Risk Reduction/Fatigue Management: What’s the holdup?

Written by William C. Keppen, Jr.
image description

The NTSB determined that crew fatigue brought on by irregular work schedules and sleep apnea was the primary reason behind this middle-of-the-night head-on collision that killed two and injured two others in Arkansas in 2014.

A recent internal Transport Canada (TC) document warns of the safety risks posed by exhausted crew members on trains, even as Alberta pursues a plan to ratchet up already-booming shipments of crude by rail.

Canadian work rules, dating from 2002, “are not effective in preventing fatigue due to work schedules and do not adequately mitigate the risks of fatigue,” says the memo. “… fatigue is managed by a patchwork of approaches, most of which are outside TC’s control.”

Many of those oil trains are now, or soon will be, traversing U.S. railroads, where train crews have the same problems as their Canadian counterparts.

Having often chided rail industry stakeholders for failing to effectively address safety risks associated with medical fitness-for-duty issues, I have been reminded from time to time by rail union officers and working locomotive engineers and conductors that there are many other issues and conditions that cause and/or contribute to train crew fatigue. The most obvious are: 1) Long and irregular work schedules. 2) Being subject to calls to report for duty 24/7. 3) Inaccurate train and crew lineups. 4) Inadequate away-from-home lodging facilities. 5) Threats of disciplinary actions for laying off when called unexpectedly to report for duty.

The 2008 Rail Safety Improvement Act (RSIA) finally recognized the fact that Hours-of-Service (HOS) is not the end-all solution to train crew fatigue. It directed railroad management, in consultation with rail labor representatives, to submit Fatigue Management Plans to the Federal Railroad Administration (FRA) for approval by October 16, 2012. Those plans were required to include: A) Education and training on human factors that affect fatigue. B) Identification and treatment of medical conditions, including sleep disorders, that may cause fatigue. C) Emergency response situation management to address fatigue risks. D) Employee scheduling and on-duty call practices. E) Methods for minimizing the effects of circadian rhythms on work schedules. F) Alertness strategies, such as napping policies. G) Rest facility issues that impact the ability of train crews to obtain restful sleep. H) An increase in the number of off-duty hours where employees are protected from communications by railroad representatives. I) Avoidance of abrupt changes in rest cycles for employees.

The FRA is charged with the responsibility for enforcement of the terms and conditions of the RSIA and for imposing civil penalties when railroads fail to meet the terms and deadlines spelled out in the regulation. Railroads have failed to meet the stipulated deadlines for implementation, and FRA continues to find reasons for extending deadlines.

Unlike PTC, there are no technological or interoperability problems associated with Risk Reduction/Fatigue Management Plans, items A – I above. So, how is it that most, if not all, of the issues that cause or contribute to train crew fatigue have yet to be addressed by the nation’s railroads? What is FRA, the industry regulator, doing to see that railroads meet the mandates of the 2008 RSIA? Can FRA produce one single Risk Reduction/Fatigue Management Plan that has been submitted to it by a Class I railroad for approval? Has it leveled any civil penalties against railroads for failing to meet requirements and deadlines? If not, why not?

So many unanswered questions. So much at risk.

MEMO TO: Those who live near railroad tracks and to the FRA:

When railroads fail to effectively address workplace issues and factors that cause train crew fatigue, the public, not just train crews, are put at great risk of train collision and derailments. Transport Canada determined that train crew fatigue was a contributing factor to the tragic oil train derailment that claimed 47 lives in Lac-Magantic, Quebec, Canada in 2013. The National Transportation Safety Board has come to the same conclusions on a number of train collisions and derailments in the U.S. FRA has the responsibility and the tools to enforce the 2008 RSIA. It is long past the deadline for it to do so.

Absent decisive action by FRA, train crew fatigue will claim more lives, believe me.

POINT OF ORDER: This is not a “new” regulation, unless FRA chooses to make it one. If it did, it would be time for Congress to step in and demand that the Department of Transportation/FRA take the necessary steps to protect public safety with immediate measures to address train crew fatigue, as spelled out in the RSIA.

William C. Keppen Jr., a retired BLET (Brotherhood of Locomotive Engineers and Trainmen) Vice President and third-generation locomotive engineer at BNSF and predecessors Chicago, Burlington & Quincy and Burlington Northern, is an independent transportation advocate with experience in fatigue countermeasures programs. A railroad industry veteran of almost 50 years, Keppen provides safety analyses for Confidential Close Call Reporting System (C3RS) programs in freight, commuter, and light rail transportation. Keppen was Project Coordinator for BNSF’s Fatigue Countermeasures Program, and former BLE General Chairman for the BN Northlines GCA. “I started working on human-factor-caused train accidents in 1980,” he says. “It has been a struggle. I would like to think I have made a difference, but there are still far to many human-factor-caused train ‘accidents,’ which I prefer to refer to as ‘preventable incidents.’”


Tags: , , , ,