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Hours of Service: The challenge of remaining compliant with flexible, moving, real-time schedules.

Posted by Dave Songer on Oct 9, 2018

The challenge of remaining compliant with flexible, moving, real-time schedulesReal-time info in transit mostly leads to conversations about passenger information – making sure they know when the next train is coming, or how long until their destination. But, what might be more important – and not as discussed – is the real-time info you receive when altering your railroad workforce’s hours.

You might think it benign, but a change in one of your rail operators could put you in violation of FRA (Federal Railroad Administration) regulations (or other, similar rules governing labour). “How?” you might ask. Well, when dealing with rail operations, we all know that you need to make sure your schedules adhere to Hours of Service (and related fatigue) regulations, explains Marcelo Bravo from Trapeze, the company that develops software to help transport agencies manage their day-to-day business operations.

This article will dive into the following three areas of Hours of Service or related labour fatigue regulations:

1. The importance of labour and fatigue regulations.
2. How software can help everyone understand and interpret the rules correctly.
3. Updated in real-time, with a shifting operating window.

1. What’s the worry? The importance of labour and fatigue regulations

The reason for many of these regulations being brought in was to make rail operations safer. If your operators are working too much or working irregular hours, they are likely to be fatigued on the job. And, besides the fact that you could be violating regulations if you don’t properly adjust your schedules, it’s becoming apparent that fatigue is a predominant factor in railroad incidents. Railroad workers are more likely to get less than seven hours of total sleep during a workday. This lack of sleep puts them at higher risk of being fatigued during work. So if you don’t adhere to the rules that are in place, you could be putting your passengers at risk.

No one in the industry is going to purposely build or submit a schedule that violates these rules. That’s obvious. But, what happens when you have a new person building out schedules? Or if one of your employees is a no-show? Do you have the proper tools to analyse your workforce in real-time to make sure you are following the rules, yet still maintaining service?

2. Software allows consistent understanding and interpretation 

Building proper interfaces between systems will streamline processes and optimise your workforceOne of the many challenges is to understand AND interpret the regulations accurately. Different people have different interpretations. Different states might have slightly different laws if you are dealing with something that isn’t a commuter service, so you might be familiar with one set of rules, leading to slight variations if you go somewhere else.

One way to help fix this, or clarify the rules your agency has to follow, is to build in these processes into your software. You can build in parameters that make sure everyone is aware that the schedule they’ve created or updated still adheres to legislative regulations. Now, through decision support, all employees (new or not) are following the same interpretations of the rules, so no confusion happens from one person to the next. But building in these parameters is the easy part.

3. The challenge is operating within a moving window in real-time

Your employees have days off they’re entitled to, and your original schedule doesn’t take into account no-shows, sick days, or any other unexpected changes. Yet, you need to keep services going. If someone doesn’t show up you need to get someone to replace them so that your passengers aren’t left high and dry. But, if you have a person coming in on their day off, you need to analyse their past and future schedules.

For example, Hours of Service has a 14-day time period before your operator requires 24 hours of consecutive off-duty time. When making a change to an individual’s schedule, you need to analyse a floating 14-day window. If someone works on their day off, you need to have the ability to look into the past to see their last full day off. From there, you can look at that 14-day period and beyond to see if future schedules will violate any regulations. If they do, you will need to adjust future schedules or bring in a different person.

There are tools out there to help ensure you can make the correct scheduling decisions on the fly

The above example is an easy one – and only having to look at one employee might be easy – but the reality is that you would be looking at everyone’s schedules to see who could fill that spot, and if it works within the regulations you need to follow. To further complicate things, having to analyse all of that in the morning when someone calls in sick and you need to get a train on the tracks isn’t an easy task. There are tools out there to help ensure you can make the correct scheduling decisions on the fly without having to worry about violating any regulations.

Your passengers depend on you

Making sure your schedules comply with fatigue tracking software (FAST or FAID), scheduling software, and complying with Hours of Service regulations is easy. The challenge facing most is doing all of this together, in real-time while still maintaining compliance. Building proper interfaces/integrations between all these systems is a no-brainer. It will streamline the process and optimise your workforce. These rules aren’t just there for show. They’re about safety. You should make sure you are as compliant and safe as possible. Your passengers depend on it.

Marcelo Bravo is Industry Solutions Manager, Rail, at Trapeze.

You may also be interested in this:

Read: 5 Minutes With… Marcelo Bravo, Director, Rail Solutions, Trapeze Group.

Read: White Paper: Are you effectively leveraging emerging technologies to better manage your rail network?

Read: White paper: Who owns your software and data in a public-private partnership?

Topics: IT and WiFi, TransportSecurity

Dave Songer

Written by Dave Songer

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