When fatigue sits between Occupational Health and Operations, who owns the risk?
Updated: 6 days ago
The Rail Safety and Standards Board (RSSB), the independent safety, standards and research body for Great Britain’s railways, published a new technical note on 22 September 2026: TN3304 – Crossover health and safety fatigue risks.
The title may sound technical, but the issue it raises is an important and very practical one.
RSSB highlights the need to consider fatigue from both an occupational-health and operational perspective, ensuring that the crossover risk between departments is covered and communicated both ways
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The technical note specifically addresses the crossover between medical and operational fatigue assessments for safety-critical workers.
It raises a question I think is worth asking:
When fatigue sits between Occupational Health and Operations, who actually owns the risk?
Fatigue rarely fits neatly into one department
Consider an employee who reports persistent tiredness or difficulty sleeping.
That could quite reasonably lead to an Occupational Health referral.
There may be an underlying sleep disorder, medication, health condition or other individual factor that needs appropriate assessment and support.
But what if that is only part of the picture?
What if the employee is also working changing shift patterns, regularly waking very early, travelling significant distances to work, undertaking night work, working on-call, experiencing high workload or finding that work continues to occupy their thoughts long after the shift has finished?
Those are not simply individual health issues.
They begin to involve the way work is organised and managed.
The opposite situation can happen too.
Operations may identify someone as fatigued or determine that a roster presents an increased fatigue risk. Working hours may be reviewed, rostering controls checked and fatigue-management arrangements followed.
But does that tell us why that particular employee is struggling to recover?
Possibly not.
This is why the crossover highlighted by TN3304 matters.
Time away from work and recovery are not the same thing
One of the assumptions we need to be careful about when managing fatigue is that providing sufficient time away from work automatically means sufficient recovery has occurred.
It creates an opportunity for recovery.
It doesn't guarantee it.
An employee can have what appears on paper to be an adequate period between duties and still return insufficiently recovered.
There can be many reasons.
The timing of the shift matters. Night work and very early starts interact with human circadian biology differently from daytime work.
The journey home matters.
The timing and quality of sleep matter.
What happened during the previous series of shifts matters.
Workload matters.
Domestic and caring responsibilities can matter.
And psychological recovery can matter too.
Someone may have physically left work but still be mentally dealing with an unresolved operational problem, worrying about tomorrow, replaying a difficult incident or thinking about responsibilities they cannot simply switch off.
Chronologically off duty. Psychologically still at work.
Looking only at the number of hours between shifts can therefore give us an incomplete picture of recovery opportunity.
Identifying fatigue is only the beginning
Rail has well-established processes for controlling fatigue risk, and RSSB's existing RS504 good-practice guide describes fatigue as something that should be systematically managed within an organisation's wider safety-management arrangements.
RSSB began a formal review of RS504 during 2026, and TN3304 will eventually be withdrawn when the revised RS504 is published.
But there is an important distinction between detecting fatigue and understanding what is causing it.
If someone is fatigued, we have identified an outcome.
We have not necessarily identified the cause.
That distinction matters because different causes require different controls.
If the primary issue is an untreated sleep disorder, the appropriate response may involve medical assessment and individual support.
If repeated early starts are creating insufficient sleep opportunity, the issue may sit within roster design.
If excessive workload routinely extends into recovery periods, reducing workload or redesigning work may need consideration.
If long journeys are reducing realistic recovery time, travel arrangements may need examining.
If employees understand sleep and fatigue very well but organisational conditions make adequate recovery difficult, providing more sleep-awareness training will not remove those conditions.
The control needs to match the cause.
So who joins the dots?
This is where fatigue can become an organisational rather than departmental issue.
Occupational Health may hold one part of the picture.
Operations another.
Safety may have fatigue-risk information.
Managers may know how the work is actually being done.
The individual employee knows what happens when they leave work and whether they are actually recovering.
Each perspective can be valid while still being incomplete.
The management challenge is therefore not simply deciding which department “owns” fatigue.
It is ensuring that relevant information can come together sufficiently for the organisation to understand the risk and act on it.
For rail organisations, TN3304 prompts some useful questions.
1. When fatigue is identified, do we investigate what is contributing to it?
Knowing somebody is fatigued is important.
Understanding whether the main contributors are medical, operational, organisational, individual — or a combination — is what helps determine an appropriate response.
2. When does an individual concern become an organisational signal?
One employee struggling with fatigue may require individual support.
Several employees experiencing similar problems on the same shift pattern, route, location, project or type of work could indicate something different.
Patterns matter.
An effective fatigue-management system needs to be capable of recognising when individual cases may be revealing a wider condition of work.
3. Are Occupational Health and Operations seeing different parts of the same problem?
Departments naturally view issues through their own professional lens.
The question is whether the organisation has sufficient mechanisms for relevant fatigue information to cross those functional boundaries and inform risk management.
4. Are we measuring recovery opportunity or simply time away from work?
A roster can be compliant while still creating difficult recovery conditions.
That does not make working-time controls unimportant. They are fundamental.
It means they are one part of a wider assessment.
We also need to understand what happens within the recovery opportunity that has been provided.
5. Are our controls addressing causes or mainly managing consequences?
Fatigue-awareness training, reporting systems, medical support and individual advice can all have an important role.
But where an organisational condition is contributing to fatigue, the next question should be whether that condition can be removed, reduced or better controlled.
That might mean examining work design, workload, rostering, shift timing, travel, staffing, management practices or another source of fatigue exposure.
Fatigue management works best when the whole system can see the problem
What I find particularly useful about TN3304 is not simply that it brings Occupational Health and operational fatigue assessment together.
It reminds us that fatigue does not respect organisational boundaries.
People experience the combined effect of their work, their biology, their health, their circumstances and their opportunity to recover.
An organisational structure may divide those issues between Occupational Health, Operations, Safety, HR and line management.
The individual experiences all of them at once.
That makes crossover important.
Effective fatigue management therefore requires more than identifying whether somebody is tired or whether working-hour controls have been met.
It requires enough curiosity to ask:
What is causing this person, team or workforce to become fatigued — and what can we change to reduce that risk?
Sometimes the answer will sit with the individual.
Sometimes it will sit within the way the work is designed.
Very often, it may involve both.
Finding that out is where meaningful fatigue management begins.
Link to RSSB TN3304 Iss 1
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