CP Rail Fatigue
Management Plan: Review
and Assessment

Patrick Sherry, 

March 8, 2012

 

 

Table of Contents

Introduction................................................................................................................ 3
Evaluative Approach................................................................................................... 3
Overall Philosophy...................................................................................................... 3
FMP Components........................................................................................................ 4
Work/Rest Rule Section 6.1.2...................................................................................4
Work/Rest Rule Section 6.2 – Development and Implementation............................5
Work/Rest Rule Section 6.2.3...................................................................................5
Work/Rest Rule Section 6.2.3...................................................................................5
Guideline Components............................................................................................ 6
A.

Statement of Principles..................................................................................6

B.

General Plan.................................................................................................. 6

C. Accountability................................................................................................ 7
D. Evaluation of Plan.......................................................................................... 7
E.

Risk Assessment............................................................................................ 8

Work/Rule Section 6.2.2 - FMP Key Risk Factors......................................................9
A.

Education and Training................................................................................... 9

B.

Scheduling Practices.................................................................................... 10

C. Dealing with Emergencies............................................................................11
D. Alertness Strategies..................................................................................... 12
E.

Rest Environments....................................................................................... 13

F.

Implementation Policies...............................................................................15

G. Evaluation of FMPs and CM Effectiveness....................................................16
Conclusion................................................................................................................ 17
FMP Key Risk Factors Score Sheet.........................................................................18

2

 Fatigue Management Plan Assessment and Review
Introduction
The Railway Safety Act and the new Work/Rest Rules for Railway Operating
Employees that came in to effect on April 1, 2003 required the submission of
Fatigue Management Plans (FMPs) to Transport Canada as an essential component
of the Work/Rest Rule. In September 2010 and revised in March 1 2011 Fatigue
Management Plans Requirements and Assessment Guidelines were published that
specified the essential components and elements of the FMPs. Following the
publication of these Guidelines the major railways and their smaller entities
submitted FMPs to Transport Canada.
In this document, the plan submitted by CP Rail has been reviewed and
evaluated. Essential components of the plans that were included in the submission
have been identified. In addition, the extent to which the components included in
the submission were consistent with the Guidelines has been evaluated and
reviewed. In some cases specific suggests for additional inclusions have been
noted. Where lack of detail or specificity prevented an evaluation this has been
noted.

Evaluative Approach
Based on the Work/Rest Rule, the Fatigue FMP guidelines and the assessment
worksheet provided by Transport Canada the following review was undertaken. The
general approach was to first review any statement that purposed to reflect the
underlying philosophy and approach taken to the process. Next, the materials
submitted (i.e. the “plan”) was examined for the extent to which it described in
sufficient detail the actions, plans, or procedures that might be followed and for
which an outside observer would be able to determine whether the practice or
principle that was thought to be identified as being needed was in fact in place and
could be ascertained from the written material provided.
Based on these guiding principles then it was determined whether the
suggested practice was in fact present. Points were assigned to each railroad
submission commensurate with the review of the materials provided.

Overall Philosophy
The Fatigue Management Plan Submitted by CP Rail Canada and the
Teamsters Canada Rail Conference (TCRC) states that the plan was developed in
collaboration with both the CP Rail and the TCRC. In the introductory section of the
document the plan “objectives” (listed on page 3) state that the objective is to
“minimize employee fatigue and thereby improve the operation task performance
3

 and safety of employees.” The objectives further list the desire to “Impact positively
on the work/family balance and quality of life of all CP operating employees.” The
CP Rail plan indicates that these objectives will be accomplished through the
following:

1. Promoting awareness of the impact of fatigue on human
performance and striving to reduce the effects of fatigue in all CP
Operations
2. A work environment that allows for the effective implement of
fatigue counter measures
3. A combination of corporate and individual responsible and
empowerment to manage fatigue.
These introductory statements provide a clear statement of the intent of the plan
and are in keeping with the intent of the Work/Rest Rule section 6.1.2 which states
that FMPs “shall be designed to reduce fatigue and improve on-duty alertness of
operating employees.” With their stated objectives CP Rail has met the intent of
the Work/Rest Rule. However, with the addition of the second objective regarding
“work/family balance and quality of life” CP has gone beyond the intent of the rule
and offered to enhance both fatigue and quality of life issues. In the spirit of
continuous improvement, the development of effective FMPs and the long term
promotion of a safe and efficient railway system that serves the public and the
industry the following assessment of the CP Rail FMP is presented.

FMP Components
The Work/Rest Rule spells out the specific requirements for filing the FMP (see
Section 7) as well as other general requirements of Fatigue Management Plans in
Section 6. In addition, there are specific sections of text in the Work/Rest Rule (e.g.
section 6.2.2 and 6.2.3, see page 8.)
The Guidelines for Developing FMPs specify that each plan should address
five main components (pg. 11). These guidelines and components address the
areas and practices that fatigue management plans should address.

Work/Rest Rule Section 6.1.2
This section of the rule states that FMPs “shall be designed to reduce fatigue
and improve on-duty alertness of operating employees.”

4

 The material provided by CP Rail state that the objective of the FMP is to
“promote awareness of the impact of fatigue on human performance and
striving to reduce the effects of fatigue in all CP operations.” The statement
of principles provided also identifies the intent or the goal of “minimizing
employee fatigue.” However, the plan does not fully address how this is
supposed to be accomplished.

Work/Rest Rule Section 6.2 – Development and Implementation
This section of the rule clearly states that railway companies and their
employees “will be involved in the development and implementation” of FMPs.
The material provided by CP Rail provided on page 2 indicates that “CP and
the Teamsters Canada Rail Conference (TCRC) representatives, officers or
representatives collaborated on the development of the roles and
responsibilities and the application of FMP.
The material provided by CP on page 2 also indicates that CP and TCRP “will
jointly be responsible for changes to this FMP.”
These statements indicate that the process required by the rule was followed.
However, it would be helpful to be able to inspect a document or letter of
support from all of the parties consulted.

Work/Rest Rule Section 6.2.3
Subsection a. - This section of the Rule states that FMPs “shall address how
operating employees, who work more than one tour of duty will be afforded the
opportunity to be involved in the decision to accept a subsequent tour of duty,
based on their fitness at the time.”
The material provided by CP Rail does not address this level of specificity
specifically required by the Rule.
Subsection b. - In addition, the rule states that FMPs “will have processes in
place that provide rest provision that allow employees to elect to take rest prior to a
subsequent shift or tour of duty.”
The material provided by CP Rail does not address the level of specificity
required by the Rule.
Subsection c. - The rule states that FMPs shall address the circumstances
under which operating employees in road service not taking rest will be provided
the option to take a break of up to 45 minutes off-duty between working hours
where the combined on-duty time will exceed 12 hours.
5

 The material provided by CP Rail does not address this level of specificity
required by the Rule.

Work/Rest Rule Section 6.2.3
The rule states that a specific FMP must be in place to address fatigue in the
following circumstances:
a. Where continuous duty exceeds 12 hours
b. Where there are more than 64 hours on-duty in a 7 day period and
c. Emergency situations
With the exception of subsection c, the material provided by CP Rail does not
address the level of specificity required by the Rule.

Guideline Components
A. Statement of Principles
The CP Rail FMP includes a general statement of Principles. The FMP states that
CP Rail will work to “mitigating accidents” to protect employees and the public
from harm. In addition, the FMP states that CP “will work with labour, regulators,
academic, industry partners and associations to address fatigue related issues
using a proactive approach.” These statements are in keeping with the intent of
the rule. However, the rule states that the goal is to reduce fatigue and improve
alertness. The material provided by CP Rail does not mention this.

B. General Plan
The material provided by CP Rail was termed a “General Fatigue Management
Plan” and it addresses many of the requirements of the Work/Rest rule. The plan
states that “CP and the TCRC have “outlined the goals of the FMP, roles and
responsibilities and its application.” The plan further states that the
responsibility for the “establishment, maintenance and monitor of working
conditions that will provide operating employees adequate rest between tours of
duty and to help sustain alertness throughout the on-duty period is shared jointly
between the company and the TCRC.” (See page 2) The material provided by CP
acknowledges that specific operating plans must be in place to address the
fatigue of operating employees when operating in work train service, emergency
situations and where operating employees are more than 64 hours on duty in a 7
6

 day period. The document states that they “specific” FMPs have been “jointly
developed and filed in accordance with the rules. The material provided by CP,
however, does not provide any evidence of the current existence of these
“specific” plans nor where they might be found nor how many have been filed,
nor how effective they are or have been. It appears as if this is a statement of
intent rather than the existence of an actual plan. This is surprising given the
likelihood that there must have been at least a few cases of employees
exceeding 64 hours in a 7 day period. It would be helpful of these “specific”
plans could have been included in an appendix or in some way made available
for review.

C. Accountability
The General FMP provided by CP outlines the general role of the
TCRC/Management Leadership as “the development, implementation, monitoring
and sustainability of the FMP.” (See page 4) The document further identifies the
responsibilities of the
-

TCRC General Committees of Adjustment & Legislative Department
Field Operation General Managers
Industrial Relations
Safety Environment and Regulatory
Front Line Mangers & TCRC Representatives
Operating Employees
CP Field Operations/Transportation Department

These duties and responsibilities are outlined on page 4 of the document. In
particular, the “Front Line Managers and TCRC Representatives are
responsible for the rollout, sustainability and compliance with the FMP.” The
description and material provided however, does not given any indication of
how these individuals will perform their duties or what materials they will
examine to be able to ensure accountability.

D. Evaluation of Plan

7

 The material provided by CP Rail identifies the Company and the TCRP as
having responsibility for this effort. It is noteworthy that the FMP states at the
outset of Section 7 “Evaluation of the FMP” that “The long-term success of the
FMP depends upon ongoing measurement and review.”
The plan states that the appropriate metrics will be identified and captured.
The plan also states that the FMP will be evaluated using a “regular review using
fatigue modeling, scheduling tools and other scientific means to determine the
likelihood of a schedule or condition for creating or developing fatigue levels that
might not be considered optimal” (page 16) This approach seems very useful
and appropriate. However, it is unclear as to what “regular review” means in
terms of frequency. Is this a once a year or once a week review? Moreover, from
the data provided, it is unclear if this review is conducted in such a way as to
provide advance knowledge of a potential risk or hazard or whether this is an
after the fact review. In addition, given the accountability statement earlier, do
the local or line supervisor’s managerial tools include the bio behavioral data
from the scheduling tools? From the material provided by CP it is unclear as to
whether the regular review is adequate to provide both preventive as well as ad
hoc analyses.
The plan described in section Seven also includes the statement that “selfreport” data and other behavior indictors, amount of rest booked, total number
of hours on duty, average stat times and average discrepancy between posted
start times and actual start times will be used. This is a very good start at
identifying the common metrics that might be used to help evaluate the
presence potentially risky levels of fatigue in the workplace.
Very noteworthy is the fact that the accident and incident analysis will
examine whether fatigue was a factor in an event. This type of review can be
useful in determining underlying trends, potential hazards and possibly the need
for systemic counter measures that can lead to a more safe and efficient
operation.
The process set in place appears to be an adequate approach. However,
there is no evidence that the plan has been implemented. There is no data on
the number of exceptions, how they were resolved and how many were reported.
Furthermore, it is unclear what data or criteria are being monitored. Most
important is the issue of when and how the monitoring is taking place. Are these
exceptions observed after the fact? What mechanisms are in place to monitor
real time events and how are they recorded. This issue is addressed again in
later sections. However, the issues of what data is being gathered, how often
and by whom, and how it is being evaluated and according to what criteria, other
than simply exceeding 64 hours in a 7 day period or 12 in 24, seems to be
missing from the plan. A more detailed and proactive evaluation plan is
essential to being able to accomplish the intent of the work/rest rule that is
8

 designed to “reduce fatigue and improve on duty alertness.” Based on the
material provided by CP Rail it does not appear that CP Rail is in compliance with
this requirement of the rule.
E. Risk Assessment
Based on the material provided it appears that relative to risk assessment,
that CP is in compliance with this requirement of the rule. The guidelines
suggest that the FMP is designed to “plan for and implement counter measures
in the event of an employee developing a risk for fatigue impaired performance.”
The CP plan specifies that the risk will be examined in accident analysis
investigations. The plan further states that “using fatigue modeling” to assess
the likelihood of a schedule or condition for creating of developing fatigue levels
that might not be optimal. This approach would be well-suited to assessing
whether a potentially risky situation might develop.

9

 Work/Rule Section 6.2.2 - FMP Key Risk Factors
A. Education and Training

A
.
C
C
C
C

Education and Training
1 Sleep Hygiene
2 Diet Health & Lifestyle
3 Body Clock
4 Definitions of Fatigue & Alertness
5 Sleep Disorders
6 Stress Management
7 Sleep & Performance
8 Various Sleep Schedules
9 Countermeasures
1
0 Individual and Age Differences

Maximu
m
Score
Possible
3
1
3
1
3
1
3
1
1

External
Assessm
ent
3
1
3
1
3
1
3
1
1

1

1

18

18

The plan submitted by CP rail includes a description of the contents and outline of
the training materials. The training program and the items within are described in
sufficient detail to determine that all of the key components are included in the
training program. Most likely CP Rail is providing a high quality training experience
that addresses the main points recommended for inclusion in the guidelines.
However, what is missing from the plan is a more detail description of the delivery
of the training program to operating employees. Several questions arise such as:
when does the training occur, how often does it occur, are repeat session offered to
experienced employees, how well is the information contained in the training
retained and or utilized. Based on the materials provided, the external review of the
plan obtained a score of 18 out of a possible 18 on this particular component.

10

 B. Scheduling Practices

B.
C

C
C

C

C

Scheduling Practices
The total length of the work shift is equal to
1 12 hours.
Employees have limited exposure to
working between the hours of 0000 and
2 0600.
Recovery periods permit opportunities less
than six hours of continuous sleep in a 243 hour period.
Off-duty times permit reasonable
4 recuperative times.
Work time is limited to 64 hours in a seven
5 day period.
Recovery periods permit two consecutive
6 nights of sleep.
Twenty minute break periods are scheduled
7 approximately every 4 hours.
8 Work schedules are highly predictable.
9 Opportunities for napping exist.
When periods of wakefulness exceed 19
1 continuous hours sufficient opportunity for
0 sleep is provided.

Maximu
m
Score
Possible

External
Assessm
ent

3

3

1

1

1

1

3

0

3

3

1
1
2
1

1

3

2

19

10

The plan submitted by CP rail includes an acknowledgement of the importance of
managing fatigue using scheduling practices. In addition, the CP FMP recognizes
the important of being rested before, during and throughout the on-duty period.
THE FMP states that CP has established specific FMPs to address situations where
the maximum time on duty exceeds regulations. The materials provided by CP in
the plan provide a definition of emergencies and examples of what emergencies
might consist of. The plan further states that additional approaches to reducing
fatigue have been identified including: regular rest days, time pools and bid packs.
In addition, employees who work more than one tour of duty without resetting their
18 hour clock are afforded the opportunity to be involved in a decision to accept a
subsequent tour of duty. In addition there are opportunities for breaks of up to 45
minutes off-duty between consecutive working tours of duty.
(See Section 2 –
Scheduling, page 8). The external review of the plan obtained a score of 10 out
of a possible 19.

11

 1. Items #1 - Regulations require that the total length of the work shift not
exceed 12 hours which is likely standard practice.
2. Item #2 – It is unknown what percent of the workforce works this particular
schedule. It is difficult to determine what percent of the employees actually
work between 0000 and 0600 hours. However, the CP FMP acknowledges
this as a fatigue risk area.
3. Item #3 – This item is only addressed generally. In particular, the CP FMP
states that when employees do not have the ability to reset their 18 hour
clock they are involved in a decision to accept a subsequent tour of duty.
4. Item #4 – In general this appears to be the case. However, additional
information in the form of percentages of individual who were able to do so
could be provided. At this point, without additional descriptive material it is
unclear whether this particular practice is utilized sufficiently.
5. Item #5 – This is a regulatory requirement and most likely being met. But, is
it being met 100% of the time? CP rail could provide data that would enable
a more accurate assessment.
6. Item #6 – In general this appears to be the case. However, additional
information in the form of percentages of individual who were able to do so
could be provided. At this point, without additional descriptive material it is
unclear whether this particular practice is utilized sufficiently.
7. Item #7 – This particular practice is not mentioned in the FMP. It seems
unlikely but, without additional descriptive material it is difficult to judge
whether this countermeasure is being utilized.
8. Item #8 – Most likely, since CP is NOT primarily a commuter railroad, that the
schedules are NOT highly predictable. Therefore, without additional
descriptive material to the contrary it is not possible to evaluate this item at
this time.
9. Item #9 - Opportunity napping has been identified in other sections. (See
Section 4 Alertness Strategies).
10.Item #10 – This item is only addressed generally. In particular, the CP FMP
states that when employees do not have the ability to reset their 18 hour
clock they are involved in a decision to accept a subsequent tour of duty.
Additional material would be needed to fully evaluate this portion, however, it
appears to be addressed.

C. Dealing with Emergencies

C
.
C
C

Dealing with Emergencies
1 Definition of emergency situations
2 Provision of specialized considerations for
12

Maximu
m
Score
Possible
4
4

External
Assessm
ent
4
3

 extra duty
8

7

The plan submitted by CP rail includes an acknowledgement of the importance of
managing fatigue during emergencies. The materials provided by CP in the plan
provide a definition of emergencies and examples of what emergencies might
consist of. The plan further states that a “Specific Fatigue Management Plans for
Emergency Situations” have been developed. The CP FMP states that supervisors
will “strive" to minimize the risk of fatigue for persons performing emergency
duties.” The FMP also states that crews involved in unusual operating conditions
will be advised of the circumstances in order to enable napping. (See Section 3 –
Dealing with Emergencies, page 10). The external review of the plan obtained a
score of 7 out of a possible 8.
The external review of the FMP notes that while there appears to be a strong intent
to manage fatigue effectively during emergency situations, there is no material that
has been provided that describes a specific emergency and how it has been dealt
with. For example, it is unclear how or where employees would be able to nap if no
facilities were available. What would the length of the nap allowed be? Etc. Some
written documentation of these activities is needed to fully evaluate the plan.
1. Item #1 – This guideline is clearly met with the listing of the possible
situations that comprise an emergency.
2. Item #2 – This section is less clearly defined than the previous section.
Moreover, it does not provide sufficient detail to evaluate. The FMP states
that “crews required to work in excess of 12 hours… will be relieved of duty
at the first available opportunity.” (see page 10)

D. Alertness Strategies

D
.
C

Alertness Strategies (Identification of onduty strategies that are encouraged
permitted.)
FMP should include a list of recommended and
1 approved alertness strategies.
2 Technological aids (alerters)
3 Napping strategies
4 Breaks
5 Checklists to stay alert.
6 Other communication strategies as needed.
7 Appropriate use of exercise
13

Maximu
m
Score
Possible

External
Assessm
ent

5

5

1
1
1
1
1
1

1
1
1

1

 8 Use of light, sound, and temperature.

1
12

9

The plan submitted by CP rail includes an acknowledgement of the importance of
alertness strategies as an aide to improving alertness on the job. While helpful the
CP FMP as acknowledges that the most important fatigue counter measure is “to
obtain sleep.” (See Section 4 – Alertness Strategies page 12). The external review
of the plan obtained a score of 10 out of a possible 15.
1. Item #1 – This guideline seems to be partially utilized and
addressed. However, the recommended strategy list does not
include strategies other than napping. It is recommended that CP
consider adding some additional strategies to its list. The CP plan
states that CP and TCRC “will research and evaluate other alertness
counter measures.”
2. Item #2 – There is no mention of technological aids in the plan
therefore it cannot be evaluated at this time and no points could be
assigned.
3. Item #3 – Napping strategies, arguably one of the most effective
alertness strategies, is clearly present in this plan. The plan
includes both opportunity naps at the home terminal as well as En
route.
4. Item #4 – This guideline is noted as being utilized, however, it is
unclear as to when and how these breaks are scheduled and
utilized. The CP plan acknowledges that “short breaks with some
light exercise can restore alertness for a brief period.”
5. Item #5 - This guideline is noted as being utilized, however, there is
no mention of it in the narrative and no examples of checklists
provided. While the intent is noteworthy and the technique sound,
evaluation of the approach would be made easier with examples as
well as data indicating the percentage and frequency of usage.
6. Item #6 - There is no mention of checklists as operational aids to
alertness in the plan therefore it could not be evaluated at this time
and no points could be assigned.
7. Item #7 – As noted above there is mention of this strategy.
However it is not specified as to when and how often or under what
circumstances it might be used. Additional information from CP
would be helpful in evaluating this counter measure.
8. Item #8 - There is no mention of the use of light, sound and
temperature as alertness strategies. Therefore it could not be
evaluated at this time and no points could be assigned.

E. Rest Environments
14

 E
.
C

C
C
C

C

Rest Environments
Standard policy for review of
1 facilities
2 Certification of lodging
3 Sleep aids
4 Light reduction
5 Sound reduction techniques
6 Temperature controls
7 Exercise facilities
8 Eating facilities
9 Wake up policies - do not disturb
1 Location or proximity to tracks or
0 switching operations

Maximu
m
Score
Possible

External
Assessm
ent

2

1

1
1
2
2
2
1
1
2

2
2
2

2

1
15

9

The plan submitted by CP rail includes a firm commitment to maintaining the quality
of the rest environment as well as the opportunity to use the rest environment.”
(See Section 5 page 14). CP states that it has a “rigorous process in place, in
conjunction with committees mandated by collective agreement to evaluate and
improve rest facilities in order to bring them up to standards consistent with
scientifically developed fatigue management principles.” The external review of
the plan obtained a score of 9 out of a possible 15.
1. Item #1 – The policy for review is identified in Section 5. The materials
provided give a good indication of the various criteria and aspects of the
environment that the company looks at. However, in order to fully evaluate
the policy it would be helpful if a copy of the detailed process and the policy
statements including criteria and definitions were included in an appendix.
2. Item #2 – The policy does not include a description of a certification process
for lodging facilities. Additional information would be needed in order to
provide an evaluation of this component.
3. Item #3 – The plan and materials provided by CP do not describe additional
sleep aides that could be used. Additional information would be needed in
order to provide an evaluation of this component.
4. Item #4 – This item is described in section 5 as an important feature of a
quality rest environment.
5. Item #5 - This item is described in section 5 as an important feature of a
quality rest environment.
6. Item #6 - This item is described in section 5 as an important feature of a
quality rest environment.

15

 7. Item #7 – The plan and materials provided by CP do not include a description
of exercise facilities. Additional information would need to be provided in
order to fully evaluate this component.
8. Item #8 - The plan and materials provided by CP do not include a description
of eating facilities. Additional information would need to be provided in order
to fully evaluate this component.
9. Item #9 - This item is described in section 5 as an important feature of a
quality rest environment.
10.Item #10 - The plan and materials provided by CP do not include a
description or discussion of the issues of proximity to tracks or switching.
Some mention of on property rest facilities is provided. However, additional
information would need to be provided in order to fully evaluate this
component.

F. Implementation Policies

F
.
C
C

C

Implementation Policies
1 General principles
2 General Plan
3 Local Plan
4 Risk Assessment
5 Commitment to FMP Rule

Maximu
m
Score
Possible
5
5
1
1
3
15

External
Assessm
ent
4
3
0
0
3
10

The plan submitted by CP rail includes several key elements relative to the
implementation policies required. The external review of the plan obtained a score
of 10 out of a possible 15.
This section clearly includes a statement of intent and commitment to the
implementation of the plan. Fatigue assessment and regular review of the data
through fatigue modeling, scheduling tools and other scientific means are clearly
specified.
16

 1. Item #1 – The general principles are clearly identified.
2. Item #2 – The general plan is outlined here in this document.
3. Item #3 - However, the lack of description of the existence or review of local
plans was considered problematic as insufficient data was available for
review. It is unclear from the material provided as to what constitutes a local
plan, where the plans would be stored, and what format they would take etc.
It is clear there is intent to implement the plans but without a specific
mechanism it is difficult to evaluate.
4. Item #4 - Similarly, the Risk assessment is described elsewhere in the
document, but it is not described in sufficient detail so that the plan for risk
assessment can be evaluated.
5. Item #5 – This section includes a clear statement of commitment to
implementation.
Overall, the lack of detail makes it difficult to evaluate the overall plan and/or the
local plan. There do appear to be some general principles which specify the
intention to review evaluate and improve, but without more specificity regarding the
scope, method, criteria and timeline it is not possible to fully evaluate.

17

 G. Evaluation of FMPs and CM Effectiveness

G.
C
C
C
C
C

Evaluation of FMPs and CM
Effectiveness
1 Specification of fatigue metrics
Specification of data gathering
2 methods
Systematic review of crew
3 scheduling data
4 Accident analysis
Opportunity for consultation (e.g.
Employee representatives; health &
5 safety committees)
Systematic review of plan
6 measurement data
Use of bio behavioral models (e.g.
7 FAST)
1
0 Utilization of self-report data

Maxim
um
Score
Possibl
e
2

External
Assessm
ent
2

2

0

2

1

2

2

2

0

1

1

1

1

1

1

13

8

The plan submitted by CP rail includes several key points relative to the Evaluation
of the FMP. Using the worksheet provided in the FMP Guidelines, the external
review of the plan obtained a score of 8 out of a possible 13.
1. Item #1 – The specification of fatigue metrics was explained and elaborated.
A list of possible metrics was provided.
2. Item # 2 – The specification of data gathering methods is not described. It is
unclear how the data will be gathered. The metrics were identified but not
how and where the data would be gathered.
3. Item #3 – The systematic review of crew scheduling data is implied in the
statements above. The analysis of work schedules, possibly using the biobehavioral models and scheduling tool is described in this section.
4. Item #4 – The utilization and assessment of accident data is clearly
addressed. The plan describes a systematic review of accidents and
incidents to assess the risk of fatigue as a contributing factor. While the
actual number and frequency of these meetings is not described, it is clear
that the plan includes this component. Additional detail is needed to fully
evaluate the extent to which guideline will be followed or used.
5. Item #5 – It is clear that this item was not included in the plan. Most likely
this was an oversight. The CP plan specifies the collaboration with TCRP, but
18

 this is not mentioned in the evaluation section. It is unclear when, how often
and who will be invited. Future plans might include the membership of the
committees and the likely officials in attendance However, some additional
detail, such as the Charter, charge, or minutes of the committee meetings
would be helpful in order to evaluate the effectiveness of the plan.
6. Item #6 - It is clear that this is desired and it is well stated in the introduction.
However, it is unclear when, where and how often it will occur.
7. Item #7 - The use of bio behavioral models is clearly identified. However, it
is unclear as to what frequency and whether they will be used before or after
problems are identified.
8. Item #10 – Self-report data is clearly mentioned in the plan.

Conclusion
The FMP material provided by CP Rail shows a definite intent to comply with the
purpose and spirit of the Work/Rule and the FMP Guidelines. The document
supports the involvement of all key stakeholders and participants in the
development of the FMP. In addition, the FMP outlines the roles and responsibilities
and overall accountability of key personnel. The plan further specifies in a very
complete fashion all of the key components required in the recommended education
and training program. The FMP also describes a number of key alertness strategies,
scheduling practices, dealing with emergencies, and a systematic plan for reviewing
rest environments, an implementation plan and an evaluation plan. Most notable
was the fact that the plan obtained all of the possible points on the Education and
Training section. The plan could benefit from additional detailed descriptions and
supporting materials in several key areas. In general, the material in the plan
provided by CP Rail provides considerable information however; additional
information is needed to fully evaluate the plan.

19

 FMP Key Risk Factors Score Sheet
A.
C
C
C
C

B.
C

C
C

C

C

20

Education and Training
1 Sleep Hygiene
2 Diet Health & Lifestyle
3 Body Clock
4 Definitions of Fatigue & Alertness
5 Sleep Disorders
6 Stress Management
7 Sleep & Performance
8 Various Sleep Schedules
9 Countermeasures
10 Individual and Age Differences

Possib Extern
le
al
Score Rated
3
3
1
1
3
3
1
1
3
3
1
1
3
3
1
1
1
1
1
1
Sub-total
18
18

Scheduling Practices
The total length of the work shift is equal to 12
1 hours.
Employees have limited exposure to working
2 between the hours of 0000 and 0600.
Recovery periods permit opportunities Less than
3 six hours of continuous sleep in a 24-hour period.
Off-duty times permit reasonable recuperative
4 times.
Work time is limited to 64 hours in a seven day
5 period.
Recovery periods permit two consecutive nights
6 of sleep.
Twenty minute break periods are scheduled
7 approximately every 4 hours.
8 Work schedules are highly predictable.
9 Opportunities for napping exist.
When periods of wakefulness exceed 19
continuous hours sufficient Opportunity for sleep
10 is provided.
Sub-total

Score

Extern
al

3

3

1

1

1

1

3

1

3

2

1
1
2
1

2

3
19

1
11

 C.
C
C

D.
C

E.
C

C
C
C

C

F.
C
C

21

Dealing with Emergencies
Score
1 Definition of emergency situations
4
Provision of specialized considerations for extra
2 duty
4
Sub-total
8

4
2
6

Alertness Strategies (Identification of on-duty
Extern
strategies that are encouraged permitted.)
Score al
FMP should include a list of recommended and
1 approved alertness strategies.
5
5
1
2 Technological aids (alerters)
1
1
3 Napping strategies
1
1
4 Breaks
1
5 Checklists to stay alert.
1
6 Other communication strategies as needed.
1
1
7 Appropriate use of exercise
1
8 Use of light, sound, and temperature.
1
9
Sub-total
12
Extern
Environments
Score al
Standard policy for review of facilities
2
1
Certification of lodging
1
Sleep aids
1
Light reduction
2
2
Sound reduction techniques
2
2
Temperature controls
2
2
Exercise facilities
1
Eating facilities
1
Wake up policies - do not disturb
2
2
Location or proximity to tracks or switching
10 operations
1
Sub-total
15
9

Rest
1
2
3
4
5
6
7
8
9

Implementation Policies
1 General principles
2 General Plan
3 Local Plan
4 Risk Assessment

Extern
score
al
5
4
5
3
1
0
1
0

 C

5 Commitment to FMP Rule
Sub-total

G.
C
C
C
C
C

22

Evaluation of FMPs and CM Effectiveness
1 Specification of fatigue metrics
2 Specification of data gathering methods
3 Systematic review of crew scheduling data
4 Accident analysis
Opportunity for consultation (e.g. Employee
5 representatives; health and safety committees)
6 Systematic review of plan measurement data
7 Use of bio behavioral models (e.g. FAST)
10 Utilization of self-report data
Sub-total
Overall Score

3
15

3
10

2
2
2
2

2
0
1
2

2
1
1
1
13
100

0
1
1
1
8
61