The national president of the Brotherhood of Locomotive Engineers and Trainmen union in a September letter claimed that unpredictable work schedules is causing fatigue among railroad workers.

Dennis Pierce, in a Sept. 22 letter to railroad CEOs and federal officials, warned about railway safety issues such as locomotive engineers “being forced by threat of an attendance policy violation to work when fatigued, even though such safety-critical locomotive engineers honesty believe that working in such circumstances would jeopardize safety.”

Pierce said the main cause of fatigue is variable work schedules, which result in unpredictable and inconsistent patterns of awake and sleep time for engineers. He said the variable schedules and punitive attendance policies are violations of the Federal Rail Safety Act by forcing employees to work in unsafe conditions.

“I strongly urge you to instruct your managers to allow locomotive engineers who find themselves fatigued to lay off due to that fatigue without fear of disciplinary retaliation,” Pierce wrote. “It is clear that if forced to work when fatigued by no fault of their own, they will be jeopardizing their own safety as well as the safe operation of the trains to which they are assigned, which in turn directly endangers the safety of the general public and their co-workers.”

A February 2013 report by the U.S. Department of Transportation on the fatigue status of the railroad industry looked at logbook surveys from different railway workers to examine the relationship between work schedules and sleep patterns.

The report found that the sleep pattern of railroad workers differs from that of U.S. working adults. Railroad workers are more likely to get less than seven hours total sleep on workdays, which potentially puts them at risk of fatigue.

The report pointed out that passenger train and engine service workers have a pattern of work similar to that of the other train and engine service work groups, but have the least exposure to fatigue. The primary difference between the passenger service employees and other train and engine service workers is predictability of work, the study notes.

“The predictability of work allows passenger [train and engine service] workers to plan sleep better to avoid fatigue,” the study says. “This suggests that improving the predictability of work schedules is one way to reduce fatigue exposure in the railroad industry.”

According the report, fatigued crews can increase the risk of accidents from 11 to 65 percent.

“It is clear that fatigue increases the risk of [human factor accidents] and that more fatigue results in more risk,” the report states.