same industry so that management can weigh their progress in fatigue risk management against other comparable railroads.

3. Performance-Based Accountability
Managing by performance-based measures is a well established method of obtaining tangible results in a business. The key is determining the right performance measure. The most obvious measure might be thought to be the accident rate, but accidents are infrequent events and do not provide a measure of the risk of every employee on a month-to-month ongoing basis.
Furthermore, implementing management incentives based on reduction in accident or injury rates leads to an under-reporting of accidents, in part because this encourages managers to devise incentives for employees not to report events or injuries. We have seen managers make all employees who suffer accidents or injuries subject to disciplinary measures because they “were obviously not following required safety procedures.” This is a very effective way of reducing reported injuries! In contrast, using measures of fatigue risk gives managers incentives to address the root causes of operator fatigue, and therefore of fatigue-related accidents.

Source: http://www.house.gov/transportation/rail/06-06-02/mooreede.html

Related Posts:
* Hours of service issues on the railroads: part I
* Hours of service issues on the railroads: part II, sleep deprivation and alertness * Hours of service issues on the railroads: part III, safety threat?
* Hours of service issues on the railroads: part IV, increasing risk?
* Hours of service issues on the railroads: part V, hours of service rules
* Hours of service issues on the railroads: part VI, train control technology
* Hours of service issues on the railroads: part VII, alertness monitoring technology
* Hours of service issues on the railroads: part IX, parallel models
* Hours of service issues on the railroads: part X, how to proceed

Hours of service issues on the railroads: part VII, alertness monitoring technology

[Our series on Dr. Martin Moore-Ede's testimony before Congress continues]

4. What is the most effective way of reducing fatigue risk? (continued)

Alertness monitoring technology?
The railroads were the first transportation mode to introduce alerter devices into the cab which signal and alert an unresponsive operator. This is undoubtedly an important safety tool, but unfortunately not a sufficient one. It is now well established that a sleepy operator can tap the reset button automatically without being alerted into a vigilant state.

Another generation of alertness monitors which directly detects operator drowsiness is under development, but this technology is not yet sufficiently advanced or reliable to be implemented in the short-term.

Source: http://www.house.gov/transportation/rail/06-06-02/mooreede.html

Hours of service issues on the railroads: part VI, train control technology

[Our series on Dr. Martin Moore-Ede's testimony before Congress continues]

4. What is the most effective way of reducing fatigue risk? (continued)

Train control technology?
There is progress being made in train control technology, which keeps trains automatically monitored and separated, but we are a long way and billions of dollars from implementing this across the entire US railroad system. Such technology holds great promise in preventing certain types of collisions, but it is not a satisfactory substitute for fatigue management.

The ultimate safeguard is an alert operator who can detect and respond to unforeseen events. From the aviation industry we know that as systems are put on “autopilot,” it is human nature to rely excessively on such systems, and vigilance can therefore become impaired. As a result, when emergencies do arise, pilots can be unprepared and de-skilled due to fatigue and inattention.

Source: http://www.house.gov/transportation/rail/06-06-02/mooreede.html

Hours of service issues on the railroads: part V, hours of service rules

[Our series on Dr. Martin Moore-Ede's testimony before Congress continues]

4. What is the most effective way of reducing fatigue risk?

Revision to Hours of Service Laws?
Experience has taught us that excessive fatigue risk is manageable and preventable, but not by the traditional regulatory Hours of Service (HoS) approach. The issue of employee fatigue in transportation operations led in the early 1900’s to the development of the HoS concept, which used a rudimentary “hour-glass” model of human fatigue: namely that after a certain number of consecutive hours on duty, or cumulative hours in a week, a person becomes fatigued.

Over the past 30 years the science of human fatigue (sleep-wake, alertness & circadian physiology) has moved ahead rapidly, but regulatory reform has lagged behind. It is now broadly accepted that, while HoS can prevent some extreme abuses, under this “hour-glass” fatigue model of current HoS, an employee can be perfectly legal but unsafe, or illegal and perfectly safe. It is not enough to point to HoS compliance and claim that fatigue has been successfully managed.

First, HoS regulations fail to consider the well-established fact that nighttime work poses a higher risk than daytime work. Many studies have shown that the most consistent factor influencing operator alertness is time of day. Similarly, daytime sleep is not as restful as nighttime sleep so the efficiency with which off-duty time can be used for rest varies with the time of day.

Second, the total number of consecutive hours of work, or total accumulated hours of work in a week do not have a simple relationship with fatigue risk, except in extreme circumstances. For example while a person who works more than 60 hours a week may in certain circumstances become sleepy and risk falling asleep at the controls, at other times of the same day he would have very little likelihood of falling asleep.

Similarly a person only working 10 or 20 hours a week, depending on what time of day he is at the controls, may be just as much as risk for fatigue as the person who worked more than 60 hours a week. Indeed one of the most common scenarios for fatigue-related accidents is the first few hours on night duty after a vacation or weekend off-duty, which should be a time of lowest risk according to the hour-glass HoS fatigue model. Yet, this time of enhanced risk is clearly predicted by fatigue risk models based on current science.

Third, the HoS does little to address the problem of unpredictable work. The flow of freight trains across a railroad system fluctuates from hour to hour, because of weather, mechanical failures, and track damage or repairs. Duty rest schedules are therefore hard to predict on a day-to-day basis, especially when labor agreements also allow other crewmembers to book off-duty, and hence accelerate the sequence of call to duty. The quality of sleep is significantly reduced during on-call situations where there is anticipation that sleep may be disrupted.

Finally, HoS regulations typically encourage operators to adopt work/rest schedules that are shorter than 24 hours. For train crews, for example, the most “productive” work/rest schedule is a duty–rest cycle consisting of successive periods of 11 ¾ hours running a train followed by the minimal 8 hours rest period, resulting in 20-hour work-rest cycles.

This results in disruption of circadian rhythms, encourages employees to work when they are tired, and often obliges them to rest when they are not. Moreover, the direction of the rotation will be “backwards” since the cycle is shorter than the natural 24-hour day. There is extensive scientific data demonstrating that backward rotations are more fatiguing than forward rotations.
Building more complex prescriptive HoS regulations that take these physiological safety factors into account is not the answer. The regulations would have to be so complex as to be unmanageable due to the multiple factors that must be taken into account. It would severely impact the competitiveness and business operations of the railroad industry and potentially negatively influence the lives and earnings of the unionized crafts. The failed attempt of the FMCSA in 2000 to revise HoS regulations for the trucking industry to incorporate physiological principles shows the pitfalls with this approach.

Source: http://www.house.gov/transportation/rail/06-06-02/mooreede.html

Hours of service issues on the railroads: part IV, increasing risk?

[Our series on Dr. Martin Moore-Ede's testimony before Congress continues]

3. Has the risk improved or worsened since 1998?
When I last testified here in 1998, it was at a time when considerable progress had been made in developing awareness of fatigue as a key safety issue in the industry. We also had a steady rate of progress in key overall safety statistics such as the rate of FRA-reportable rail accidents per million train miles (excluding highway-rail crossing accidents which have a very different causation). The FRA reportable rate had progressively dropped each year from 4.25/million miles in 1993 to 3.54 in 1997.

Unfortunately, the trend has reversed since then. An examination of the published safety statistics of the Federal Railroad Administration shows the FRA reportable accident rate has steadily increased each year since 1998, and reached a level of 4.17/million miles in 2001. Obviously not all these accidents are caused by human error. Mechanical and environmental events, and hazards from trespassing & vandalism are also part of the mix.

However, when we isolate out railroad collisions caused by human error, we see a similar trend of increasing accidents. The accident rate per million miles of human error collisions progressively fell from 0.30 in 1994 to 0.18 in 1998. Since 1998 the trend has reversed, and it has again risen to 0.27 in 2000 and 0.24 in 2001.

The number of injuries and fatalities in human error-caused train collisions fell to an all time low of 30 in 1998, but rose back up to 136 in 2001. The cost of human error collision train accidents (equipment & track damage only – excluding third party liability, and environmental clean up) had progressively fallen to $12 million per year by 1997, but climbed back up to $37 million per year in 2001.

With numerous studies suggesting that over 50% of human error transportation accidents are fatigue-related, this increase in human error train collisions in recent years is a significant issue of concern, and indicates that addressing fatigue in rail operations must be high on the industry’s agenda.

The level of risk has also increased from another perspective. We are now in the post 9-11 era, where the potential loss of vigilance and situational awareness in fatigued railroad employees has also become a critical national security issue. Because they are responsible for the secure transportation of sometimes hazardous cargoes across our nation, the vigilance of railroad employees has now become doubly important.

We must ensure that the railroad personnel transporting freight or passengers are not impaired in their capacity for continuous vigilance because of excessive fatigue.

Source: http://www.house.gov/transportation/rail/06-06-02/mooreede.html

Hours of service issues on the railroads: part III, safety threat?

[Our series on Dr. Martin Moore-Ede's testimony before Congress continues]

2. Does this loss of vigilance pose a safety threat?
Anticipation, judgment, attention and cognition are all impaired by fatigue. A trained and experienced railroad engineer lapses back to the performance level of a novice when overwhelmed by fatigue, and will fail to anticipate the gradients of a track or the aspect of a signal.

Furthermore, anybody who has ridden through the night or the early-hours of the morning in the cab of a train, as I have, will attest to the battle one must sometimes fight against the waves of sleepiness that impede the safe performance of the often monotonous task of operating a train. These microsleeps in fatigued operators are found in every mode of transportation. In fact my career has given me the opportunity to find myself inadvertently nodding off alongside the operators of every mode of transportation!

We and others have conducted extensive scientific documentation of this phenomenon by wiring up train engineers and conductors with EEG recording devices that measure sleep brain waves. In a study of 500 engineer trips, we found that the average railroad engineer has 4 seconds per hour of operating the train where his eyes are shut in a microsleep (a brief lapse into sleep in the midst of wakeful activity). Among the most sleep deprived engineers, this can reach as high as 100 seconds per hour. It only takes a few seconds of microsleep to miss a stop signal, and indeed examples of this have been captured on tape.

Train collisions where the crew run a train through not only the warning signals but the stop signal and collide with another train, are most commonly the result of such microsleeps. A tell tale sign is that the rate of these accidents peak during the nocturnal and into the morning hours (1AM - 9 AM) at the end of an overnight shift, just the time when we know that human alertness most often fails. The recent (April 23, 2002 ) collision in Riverside, California between a Metrolink passenger train and a BNSF freight train that passed through a red signal at 8:18AM, killing 2 and injuring 265 commuters is just one of the many examples where it would be appropriate to explore the occurrence of a fatigue-induced microsleep event as a potential explanation.

Source: http://www.house.gov/transportation/rail/06-06-02/mooreede.html

Hours of service issues on the railroads: part II, sleep deprivation and alertness

[Our series on Dr. Martin Moore-Ede's testimony before Congress continues]

1. Does sleep deprivation and fatigue significantly impair railroad employee alertness and vigilance in our railroads?
Much has been written in the scientific and industry literature, and already reported to this Subcommittee, on the prevalence of fatigue, or more precisely loss of attention and vigilance due to sleep deprivation in railroad employees. Like other transportation modes which operate 24/7 (twenty-four hours a day - 7 days a week), the railroads by their nature have to work continuously around the clock to perform their vital mission in our economy.

From the dispatchers to the yard workers, from the track repair crews and signalmen to the train crews, work and rest is driven by the incessant 24/7 demands of the business. This means work intrudes into the natural nocturnal hours of sleep, when staying alert is more challenging, and off-duty rest must be obtained during the daytime hours, when good quality sleep is more difficult to obtain.

Scientific research and industry experience both confirm that, because of our inherent human biology, sleep deprivation and fatigue is a significant issue for many railroad employees.

Train crews face special challenges. Even when trains are scheduled, as in the passenger railroads, the work patterns can lead to sleep disruption and fatigue. Train crews in most freight railroads work on-call, non-scheduled shifts.

The flow of trains across the system is impacted by weather, mechanical failure, track conditions and the schedules of shippers and receivers of freight, so that most train crews do not know precisely when they will be called to work. Thus not only do they work on irregular 24/7 schedules but many of them also have unpredictable hours of work and rest, making it difficult for employees to plan their sleep. You can, for example, be up all day at home and then get called with 2 hours notice at 11PM, just as you are climbing into bed, to operate a freight train for up to 12 hours throughout the night and into the next afternoon.

Source: http://www.house.gov/transportation/rail/06-06-02/mooreede.html

* Hours of service issues on the railroads: part III, safety threat?

* Hours of service issues on the railroads: part IV, increasing risk?

* Hours of service issues on the railroads: part V, hours of service rules

* Hours of service issues on the railroads: part VI, train control technology

* Hours of service issues on the railroads: part VII, alertness monitoring technology

* Hours of service issues on the railroads: part VIII, risk-informed fatigue management

* Hours of service issues on the railroads: part IX, parallel models

* Hours of service issues on the railroads: part X, how to proceed

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?