We are committed to the management of fatigue of all our workers and the application of this policy which meets the requirements of Regulation 25 of ROGs. ORR and RSSB Fatigue Guidance, and is in line with the national health and safety strategy- ‘Leading Health and Safety on Britain’s Railway’.
Consideration during our planning process is also given to the NFSG (National Freight Safety Group) Code of Practice published in December 2018 which was agreed by all Freight Operating Companies under the Rail Freight Project Charter.
We recognise the importance of such a policy in its contribution towards ensuring the health and safety of our workers, contractors and those affected by our activities.
We will take all measures as far as is reasonably practicable to ensure that all safety critical workers and contractors are aware of and adhere to the guidelines for hours of work and managing fatigue.
GB Railfreight are committed to the following fatigue controls:
a) A maximum rostered turn length of 12hrs.
b) At least 12hrs rest between safety critical turns excluding first night in lodge.
c) No more than 13 consecutive shifts without a 48-hour break.
d) At least 32 hours of rest after a block of consecutive nights.
e) No more than 5 consecutive shifts in a permanent base rostered pattern.
f) No more than 60 hours worked in a period of available days.
g) Very early shifts starting before 05:00 will be minimised if possible.
h) Risk evaluating all base rosters in conjunction with the ORR fatigue guidance and the Fatigue Index model.
i) Weekly & Daily fatigue monitoring throughout the planning and control processes.
j) Review of the ORR Fatigue Risk Management System document periodically
First night shifts are identified and mitigated by the following:
a) Development of staff education packages on the performance effects of first nights, long hours awake and misaligned body clock
b) Creation of staff education on sleep hygiene and napping
c) Targeted fitness for duty discussions, led by managers, which specifically include a discussion on recent sleep and activity
d) Checks on staff during duty reducing exposure to monotonous or particularly hazardous
Note: Any deviation from the above limits will require a risk assessment to be carried out.
GB Railfreight has developed internal procedures to prevent staff or contractors from working excess hours or shifts. Where applicable rosters shall be risk assessed using the Fatigue and Risk Index prior to implementation to evaluate whether proposed shift patterns place staff at risk of fatigue.
Measurement of the effectiveness of these control measures will be via continuous monitoring and audit. Should this reveal a deviation from the procedures then appropriate action will be taken at lead by the Fatigue Focus Working Group made up of Safety, Ops, Planning and Union Representatives.
Any deviations or concern will be treated under our Fair Culture and should be sent to Vittorio Licata and Stuart Anderson.