Human Factors R&D Program Office of Research and Development The Australian Approach to Fatigue Management: Context and Details Michael Coplen, M.A., Co-Chair,

Human Factors R&D Program Office of Research and Development The Australian Approach to Fatigue Management: Context and Details Michael Coplen, M.A., Co-Chair, HFCC Operator Fatigue Management Initiative Federal Railroad Administration Stephen Popkin, Ph.D. Co-Chair, HFCC Operator Fatigue Management Initiative Volpe Center April 22, 2003 Washington, DC

Human Factors R&D Program Office of Research and Development Overview Why Australia? Evaluation Questions Fatigue Context Factors in the Australian Railroad Industry Principles and Philosophy of the Australian Approach OH&S Framework Perceived benefits and current challenges Next Steps Human Factors R&D Program Office of Research and Development

Human Factors R&D Program Office of Research and Development Background: History of Sleep And Fatigue Research Pre-1930s Sleep seen as a subjective state 1930s EEG objective measures of sleep 1954 Discovery of REM Sleep 1960s Medical focus on sleep research 1970s Explosion of research on sleep, performance and fatigue 1983 Congressional Hearings on Biological Clocks and Shiftwork Scheduling Post 1984 Federal Investigations of fatigue accidents Wiggins, CO, 1984 Woodford, CA, 1994 Newcastle, WY, 1984 Keenbrook, CA, 1994 Hinton disaster, 1986 Sugar Valley, GA, 1990 Thompsontown, PA, 1988 NYC Subway, 1995 Corona, CA, 1990 Kingman, AZ, 2000 Harrisburg, OR, 1991 Clarkston, MI, 2001 Eggleston, VA, 1992 Wendover, UT, 2001 Norway, NE, 1994 Hallsville, TX, 2001 Haymond, TX, 1994

Human Factors R&D Program Office of Research and Development Background:History of Sleep and Fatigue Research (continued) 1988 Sleepiness, Circadian Dysrhythmia and Fatigue in Transportation Accidents journal article 1988 Catastrophes, Sleep and Public Policy journal article 1989 Senate Committee Report Transportation-related Sleep Research 1990 The Hinton Train Disaster journal article 1992 GAO report Engineer Work Shift Length and Schedule Variability 1993 GAO report Human Factor Accidents & Issues Affecting Engineer Work Schedules 1992 Transport Canada Fatigue Report on Rail Operator Fatigue 1998 Sherry Report on Current Status of Fatigue Countermeasures 2000 DOT Operator Fatigue Management Initiative

Human Factors R&D Program Office of Research and Development Why Australia? European approach Very prescriptive Low tolerance to business case when compared against perceived worker well-being Current US approach Prescriptive Improvements hampered by current HOS law, FELA issues, trust Low tolerance for changes without a business case AUS approach Non-prescriptive Regulator responsible for driving and enforcing the process, not solution

Human Factors R&D Program Office of Research and Development Why Australia? 4 th International Conference on Fatigue in Transportation, 2000 Emphasis on Non-prescriptive Approaches Similar Scientific/Regulatory Pressures RE fatigue Similar Industry Fatigue Working Groups US Work/Rest Task Force formed in 1992 Australian Rail Consortium formed in 1995 US NARAP formed in 1998 Fatigue Management Implementations in both US & AUS US pilot projects fading AUS pilot projects sustainable Difficulty in FRA assessing and addressing fatigue Labor and management feel a threat to their bottom line No reliable methodology to determine extent of problem or effectiveness of interventions

Human Factors R&D Program Office of Research and Development Why Australia? 2003 Meeting Schedule State Rail, Sydney, New South Wales (NSW) Pacific National Railway, Sydney Rail Tram and Bus Union (RTBU), Sydney NSW Department of Transport, Sydney Australian Rail Track Corp. (ARTC) Australian Railroad Group (ARG) University of South Australia 5 th Intl Conference on Fatigue in Transportation Australian Rail Consortium

Human Factors R&D Program Office of Research and Development Evaluation Questions Is the Australian approach successful? What are the principle contextual factors influencing the process? What are the principle components of the Australian model? How can AUS approach be applied to the US rail industry? What does this suggest for future directions of FMPs in the US transportation industry?

Human Factors R&D Program Office of Research and Development FMP Contextual Factors In the AUS Railroad Industry 1986 Occupational Health and Safety and Welfare Act (SA) 1991 Hillmer Report Privatization of RR industry 1993 Rail Safety Act (NSW) Revisited every 5 years 2002 Act require FMPs as condition of accreditation Consultative approach with all stakeholders 1994 EEO Act 1995 Australian Rail Consortium formed 2000 Beyond the Midnight Oil Report Commonwealth inquiry on fatigue in transportation 2002 NSW Rail Safety Act First state to adopt FMP as a regulation

Human Factors R&D Program Office of Research and Development FMP Contextual Factors In the AUS Railroad Industry No Federal Rail Regulatory Authority State Regulators only HOS All industrial agreements (labor/mgt.) NSW is only state with HOS regulation OH&S State by state laws Requires safety case plan for each company De facto Code of Practice developed for each company Duty of care for employer and employees Chain of responsibility between employee, employer, and consigner Federal OH&S apply only to Commonwealth employees EEO laws Precludes age discrimination Interpreted to include seniority

Human Factors R&D Program Office of Research and Development Principles and Philosophy of Australian Approach OH&S framework Management-based regulations and company policies Alternate compliance model Risk-based implementation Performance-based outcomes

Human Factors R&D Program Office of Research and Development OH&S Framework Legal duty of care, varies state by state Required by regulator to have a safety plan Established in OH&S legislation Fatigue identified as a workplace hazard to be controlled Medical pre-placement requirements General sensitivity towards general medical conditions and treatments that may affect fitness for duty Include sleep disorders Duty of care for managers and employees

Human Factors R&D Program Office of Research and Development Duty of Care Shared Responsibility Model Management responsibility Employer responsible for minimizing risk associated with work related fatigue Providing staff and shift system that permits sufficient opportunity to rest and recover Employee responsibility Employee responsible for minimizing risk associated with non- work related fatigue Using allocated time off to obtain sufficient sleep in order to work safely If not possible, employee must notify employer that they may have had insufficient sleep

Human Factors R&D Program Office of Research and Development Management-based Regulations Co-regulatory process, few regulations Broad policy level guidelines, not overly prescriptive Certified company Codes of practice driven by state regulations Role of regulator to drive process, not solution NSW audit capability can compel compliance to certified safety plans

Human Factors R&D Program Office of Research and Development Employee Responsibility for Sufficient Sleep The 5/12 Start Rule (based upon literature and collected data) Must obtain 5 hours sleep in 24 hours prior to work; and 12 hours sleep in 48 hours prior to work The Finish Rule The period of wake-up time to the end of the shift should not exceed the amount of sleep obtained during the past 48 hours prior to commencing the shift The Final Rule If either rule is broken, fatigue is a potential problem and the organization should engage in an auditable fatigue risk reduction process

Human Factors R&D Program Office of Research and Development Employee Responsibility for Sufficient Sleep If start and finish rule not met, then must notify line manager. Options include: Additional sleep time Alternate task Sick leave Performance management approach In event of fatigue-related incident, if employee fails to notify, then Employee assumes at least partial responsibility

Human Factors R&D Program Office of Research and Development Obtained Sleep Metric Sleep in prior 48 hours Sleep Work Wake-up End-of-shift Sleep in prior 24 hours AB Time Awake

Human Factors R&D Program Office of Research and Development Quantifying Sufficient Sleep Rules are evidence-based from engineers sleep studies Software-based fatigue model (fatigue estimation algorithm, FAID) Evidence based data from engineers Length and time-of-day of shifts and breaks 7 day prior work history Biological limits to rest and recovery Obtained sleep model Simple, objective, easy suited to employees and management Count sleep prior to commencing work Spreadsheet or paper-and-pencil versions available

Human Factors R&D Program Office of Research and Development Employer Responsibility for Minimizing Fatigue Fatigue Management Policy Defined responsibilities and actions for reasonably foreseeable situations Accountable executive Demonstrate appropriate methodology and compliance with S/F rules Competency-Based Training and Education Program For all staff responsible for decisions that impact on the targeted individuals opportunity to obtain sufficient sleep Public domain provision of hard copy available to all Web-based materials Audit capability Must have quantitative methodology for ensuring employees provided with opportunity to have obtained sufficient sleep to operate safely

Human Factors R&D Program Office of Research and Development Evaluation of AUS Approach: Perceived Benefits FMPs viewed as a profit center rather than a cost centerFMPs viewed as a profit center rather than a cost center Attraction and retention tool Marketing strategy, competitive advantage Sustainability and commitmentSustainability and commitment Unified direction with Australian Rail ConsortiumUnified direction with Australian Rail Consortium Regulatory standards being adopted from Codes of Practice and company policiesRegulatory standards being adopted from Codes of Practice and company policies

Human Factors R&D Program Office of Research and Development Evaluation of AUS Approach: Current Challenges No objective data establishing successNo objective data establishing success Some workers still prefer long work periods and long blocks of time offSome workers still prefer long work periods and long blocks of time off Labor seeks mandatory federal standards to establish floorLabor seeks mandatory federal standards to establish floor minimum guaranteed time off minimum shift length maximizing pay potential still an issue Regulatory process for FMPs moving too quickly for someRegulatory process for FMPs moving too quickly for some Consultative process for accrediting FMP excludes labor Improper applications of FMPImproper applications of FMP FAID applied as a rule, not a tool in new implementations Regulatory pressures for simple solutions Incomplete transfer to other work groups No buy-in process or tailored solutions for 2nd generation

Human Factors R&D Program Office of Research and Development Summary Rapidly evolving and continuously changing processRapidly evolving and continuously changing process Currently few regulations Highly flexible States learn from one anotherStates learn from one another Companies learn from one anotherCompanies learn from one another Trend toward national minimum standardsTrend toward national minimum standards Effective practices approach, informal

Human Factors R&D Program Office of Research and Development Conclusions Better objective evidence and documentation of fatigueBetter objective evidence and documentation of fatigue Monitoring and evaluation of program performance neededMonitoring and evaluation of program performance needed Australian contextual factors have fostered an environment suitable for flexible FMP solutions and implementationsAustralian contextual factors have fostered an environment suitable for flexible FMP solutions and implementations FMPs are sustainable due to the OH&S act, EEO interpretation, and the view that FM is a business benefit, not a cost itemFMPs are sustainable due to the OH&S act, EEO interpretation, and the view that FM is a business benefit, not a cost item Buy-in strategies are critical; must go through appropriate processBuy-in strategies are critical; must go through appropriate process Further exploration of value of the Australian approach neededFurther exploration of value of the Australian approach needed

Human Factors R&D Program Office of Research and Development Proposed Next Steps Determine who within the transportation enterprise is interested in this approach and participating in furthering its developing here in the USA Conduct In-depth Evaluation of Australian FMPs Evaluate outcomes and objective benefitsEvaluate outcomes and objective benefits Verbal agreement from AUS Rail Consortium for dataVerbal agreement from AUS Rail Consortium for data Availability of operational data (close call and leading indicator data)Availability of operational data (close call and leading indicator data) NSW accident dataNSW accident data Conduct Benchmarking, Lessons Learned and Effective Practices Studies Develop White Paper on Applicability of AUS Approach to US Rail Industry Develop Improved Fatigue Data Collection and Surveillance Systems Investigation protocols Record-keeping

Human Factors R&D Program Office of Research and Development Questions & Feedback

Documents

Human Factors R&D Program Office of Research and Development The Australian Approach to Fatigue Management: Context and Details Michael Coplen, M.A., Co-Chair,