Prepare for Network Rail's updated Fatigue Risk Management Standard (NR/L2/OHS/003)

In 2018 Network Rail announced updates to their Risk Management Standard (NR/L2/OHS/003) after an Office of Rail and Road (ORR) review emphasised the importance of fatigue reduction in the workplace.

With the industry compliance deadline of October 2022 fast approaching, it is important to understand how to proactively monitor fatigue and how to implement a fatigue management plan which complies with the updated regulations.

A history of fatigue

Historically, a fatigued workforce was never properly considered a major cause of accidents within the rail industry. Despite this, the Rail Accident Investigation Branch (RAIB) East Somerset Junction Report (2009) highlighted that fatigue contributed to the cause of 74 railway accidents within an eight-year period.

Fatigue is defined by the Rail Safety and Standards Board (RSSB) as a state of weariness and can be caused by:

• A lack of sleep
• Insufficient rest
• Heavy physical exertion

In addition to this, the ORR also highlights that continual mental effort and attention to a task can also contribute to a state of mental fatigue which can be equally hazardous on site.

Fatigue has always affected performance within workers by causing hazards including:

• Impaired concentration
• Reduced mental alertness
• Drowsiness

However, it can be argued fatigue was only considered a serious safety hazard following the Clapham incident of 1988. The accident caused by a wiring error on the railway tragically claimed the lives of 35 people. In the investigation following the incident it was found the technician responsible for the error was severely fatigued after having had only one day off in his previous 13 days of work.

After fatigued staff were highlighted as the cause of  further incidents and accidents such as the near miss collision at Cardiff East Junction in 2016, the ORR launched an investigation and review into how Network Rail managed fatigue.

ORR report / review

The ORR report made a recommendation for Network Rail and their contractors to review how fatigue management systems were being implemented on major rail projects.

Furthermore, the ORR suggested that Network Rail’s response to the review should include measures to ensure all project staff, from managers to front-line employees, are aware of how fatigue is managed and how to implement this in working practice. The recommendations made by the ORR in 2018 focused on the overall goal to safeguard the Network Rail workforce by reducing fatigue amongst staff and minimising the risk of errors when operating construction equipment.

Network Rail’s Response

In response to the recommendations presented by the ORR review, Network Rail updated their Risk Management Standard (NR/L2/OHS/003). The standard stages of the plan were implemented in 2018 and 2019, however the industry compliance date remains October 2022.

To ensure that fatigue is eliminated or reduced to an acceptable level, the new regulations encourage both managers and site staff to consider fatigue at all times throughout a shift, taking into account total hours and site and commute times, to ensure the proactive management and mitigation of fatigue.

The new standards suggest a three step process to try to foster this mentality surrounding fatigue:

• Set trigger points for on site activities which put individuals at risk of fatigue - for example one trigger point under the new NR/L2/OHS/003 regulations is when an individuals commute and working time totals or surpasses 12 hours a day
• Once an employee has surpassed one of these triggers their line manager must organise a meeting to assess the risk of fatigue to the employee
• A tailored fatigue management plan must be designed for the individual to assess how employers can reduce the risk of fatigue, this may include implementing strategies, such as staggering shifts.

The new fatigue management standards will include all Network Rail and contractor staff working on the railway. As the new regulations will have consequences on the whole industry, it is important to ensure your business complies with the revised standards before October 2022.

How to ensure compliance

Do you have a fatigue management strategy in place for Network Rail’s updated Risk Management Standard (NR/L2/OHS/003) yet?

If your project team works on any sites managed by Network Rail, you will need to comply with the new industry standards before October 2022, so now is the time to innovate and get ahead of the game.

To comply with the new NR/L2/OHS/003 regulations it is vital that both managers and employees have access to a detailed breakdown of travel times and shift lengths to effectively monitor fatigue. Information on your workforce’s fatigue is only effective when captured and understood in real time. Taking a proactive approach to fatigue management it is important to have access to this data as it is captured in real-time to be proactive in flagging workers who exceed certain fatigue trigger points.

Raildiary have also produced a free Fatigue Risk Index Calcuator! You can use the calculator to help to support NR/L2/OHS/003 compliance and receive a PDF download with a detailed breakdown of the fatigue calculation, allowing you to fully understand fatigue trigger points!

Need help implementing a fatigue management strategy?

Read more about how to successfully manage fatigue here

A simple and easy way to achieve this is by implementing a digital site reporting solution, like Raildiary, which automatically monitors data input by site teams and immediately notifies you of any works at risk of fatigue. Remove the administrative burden away from managing fatigue, safeguard your workforce and ensure compliance.