Sometimes change happens in a logical manner. Sometimes it needs a push. In this case, it took two major precipitating accidents to effect a significant change in hours of service for rail transit operators.

The National Transportation Safety Board found operator fatigue to be a contributing factor to those and other rail transit accidents and, as a result, issued a finding to the Federal Transit Administration and the individual transit agencies involved in the accidents to adopt limitations on the working hours of train operators. Specifically, the NTSB recommended that train operators be provided the opportunity to obtain eight consecutive hours of uninterrupted rest between work shifts.

Lack of Regulatory Mandate
Congress provided the charter to other agencies, including the Federal Aviation Administration and the Federal Highway Administration, to mandate regulations they deem necessary—and those agencies, and more, have long limited the working hours of vehicle operators in commuter rail, aviation, long-haul trucking, and the maritime industries. So while the NTSB’s finding addressed the Federal Transit Administration, the FTA is not a regulatory agency and does not have the authority to regulate train operator working hours. So the FTA turned to APTA’s standards program.

Working off an NTSB finding to limit those hours, APTA’s Policy and Planning Committee assigned the development of an Hours of Service standard to the Rail Operating Practices Committee, chaired by Gerald Francis, deputy general manager of the Washington Metropolitan Area Transit Authority. Over a period of more than 18 months, that committee met to hammer out compromises that would be accepted.

“We developed a white paper that looked at what other transportation industries do, at the regulations in aviation, commercial trucking, and maritime—and modeled our standard on that,” said Christopher Wallgren, vice president of Philadelphia-based Transportation Resource Associates and one of two co-facilitators for this project. “Plus we looked at research at how long people can work and how much rest they need,” he added.

The NTSB’s finding related only to train operators, so that is where the committee focused. The resulting voluntary standard allows train operators to work a maximum straight shift of 14 hours or a split shift of a total of 16 hours duration, provided they have at least two hours’ break. The work shift must be followed by a minimum of 10 hours off before the operator can work another shift. In addition, to work through labor contracts and negotiations, the standard allows for an implementation period of five years.

“What makes me happiest about the standard,” said Wallgren, “is that we had very active involvement from small and medium and large-size rail transit systems. They helped to make this a strong standard that everyone can live with—and that participation should help with implementation.”

Possible Concerns/Resistance
There may be some concerns about the reduction of overtime, said Charles Dziduch, WMATA’s line service director and a member of the committee, but he believes that “that’s something we’ll be able to work our way through.”

He stated that there will be a need to have more operators, so that when they write their schedules, “it will be a priority of management to make sure they have fully staffed ranks, because that then reduces the need for overtime.” This standard will have to be negotiated with the unions, but as Dziduch observed, “it will mean a more rested operator—he will be more alert and less likely to have fatigued-related incidents.”

Impact of Standard
“We’re just starting as an industry to recognize that fatigue is a factor that needs to be addressed,” said General Manager Al Fazio of New Jersey Transit Corporation’s River Line, another committee member. Calling the standard “beneficial” for the industry, he pointed out that “it’s rare when fatigue isn’t at least a contributor, if not the primary cause, when you look at the history of events and accidents. The highest benefit is in the reduction of risk, of catastrophic events, so it benefits the industry across the board.”

Experts commented that the standard will improve employee attentiveness and decision-making abilities, particularly at the end of shifts where people have worked very long hours. It will also make fatigue an issue that needs to be noted in incident investigation.

“This wasn’t an issue that came up before,” said Wallgren. “There wasn’t hard data out there. It wasn’t as if there was a check-off list on accident inspections, i.e., was this person tired? Now that it’s a standard, it will have to be looked at,” he added.

“It’s a very worthwhile standard,” said Dziduch. “I think it will help the industry be safer.”

The approved standard is available for download here.

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