Fatigue management of maintenance employees

[Operator] has a Fatigue Risk Management System (FRMS) as part of our overarching Safety Management System (SMS). The [operator] FRMS complies with the requirements of the Rail Safety National Law and Regulations and the Work Health and Safety Act and Regulation.

The [operator] fatigue risk management (FRM) documentation and system consists of the following five-tier hierarchy:

1. Overarching FRM Policy;
2. A System Procedure ([document number] Health Management);
3. Two Operating Procedures ([document number] Manage Fatigue Risks and [document number] Managing Shift Work and Rostering);
4. A Fatigue Risk Profile tool (document number); and a Fatigue Risk Management Plan (document number);
5. Training and awareness activities.

The [operator] FRMS Managing Shift Work and Rostering Operating Procedure explains how Line Managers and workers responsible for rostering and scheduling manage shift work arrangements and apply a risk management approach by using rostering principles to reduce the risk of fatigue. Within the Shift Work and Rostering Operating Procedure it states that: "By applying the rostering principles in Table 2, which provide guidance on working hours arrangements, Line Managers can reduce the risk of fatigue of workers. Where there is departure from the rostering principles owing to operational requirements, Line Managers must demonstrate that they have implemented control measures as part of a risk management approach, including consulting with affected workers.

Line Managers are responsible for the following procedure when rostering workers engaged in shift work and extended hours arrangements.

1. Develop rosters consistent with the rostering principles in Table 2 Rostering principles.
2. Apply FAID® tolerability limits to rosters in conjunction with the rostering principles. FAID® is a computerised tool that calculates the predicted fatigue associated with roster patterns. FAID® is only able to take account of hours of work, time of day that work is undertaken and breaks within and between shifts. It does not, and cannot, take account of other work and non-work causes of fatigue. Do not use FAID® alone to reduce the risk of fatigue. (bold added)
3. Take appropriate action to reduce the risk of fatigue when roster changes are made (e.g. when covering unplanned absences or the need to work extra hours as a result of unforeseen circumstances).
4. Implement and document control measures, where FAID® is used, to manage the risk of fatigue from rosters with elevated FAID® scores that exceed tolerability limits.

[Operator] currently uses FAID as part of the Fatigue Risk Management System (FRMS) to support the development of master rosters across the business and also to help manage day to day roster changes in some business areas. In both instances the use of FAID is integrated into two rostering systems and the use of the bio-mathematical algorithm supports rostering along with business rules that are built into each of the rostering system.

"The reporter has also expressed a concern that the [operator] users of FAID for rostering do not have training/understanding of what FAID scores mean and why they may or may not accurately represent an individual's fatigue".

SMS procedures (document number) Manage Fatigue Risks and (document number) Managing Shift Work and Rostering, identify the training required to ensure the level of knowledge and competency for all employees to carry out their mutual responsibilities to manage fatigue risk.

"The reporter has also expressed a concern regarding the manner in which rosters are manipulated to create "acceptable" FAID scores. The reporter stated that the FAID model does not appear to represent inevitable overtime and real world fatigue, which was highlighted in July 2010 by the Independent Transport Safety Regulator, who released a transport safety alert which specifically addressed the use of bio-mathematical models in assessing an employee's fatigue levels". "The reporter advised that there is an inconsistency between different departments of the organisation in which the way FAID is used and what level of scores are being accepted for rostering purposes". "The reporter believes the approach being utilised by Sydney Trains does not give consideration to the action suggested by the Independent Transport Safety Regulator in the July 2010 report".

Each division within the organisation will have varied levels of Fatigue Risk. This is based upon several factors that are related to rostering practices, work disciplines and working environment/conditions —Work/Non-work fatigue related factors. To effectively manage the fatigue risk applicable to each workgroup within the organisation the below documents are developed as prescribed within the [operator] FRMS:

• Fatigue Risk Profile: indicating applicable fatigue risk factors and appropriate control measures. As part of this procedure a statement is made that "bio-mathematical models should only be used as guidance for possible fatigue inducing rosters”.
• Fatigue Risk Management Plan that identifies:
  • Fatigue risks associated with different roles
  • The fatigue self-assessment and sign on process
  • Management of shift swapping
  • Location of the fatigue management training plan
  • FAID tolerability levels and processes to manage shift or duty extensions
  • How fatigue risks are monitored and reviewed

"The reporter has advised that many employees have raised concerns around the use of FAID and it being used to solely manage fatigue and were told numerous times throughout 2017 they would be involved in workshops to work towards a better approach to fatigue management, after [operator] management acknowledged there were valid concerns with FAID and the way it was being used. However, at the ground level, there has been no progress on this issue to date".

There has been significant preparatory work on issues such as those raised by the reporter since early 2017. [Operator] is currently undertaking a Fatigue Risk Management Improvement Program. This program is currently still in development. Communication and consultation with ONRSR, [operator] Executive, managers and workers is an essential element of our plan and will be undertaken in accordance with our development schedule.

The initiation of this Program coincided with the scheduled review date for [operator] Fatigue Management Policy and aims to further improve the administration of fatigue risk management across the organisation by taking into account recent research, best practice and international experience, and streamlining the administration of rostering and day-to-day operations to support these improvements. The programmed work includes:

• Reviewing and updating fatigue risk management systems, processes, principles and tools to ensure continued alignment with contemporary fatigue risk management practice; and
• In association with the above, development of updated fatigue risk management resources, promotion, training, awareness and communications. We are not able to comment on the extent of compliance by individual managers or issues faced by individual workers with respect to the above mandatory aspects of the [operator] Fatigue Risk Management System.