Feeling sleepy? Are we taking fatigue management seriously enough?

Philip Hoare | 16 Mar 2015 | Comments

Delivering rail infrastructure projects places many demands on our industry. Pressures to deliver value for money in short timeframes with limited resources can result in our people working long hours over several consecutive nightshifts. When you factor in the many safety critical tasks staff must undertake to protect the travelling public and themselves, it’s clear that fatigue management is a crucial issue.

Following the Clapham disaster in 1988, Anthony Hidden QC handed down recommendations to limit excessive overtime. These so-called ‘Hidden rules’were introduced by British Rail and became more widely adopted. These limited the shift length to 12 hours and the maximum hours per week to 72. Given these were introduced over 25 years ago and are no longer part of a Railway Group Standard, it might be reasonable to assume that things have moved on considerably. But have they? Twelve hour night shifts are still common, and much of fatigue management is still based on these ‘Hidden’ values. So six consecutive nights of 12 hour shifts are not that unusual.

But let’s step back a bit. What do we actually mean by fatigue? Is it just about hours? What does UK legislation require of us – and what might good look like?

The Office for Rail Regulation guidance (Managing Rail Staff Fatigue, 2012) suggests fatigue is “a state of perceived weariness that can result from prolonged working, heavy workload, insufficient rest and inadequate sleep”. The implication is a reduced ability to perform work effectively. A fatigued person will be less alert, less able to process information, will take longer to react and make decisions, and will have less interest in working compared to a person who is not fatigued.

Causes of fatigue may be work-related (e.g. timing of working and resting periods, length and number of consecutive work duties, intensity of work demands), individual factors (e.g. lifestyle, age, diet, medical conditions, and any drug and alcohol use which can affect the duration and quality of sleep), and environmental factors (e.g. family circumstances and domestic responsibilities). It’s well-known that night time working poses particular fatigue-related challenges because it conflicts with the ‘body clock’.

Whilst the way we manage work is very important, people’s choices, such as staying in a hotel after a night shift rather than driving home, also have a very important impact on safety. Sometimes workers take the risk and drive home while fatigued despite the potentially fatal consequences. These are summed up very powerfully in a film called RED Day Sleeper on Network Rail’s Safety Central website. Inspired by real events, the film follows the story of an employee who is trying to balance working night shifts with the pressures of raising a young family. The consequences of the choices he makes prove fatal and life changing – watch it for yourself and I am sure that many of you will be able to relate to the issues and challenges it presents.

What this film and other experiences highlight is that we as an industry have a dual responsibility to both manage work patterns better but also to help our people make the right personal choices to encourage them to take responsibility for their own safety. At Atkins we run a behavioural safety programme called Safe by Choice where staff are empowered to take responsibility for their own safety. As part of this programme, we gave staff who drive company vehicles a card that says “Don’t risk it, don’t drive tired” and that also states “You already have approval to book a hotel”. Informal feedback suggests that this overt empowerment has been important in good decision making.

What does UK law require of us? The Health and Safety at Work Act 1974 states that employers should ensure “so far as is reasonably practicable, the health, safety and welfare at work of all his employees”. The Management of Health and Safety at Work Regulations 1999 require a “suitable and sufficient” written risk assessment with controls along with an effective system to manage risks. The Working Time Regulations 1998 (as amended) may also be relevant, though there are certain opt-out provisions. In terms of rail-specific requirements, the Railways and Other Guided Transport Systems (Safety) Regulations 2006 (ROGS) says workers should not carry out safety critical work when they are fatigued or are likely to become fatigued to the point that “health or safety…could be significantly affected.”

What this all means is that an approach that focuses only on hours and not explicitly on risks is unlikely to make a real difference or fully meet UK law. To address this, in 2011, Network Rail published standard NR/L2/ERG/003. This standard requires fatigue risk assessment and management for those involved in safety critical work with a focus on the planning of rosters and shifts. However, in my experience its implementation is partial at best amongst those delivering infrastructure projects. I believe that everyone working in the sector should implement a risk-based approach to fatigue that leads to better shift management, the reduction of associated risks and better management visibility of what is happening in practice.

Despite these concerns, I know that many people and organisations are looking hard at fatigue management but are we doing enough and should we be acting more consistently and with more pace? Are we as an industry really taking fatigue management seriously enough?

I believe it is time to apply risk assessment tools, like the HSE Fatigue and Risk Index, consistently and effectively across our sector. This will enable us to assess how we are really doing and then take the appropriate steps together as an industry to help minimise the impact of fatigue on our people and our projects.

An industry wide plan could be as simple as 1, 2, 3

  1. Develop a suitable benchmark for the fatigue index
  2. Produce a “ready reckoner” to make the application of a fatigue model easy to understand and implement
  3. Support this with guidance, training and advice to our people

Of course, the answers do not just lie in modelling so it’s vitally important that a communications and behavioural change programme underpins this work.

I know that many of you are also considering how best to improve in this area and it would be great to hear your thoughts – please contact me at or join in the discussion below.

I think that it is essential that we pull together as an industry and take a new and consistent approach to managing fatigue to enable and empower our people to make the right choices.

This article was originally published in the March edition of Rail Professional.