Metrolink peer review report - Ventura County Star

METROLINK COMMUTER RAIL SAFETY PEER REVIEW PANEL
Final Report – January 5, 2009
f. Railroad Industry Hour of Service/Split Shift Issue
Issue Papers
Observations
Following the Panel presentation to the SCRRA Board on December 12, 2008, the issue came up regarding the
impact of Split Shifts on Metrolink train service. The Panel did not study this issue in detail but has presented
below some observations and recommendations.
The current statutory provisions that govern the hours of service of railroad train and engine crews, dispatchers,
and signal maintainers were first enacted in 1907. The FRA has proposed to revise and update these hours of
service laws based on scientific information addressing fatigue-induced performance. As part of this FRA review,
the current practice of split shift assignments used by many commuter railroads would be addressed.
The Panel observed that SCRRA has not done an Hours of Service or Split Shift study. Some of the difficulties of
SCRRA conducting this type of study are that SCRRA does not have direct control of the contractors’ employees,
since they are employed by SCRRA’s contractors and those employees’ rates of pay, rules and working conditions
are governed through collective bargaining agreements. Additional difficulties are that SCRRA does not currently
have supervisors in the field where the work is being done and SCRRA staff has not developed statistical measures
for this type of review.
The Panel believes that these difficulties can be overcome by conducting an independent study in cooperation
with SCRRA’s contractors. For example, regarding a survey of the contractors’ employees, the independent study
consultant could provide the survey instrument and the survey could be conducted by the contractors themselves.
The analysis of that survey plus any additional analysis of Metrolink’s schedules and other data sources would be
done by the independent consultant.
Recommendation
a. Since SCRRA’s Transportation contractor uses split shift assignments in its train and engine crew
schedules, it is the Panel’s recommendation that SCRRA participate actively on the Hours of Service issue
as part of the FRA Rail Safety Advisory Committee (RSAC) process.
b. The Panel also recommends that SCRRA, in cooperation with its operating contractor, conduct a review of
its contractor’s Hours of Service Split Shift schedules for their train and engine crews and determine if
fatigue is a factor in the use of Split Shifts. In addition, SCRRA should evaluate whether any relevant rules
and their particular application require any short term measures pending the results of the FRA RSAC
process regarding Hours of Service.
Background
Human factors, in particular, fatigue, are the subjects of increasing study and rulemaking in much of the regulated
transportation sector. One operating practice, split shifts, falls under the study’s purview since it can lengthen a
workday beyond the traditional ”straight eight” However, the practice of split shift assignments in the commuter
rail industry is both common and cost effective because of the service patterns necessary to support the peak
markets of commuter operations. Generally there is a high frequency of train service between 5:00 AM and 9:00
AM to service the demand into major business centers in the morning and between 4:00 PM and 8:00 PM to
return customers to their homes in the evening.
The split shift assignments allow commuter agencies to establish crew assignments to cover both peak periods of
service thereby maximizing their utilization. In the interim period between the morning and evening assignments,
crews are placed on rest for a minimum of four (4) hours. It is the most efficient way to cover the service pattern
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