CPA Bulletin

www.cpa.uk.net CPA Bulletin > May 2021 43 rail plant association RAIL PLANT ASSOCIATION: 1 Operational Challenges The avid readers among you may recall the RPA have been writing about plant provider’s operational challenges. From an On-track Plant (OTP) provider’s point of view, we have written about challenges such as transport (‘movement order’ challenges), POS, delivery and collection point management, loading and unloading low loaders and lorries, and OTP maintenance. In this article, we’ll touch on a very important topic which affects us all. Fatigue Management. Or more specifically, the latest Network Rail Standard on Fatigue Risk Management, which we believe will drive a significant culture change in railway infrastructure working. Before we start, let’s take a minute to reflect on our legal obligations. It is legally binding that we follow the laws of the land. There are many Acts and Regulations affecting all work environments, and additional industry specific ones that are relevant to those industries. We also have other binding documents to comply with. Standards. These can be industry standards (readily available from the Rail Safety and Standards Board (RSSB), and Infrastructure Manager Standards, such as those required to work on the Network Rail or London Underground infrastructures, which are available from a variety of sources. As you know, routine standard changes occur on a quarterly basis. On the whole, changes to standards cause very little disruption. However, every now and again, a new standard is introduced or changed that has a big impact on us. The latest Network Rail Standard NR/L2/OHS/003 - Fatigue Risk Management, is doing just that. NR/L2/OHS/003 issue 8 - Fatigue Risk Management This 13-page standard came into publication on 1st June 2019, and is supported by 3 separate modules which focus on Fatigue Risk Principles (Module 1), Design Roster and Work Patterns (Module 2), and Exceedance Management (Module 3), all of which were released at a similar time in 2019. What determines this standard to be different from others, is the seemingly distant compliance date, 29th October 2022. That’s two and a half years. Surely, we’ve got more than enough time??? Some businesses may believe they have this covered and see no reason to address this until closer to the compliance date. Well good luck to you with that one. For most of us, this standard will drive a significant culture change, and we all know cultures don’t change overnight. Why are we having to do this? • The Office of Rail and Road (ORR) applying demands on infrastructure managers to get fatigue risk under control • Many accident investigations have concluded fatigue to be a root cause • Fatigue is an adverse health issue that can also lead into more severe health problems if left unchecked What we do now RISQS audits check each year we have and demonstrably follow a Management of Fatigue Policy. Many will still use a system that sets limits to the number of hours and shifts a person can work on a managed railway infrastructure (inclusive of hours and shifts undertaken outside the railway for some workers). The general limitations followed are: • A person shall have at least 12 hours rest before work • A person shall work no more than 12 hours without taking a further 12 hours rest • A person shall work no more than 72 hours in a 7 day period • A person shall work no more than 13 consecutive shifts in a row (Network Rail) or 6 days in a row (London Underground) without taking a full 24 hours rest This is how we have managed fatigue risk for a long time for all our staff, full time and part time alike. It’s worth noting, the OTP operator community has changed over the past 2 decades. At the turn of the millennium, most OTP operators had a full-time post with their employers. This was achievable in a railway that offered many mid-week shifts to support the weekend shifts. The ratio 20 years ago would be close to 90% full-time OTP operator to 10% ‘zero hour’ operators looking to top up their midweek work earnings outside the railway industry. Today, the ratios have closely reversed. Mid-week shifts are few and far between and employers simply can’t afford to keep operators sat at home on Welcome back. Before we begin, can we say a big thank you to those who commented on our last article. After a detailed risk assessment, bow tie analysis, SWOT and PESTLE, we took a chance to write about the On-track Plant Operating Scheme (POS). Knowing how opinionated some folks are around this subject, it was touch and go whether to publish the RPA’s ‘take’ on the topic. However, your feedback was very positive, and we want you to know it is appreciated.