3.1 All rail employers have a duty to assess and control risks arising from staff fatigue, whether their staff carry out safety critical work as defined in ROGS 2006, or not. The complexity of these arrangements will depend on the type of work but will require greater rigour where there is shift work, significant overtime, or safety critical work being carried out.
3.2 It is recommended that duty holders set up and operate an overarching Fatigue Risk Management System covering both safety critical and non-safety critical work and use similar management systems to control fatigue risks in both groups. An FRMS need not be standalone but could be integrated into the wider Safety Management System. Alternatively, duty holders may choose to adopt a different approach, but should ensure that those measures are equally effective.
3.3 Duty holders should devise and implement an FRMS which is proportionate to the likely risks from fatigue. There is no 'one-size-fits-all’ for fatigue risk management systems. This guidance outlines some key features of a comprehensive FRMS, but the extent to which each of the outlined features may be necessary for a particular organisation will depend on the nature, size and complexity of the operation, and the degree of risk which may arise from fatigue.
3.4 Section 4 in this document provides guidance on basic fatigue controls which would be expected of all responsible employers, even if their staff do not work shifts or significant overtime or carry out safety critical work under ROGS 2006.
3.5 Sections 5 to 9 are relevant to all rail employers whose staff work shifts or work significant overtime, whether their staff carry out safety critical work under ROGS 2006 or not. It outlines the features of a company-wide Fatigue Risk Management System, following the Plan, Do, Check, Act approach outlined in the HSE publication HSG65.
3.6 In the 2012 version of this guidance, a separate section was provided to cover the ROGS 2006 9 stage approach. However, sections 5 to 9 of this guidance amalgamates sections 5 and 6 of ORR’s 2012 guidance so that there is now one overarching approach to managing rail staff fatigue.
3.7 Appendix E provides the key definitions and abbreviations used in this guidance.