Hours of Service: Where we’ve been; where we need to be

Written by Evan Mitchell, Railroad Software
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Photo courtesy Railroad Software.

Work exhaustion and lack of effectiveness to properly carry out job functions to the highest standards put people at risk on a railroad. The Federal Railroad Administration (FRA) makes it a strong priority to know when employees are on the clock working on the movement or function of a train and when they are not. These regulations and time tracking fall into the Hours of Service (HOS) law. They must be met within FRA standards; railroads face fines and penalties if they aren’t met.

The history of HOS regulations is interesting and surprising as we take a look back on how we got to where we are today. The rules have been reconfigured over time as the industry has become more aware of best practices for employees.

The Secretary of Transportation is the chief administrator of HOS laws, which are actually enforced by the FRA. The laws have been changed over time. In 1907, the federal government first set in writing limitations on working significant continuous hours—16 at the time—on a railroad to promote better safety. But imagine working 16 hours straight on a train or assets involved in the overall movement of a train.

It took nearly 60 years to reduce the number of hours. The first amendment to the HOS law was enacted in 1969. It decreased the maximum number of hours of work from 16 to 14. In 1976, the law was amended further to reduce the maximum number of continuous hours to 12.

Yet, despite these improvements, FRA data shows that fatigue-related accidents still occur. Recently, several studies have been conducted to show the effects of working too long without proper rest. As such, keeping proper track of tours of duty is crucial to our industry as we promote safety first and foremost.

Research conducted by Hursh, Raslear, Kaye and Falzone in 2006 provided case studies on work exhaustion. The data summarized that between the hours of midnight and 3 a.m., human-factor-caused accidents increased by 20%. Furthermore, they discovered the relationship between job effectiveness and human-factor-caused accidents. As the percentage of effectiveness decreased, the percentage of accidents increased dramatically. An effectiveness score of 50 or below led to a 65% increase in accidents, which contributed to multi-million-dollar costs/losses.

With this data in mind, FRA is constantly checking employee time-tracking data. When an accident occurs, FRA will go straight to the compliance information to see if the accident was caused by human error related to HOS violations.

Taking this small sample of information from the recent past and comparing it with the law established in 1907, we can see how far we have come with HOS. Now, with railroads keeping track of their employees, we better-understand the need for educational information not found in research studies and lengthy government data.

The industry is changing, with new ideas, a new generation of employees, and new technologies. Understanding our industry’s foundations will propel us to improve on the past and grow together.

What You May Not Know about Signal Maintainer HOS Rules

Signal maintainers are responsible for the installation, maintenance and inspection of signals (including grade crossing warning devices) along a railroad. Signal maintainer HOS law requirements also date back to 1907, but their requirements are different from those of T&E (Train and Engine Service) employees, just as dispatchers have their own set of guidelines. Signal maintainer requirements are similar to those of T&E, but are simpler, with different consecutive-hour, rest time and consecutive days on duty limitations.

Signal maintainers can work a maximum of 12 hours covered or commingled within a 24-hour period. Covered time includes hands-on work on the installation, repair or maintenance of a signal. For example, when a maintainer works on a crossing, changing out the gate arm and replacing the flasher battery, it is covered by HOS.

Commingled service is not separated from covered service by the required time off per FRA regulations. An example of commingled service would be a signal maintainer starting the day with administrative duties in the home office but later in the day being called in to repair a particular signal in the field. Due to the covered service time, the non-covered time from the morning is counted toward the overall count of hours toward the 12-hour maximum.

For signal maintainers the required rest time prior to a new shift for covered service is 10 hours. During those 10 hours, a signal maintainer cannot be in contact with the railroad in a conversation relating to the safety of the signal as it relates to train movements, if the railroad initiated the conversation. As well, there are varying job functions where distinguishing between covered and non-covered service gets a bit tricky.

Keeping track of differences in covered vs. non-covered service can make a signal maintainer’s day more complicated if hours need to be manually tracked—for example, on a notepad—throughout the day, before being officially reported. Many employees complete their work and then at the end of the day base their reports on estimates of when they were in covered or non-covered service.

One of the benefits of modern technology advancements in the industry means that time spent with guesswork can be cut down immensely. There are applications that easily allow users to select their times in visual templates with defined work. This allows the user not only the ability to lose the paper wasted on timekeeping but also allows administrators in the office the ability to review time entries in real time and make better decisions when looking for employees to cover work when hours are high or low for certain individuals.

A Locomotive Engineer’s Day

T&E employees—locomotive engineers, conductors, hostlers, switchmen, trainmen, and switch tenders—have their own HOS regulations. At many places across the country, one individual can hold one or more of these positions. This makes keeping track of their covered and non-covered service very important.

From previous FRA-backed research into work exhaustion, we know the effect of long hours on the human body and mind. Safely moving trains and ensuring the safety of passengers or freight and crew calls for accountability, efficiency and general awareness. As supervisors and administrators may not have unlimited access into these employees’ workdays, it is entrusted to the employees to keep general notes on their day.

Similar to signal maintainers, T&E employees cannot exceed the 12-hour limit. An employee who works the full 12 hours must have 10 consecutive hours off duty. In addition, employees that work 12 hours consecutively, with some hours on an active train movement and some hours on administrative tasks, require 8 hours off duty within a 24-hour period before returning to work.

As railroads look to have better access to their employees’ workdays to improve safety and efficiency, many third-party contractors are developing time tracking software that enables supervisors to easily monitor and schedule employee HOS. In developing our own software, we’ve seen the types of problems short lines, switching and terminal and Class I’s encounter. Whether it may be falling asleep on the job, general slacking off, or not carrying an efficient pace throughout the shift to get the work done, with the help of modern innovations, companies have that visibility to greatly enhance their operations through efficiency. Why take 6 hours to do a job that can be done in 3?

The railroad industry is changing. Incoming workers in all disciplines are younger, and with that change in age, there is now a new movement toward more technology being integrated into rail operations. Instead of using many sheets of paper and bulky files, companies are looking toward innovative, user-friendly applications that make for more efficient business.

This is important for HOS laws and for those in covered service, especially T&E crews. Covered and non-covered service, limbo time, interim releases and off-duty hours can be all tracked more easily through these new tools, which are readily available to the industry. Investigate opportunities to improve your business now, not later when it becomes a pain point to switch.

Evan Mitchell is a Marketing and Sales Associate at Railroad Software. He is experienced in coordinating and implementing technology solutions within the rail industry. Evan’s experiences as a corporate trainer and customer service representative in leadership positions across different industries have granted him a balanced understanding of different core functions to businesses needs and operations. Evan worked as a writer for a regional magazine, which is where he first found success in publishing articles.

Based out of Cumming, Ga., Railroad Software has grown rapidly since beginning operations in 2013. Founded out of the desire to make software user friendly and affordable to the rail industry, Railroad Software currently manages several hundred thousand railcars through its RTMS product in addition to managing FRA compliance through its TrackAsset and TrackHOS products. For more information on Railroad Software and its Compliance Software for Hours of Service, TrackHOS, visit: https://www.railroadsoftware.com/railroad-hours-of-service-software/.

Categories: Class I, Commuter/Regional, Freight, High Performance, Intercity, Passenger, Regulatory, Safety, Short Lines & Regionals, Switching & Terminal Tags: ,