Fatigue Federal agencies Hours of service Transportation Transportation

Should transit workers have standards for hours of service and fatigue?

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Photo: vanbeets/iStockphoto

Washington — Citing high-profile transit incidents in which worker fatigue played a role, the Federal Transit Administration is considering minimum standards for hours of service and fatigue risk management programs for the industry.

In an advance notice of proposed rulemaking published Oct. 30, FTA notes that public transit is the only mode of transportation without these measures.

The agency doesn’t offer specific proposals for HOS or fatigue risk management programs, but it asks for public input on each issue.

The notice details HOS and fatigue risk management program recommendations from the National Transportation Safety Board and FTA’s Transit Advisory Committee for Safety. Additionally, it includes information on American Public Transportation Association consensus standards and other relevant federal regulations.

APTA’s consensus standard for train operator HOS is 12 hours, with a “maximum duty day” of 16 hours. It also includes a minimum off-duty time of 10 hours and a max of seven consecutive workdays.

The deadline to comment is Dec. 29.

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Michel Courval
November 29, 2023
I am a transit professional with over 25 years of experience in the creation of work assignments in the bus and rail transit industry. While minimum rest time between adjacent work days (aka off-duty time) of 10hrs is fairly common, it does not address the rest time needed based on cumulative work hours. As the industry continues to face important workforce shortage, agencies are forced to rely on forded and/or voluntary overtime, or cancelling service. Operator fatigue is not only about regulating how many rest-hours they have between shifts, or how much working and/or driving time they can accumulate over continuous days such as the 70 / 7 (cap 70 hrs of work across 7 continuous work days). In order to reduce overtime (and resulting fatigue) we need to change how work shifts are created, promoting more attractive work/life balance and work conditions, regardless of what are the 'current' collective bargaining agreements. The needs and expectations of the new workforce are not the same, nor are they aligned, with preferences of the previous generations of workers.

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Christine Ivey
November 29, 2023
In 1937 these current rules were put into place. That's eighty-six years ago. The dynamics of society and communities have changed greatly. Population has grown and so has traffic. Transit company create a workforce based on the need of the community. Rarely if ever are the needs of the employees are takin into consideration. Employees like other workers live in areas that accommodate their lifestyle or finances just like the employers. This may require employees to commute to and from work, often times great distances. This can impact the employees rest schedule. The rest schedule starts the minute the driver clocks out and ends when the driver clocks in at work. But did the driver get an actual eight hours of uninterrupted rest? Now let's look at the runs the employers have put together. Prior to the pandemic runs were created to allow for the most part an 80% on time schedule which would allow a driver to get out and stretch and refresh or take a power nap at a layover on both ends of the run. However, post pandemic where transit companies have reduced the layover/recovery time down to 5 minutes from the norm of 15-30 minutes and placed undue stress and strain on drivers to drive fast and become careless just to get to the end of the line for a break from a run that is most often over an hour long in the seat. a lot of times the driver is late and is unable to get that break. Recovery time is NOT for the driver. Drivers are faced with passenger loads, traffic, lack of lane infrastructure and lights just for buses. This within itself is exhausting not only mentally but emotionally and physically. All this information only compounds issue that contribute to the need of transportation to restructure how it operates so that drivers can get the actual rest they need to focus on doing their job safely and effectively. Drivers need to have a minimum of 10 hours off. Times have changed. This also touches on the time change. In the Spring, drivers like everyone else loose an hour of sleep.