Labor s Perspective: Safety and Health for Railroad Employees. The problem of fatigue in the rail industry

Transcription

1 Labor s Perspective: Safety and Health for Railroad Employees The problem of fatigue in the rail industry

2 Sleep Apnea is just one of many factors that may cause fatigue among operating (T&E) crews. Others causes include but are not limited to: 24/7/365 schedules with as little as 2 hours notice; backward rotating start times; excess time spent being transported to layover facilities after 12- hour workday; sleep debt/deprivation from irregular scheduling; extensive time spent at away-from-home lodging facilities; unhealthy diet (fast food and machine food at away-from-home terminal); and punitive attendance policies.

3 Railroaders and irregular schedules Operating employees have difficulty maintaining proper diet, exercise and regular sleep. This is due in part to: lack of predictable work schedules (being on call); 70% of operating employees work on call on the freight railroads; being on duty for long periods of time during overnight hours; working on trains in remote locations; and lack of access to nutritious meals. Proper and predictable sleep is a key need for the human body to perform the safety sensitive work of Locomotive Engineers, Conductors, Trainmen and other railroad operating crafts.

4 Rail Safety Improvement Act of 2008 RSIA mandates that industry develop fatigue mitigation plans by Labor believes much can be accomplished combating fatigue by instituting: a 10 hour call for duty for operating employees; a predictable rest day in each calendar week, at home, not at the away-from-home terminal; and a maximum of 2 hours beyond the 12-hour workday to get crews from their trains to layover facilities (statute currently allows 30 hours per month). Hyper-vigilance is a requirement of the job inside the locomotive cab.

5 Treatment for Sleep Apnea Labor and the rest of the rail industry are in agreement that train crews should seek and receive treatment for any sleep disorder, including sleep apnea. BLET wants sleep apnea and other disorders to be treated so that their members get the restorative sleep necessary to perform their job duties safely. Along with sleep apnea, other non-medical causes of fatigue must be given equal weight and addressed to satisfy the RSIA mandate (in 49 U.S.C ) that calls for establishing fatigue mitigation and risk reduction programs.

6 Federal Railroad Administration (FRA) FRA has made steps to try to put many measures included in RSIA into place through the Rail Safety Advisory Committee Working Group process. Hours of Service Working Groups were established for freight and for passenger/commuter rail. Freight railroad operating employees still endure fatigue from unpredictable work schedules. The RSIA only addressed limited conditions that contribute to fatigue such as: total time on duty; limbo time; and minimum off duty periods. Passenger/Commuter Rail Hours of Service regulation recently went into effect pursuant to 49 U.S.C The regulation was based on scientific and medical research.

7 FRA and RSAC Working Groups Through the RSAC process, industry stakeholders currently are trying to fashion a way to ensure railroad workers receive education and treatment for sleep apnea, as employees may not realize what it is or that they have it. The BLET is working with other Rail Labor Organizations to proactively address other causes of fatigue.

8 Fatigue abatement issues: 1. When the RSIA was passed into law, the passenger railroads were given 3 years to study the problem; however, changes mandated for freight railroads were not based on science and medicine, and have had little effect on fatigue. 2. The passenger railroads got it right, through science. 3. The freight railroads need to work on fatigue through the use of science. 4. A 10-hour call versus a 2-hour call. 5. More regularly scheduled work. 6. Time off at the home terminal, not the away-from-home terminal. 7. Eight hours rest at away-from-home terminal, and ten at the home.

9 General Accounting Office Report on the Hours of Service: September 2011 Conclusion said in part: RSIA did not address work performed during night hours, which, according to both scientific literature and our analysis of covered T&E employee work schedules, represents a major factor in fatigue risk. Therefore, opportunities for reducing the risk of fatigue remain, especially since night work is integral to freight rail operations. Additionally, in our view, FRA is missing opportunities to better identify the potential costs, benefits, and safety implications of alternatives to the current hours of service requirements.

10 GAO Report Cont. Recommends that the Secretary of Transportation along with FRA s Administrator : 1) Evaluate and develop recommendations about the relative impact of consecutive days worked and work performed during night hours on the potential for fatigue and risk of accidents in the freight railroad industry. 2) Work with the railroad industry to identify pilot projects that could be implemented to test the fatigue reduction potential of alternatives to the current hours of service laws. The Railroads have had the opportunity for many years to conduct pilot projects and have consistently refused to take advantage of the opportunity.

11 Final Thoughts Labor s perspective is given here is intended to; 1) Remind the industry and the scientific community of the unaddressed causes of fatigue. 2) Emphasize that sleep apnea is only one of many factors causing railroad workers to experience fatigue. 3) Recruit all stakeholders in the industry to work toward minimizing the risk that results from sleep apnea and the other non-health related causes of fatigue.