Clarification sought on how fatigue is managed at Old Oak Common Depot
A reporter has requested clarification over Bombardier’s fatigue management at Old Oak Common Depot. The reporter would like to know if Bombardier are following the recommendations from the Hidden Report (1989). Clause 18 states the need to monitor overtime to ensure employees do not work excessively. It is believed employees at this depot are working excessive hours.
The reporter states that the depot is made up of employees who are either new to the railway industry, or do not have a railway background. In both cases, they may be unaware of the Hidden Report and its recommendations. The reporter is concerned about fatigue-related incidents if working hours are unmonitored.
Could Bombardier clarify the following:
- Are the Hidden recommendations being followed?
- Can all staff be made aware of the recommendations?
- If they aren’t being followed, what guidelines are used for fatigue management?
Bombardier Transportation fully understands that fatigue can highly affect a person’s health, reduce their performance and productivity within the workplace, and increase the chance of a workplace accident occurring. We are committed to systematically eliminating, or controlling the risks associated with fatigue in its workforce through the implementation of the following:
- A fatigue management plan in order to undertake evaluations of different roster and shift pattern scenarios, with a view to continually improving rosters to reduce, as much as possible, any risks associated with fatigue.
- Providing briefing and/or training to raise awareness and knowledge about fatigue management with managers, supervisors, rostering personnel and employees.
- Using the fatigue assessment tool to understand the different shift patterns and time limits prior to planning and distributing any overtime to staff.
- Setting up individual fatigue calculators for those who regularly request or volunteer for overtime to ensure those individuals are not exceeding the fatigue limits.
- Providing shift and night workers with the Night Worker questionnaire to complete and return if they wish.
- Pre-planning times when shift cover may be needed, such as summer holidays or Christmas, and potentially using agency staff to help in these busy times.
- Talking to staff and encouraging them to report fatigue in themselves and others.
- If there is the potential for staff to be working a longer day than normal (e.g. travelling to another site for a meeting so their day and travel time has increased), discussing with them how to reduce fatigue such as staying over in a hotel or working a shorter day after or beforehand.
- Education: making everyone aware of the signs of fatigue in themselves and others, and when they may be more likely to make errors. Ensuring this information is distributed throughout the workforce.
- Ensuring managers and staff understand the purpose of the fatigue assessment tool, how to use it and how to manage the fatigue of their teams effectively.
- Use technology rather than travelling, such as Skype and video conferencing.
- Encourage staff to use local accommodation where they live a long distance from their place of work.
Information given to employees regarding fatigue includes the following: We have strict regulations for the amount of time you are allowed to work. Our group policy and the Hidden 18 standards mean that you:
- Must not work more than 12 hours per day.
- Must have at least 12 hours between shifts.
- Must not work more than 13 days in a row.
In exceptional circumstances where it is necessary to exceed these limits, your line manger must raise a ‘Working Hours’ concession form. The Fatigue Management Procedure is available to all employees. This gives guidance on symptoms of fatigue, how it can affect an individual’s health, things individuals can do when they know they are feeling fatigued and guidance to managers on how to check shift patterns within the fatigue calculator.
During investigation, no evidence of the concerns raised in this report were found. When considering fatigue management, reference is often made to the Working Time Regulations 1998 which, amongst other things, place maximum limits on the amount of time an employer can ask an employee to work.
An employee cannot, on average, work over a 48-hour week. Days off can be averaged over a two-week period, meaning you are entitled to two days off a fortnight. Adult workers are entitled to a rest break of 20 minutes if you have to work more than six hours at a stretch, and 11 consecutive hours’ rest in any 24-hour period. An employee can choose to opt out of the Working Time Regulations, but they cannot opt out of the requirements within regulation 25 of the Railways and Other Guided Transport Systems (Safety) Regulations 2006 (ROGS).
Every person working for Bombardier at Old Oak Common is monitored thoroughly by their line manager. Bombardier Transportation supports the fatigue management requirements contained within the group policy and the Hidden 18 standards, as well as the Health and Safety at Work Act 1974 (HSWA) which places general duties on employers to reduce risks so far as is reasonably practicable, including risks from staff fatigue.
Actions taken as a result of this report:
A group Toolbox Talk will be carried out during Safety Hour Stand-down to raise staff awareness and ensure them that fatigue management is being monitored, what they can expect from the managers and what is expected from staff.