Metrolink peer review report - Ventura County Star

METROLINK COMMUTER RAIL SAFETY PEER REVIEW PANEL
Final Report – January 5, 2009
Issue Papers
and without this practice, the crewing costs could rise dramatically in the industry since an additional set of crews
would be required for one of the peak periods.
The concern of the FRA and the industry is: What are the employees doing during their rest period and are they
in fact resting during their off -hours? Is the way the split shifts are set up contributing to fatigue by upsetting an
employee’s circadian sleep patterns?
Currently there is insufficient data to show that the split shift assignments are a contributing cause in human
factor accidents. The FRA and industry professionals do not believe they have enough information to make a
determination on the effect of split shift assignments on fatigue.
Congress has an alternate allowance as part of the railway act (HR 2095) to defer the compliance of the commuter
rail industry to new Hours of Service requirements through an RSAC process, in deference to the very different
operating conditions of most commuter train and engine crews.. The new Hours of Service 8 requirements will be
applied to the freight industry in July 2009. In addition, railway labor has indicated that they may not support the
change in Hours of Service including elimination of split shift assignments.
Currently FRA plans to address this issue as part of its 2009 Docket for the RSAC. FRA will submit a task
statement of work in April 2009 for acceptance by the RSAC. That will start an 18 months clock for coming up
with any alternative Hours of Service regulations for commuter rail and intercity passenger rail.
FRA also has demonstration projects underway that, similar to aviation programs, attempt to develop data on
near miss occurrences as a means of developing better data on root causes of incidents. Such data development
and root cause analysis are critical to developing truly effective accident prevention strategies.
Many factors enter into human factors analysis. For example, SCRRA and other railroads provide rest facilities for
employees’ use between-shift respites. The use of these facilities by employees with split shift assignments should
be periodically reviewed. SCRRA's general work environment is similar to other commuter rail agencies in the
United States located in urban areas: high cost real estate in major metropolitan areas of Los Angeles, New York,
Washington DC, Boston, and others means that employee travel time to and from work assignments can be
substantial. Also, seniority plays a major role in where employees can hold job assignments; low seniority
employees, for example, have little or no choice in their work assignment locations.
The Panel recommends that SCRRA participate in the FRA RSAC process regarding this practice. The Panel also
recommends that SCRRA conduct a short term review of its major human factors conditions that may improve or
increase risk, including fatigue, and the impact of Hours of Service and Split Shifts and other rules whose
application may require short term changes, in addition to complying with the current and pending FRA rules
and regulations. To the extent that the review of major human factors conditions requires cooperation of
SCRRA’s contractors because they are the direct employers of the individual employees subject to the study, the
Panel recommends that SCRRA take all steps available to it to require those contractors to cooperate with the
study.
8 Commuter Rail and intercity passenger rail has to comply with the current Hours of Service regulations in law 49 CFR 228.
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