Fatigue Risk Management: River and Port Pilots

Fatigue Risk Management: Addressing NTSB Recommendations

Over the past few years CIRCADIAN® has helped river and port pilot associations address fatigue risk in their 24/7 operations. This has included fatigue training, conducting fatigue studies, and testifying before state commissions to support requests for increased rates to ensure good quality pilot sleeping accommodations, and pilot complement levels that are adequate to meet increasing demand for piloting services.

Now the NTSB, as a result of attributing the Eagle Otome collision in the Sabine-Neches Canal to pilot fatigue, has urged state governors to “require local pilot oversight organizations that have not already done so to implement fatigue mitigation and prevention programs that 1) regularly inform mariners of the hazards of fatigue and effective strategies to prevent it, 2) promulgate hours of service rules that prevent fatigue from extended hours of service, insufficient rest within a 24-hour period an disruption of circadian rhythms”

CIRCADIAN® (www.circadian.com) the global leader in fatigue risk management systems (FRMS) has helped marine pilots and many other industries develop and implement fatigue risk management systems, which enable them to avoid the burden of excessive government hours of service regulation. For example we recently helped the petrochemical industry develop an FRMS standard (ANSI/API 755) which removed the threat of government hours of service regulation following the Texas City refinery explosion where the US Chemical Safety Board identified operator fatigue as a major causal factor.

The NTSB recommendations provide clear notice to all pilot associations that the issue of fatigue needs to be promptly addressed in a systematic and comprehensive manner. CIRCADIAN® would be pleased to work with your pilot association to:

  1. Plan, develop and implement a comprehensive Fatigue Risk Management System (FRMS) tailor made to protect the integrity our your own operations
  2. Provide fatigue training through classroom, or online programs for pilots, dispatchers and other support staff.
  3. Undertake a piloting/staffing analysis to support pilot fee negotiations to fund the hiring of additional pilots, where necessary, to reducing the risk of pilot fatigue
  4. Develop FRMS based scheduling rules that do not disrupt piloting service delivery but provide safeguards against excessive fatigue risk.
  5. Implement sleep apnea screening and treatment programs.
  6. Assess pilot house accommodations to ensure they are designed to mitigate fatigue risk and maximize rest/sleep opportunities while on-call.

For more information about FRMS planning and/or implementation:

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  • Phone: 781-439-6300

Personal Care

Personal Care

Worldwide demand for quality products on which consumers rely requires a special attention to the workforce to ensure standards are maintained twenty-four hours a day.

How CIRCADIAN can help you:

  • Staffing Level Analysis. Using advanced analysis techniques, CIRCADIAN can identify the optimal staffing levels for your operation taking into account the fluctuations in demand that are inherent in the food industry.
  • Shift Schedule Optimization. CIRCADIAN works with both managers and employees to identify a set of ideal schedule solutions to meet business and family/social needs.
  • Fatigue Risk Management Systems. Comprehensive fatigue management programs will map out the course of action to maintain high safety standards while reducing costs associated with fatigue-related errors and incidents.
  • Managing a Shiftwork Lifestyle. These programs assist shiftworkers with managing their personal health, which will help minimize healthcare costs.
  • 24/7 Workplace Evaluation and Design. CIRCADIAN’s expert researchers can assess the impact of the work environment and identify the best means of maintaining alertness for the workforce.

For more information about our Process Manufacturing Solutions:

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  • Phone: 781-439-6300

Pipeline Controller Workload Assessment Program

Meeting DOT/PHMSA CFR 49 Part 195.446(e)(5)


Over the past few years, CIRCADIAN has worked with many Pipelines as they have implemented the fatigue mitigation portion of the PHMSA regulation for control room management.

In recent months, several of our pipeline clients have struggled with Part 195.446(e)(5), and As a result, CIRCADIAN® has adapted a program that uses the NASA-TLX task load analysis to assist pipeline control rooms in complying with this part of the regulation.

The PHMSA control room management regulation (195.446(e)(5)) requires pipeline control rooms to “Monitor the content and volume of general activity being directed to and required of each controller at least once each calendar year, but at intervals not exceeding 15 months, that will assure controllers have sufficient time to analyze and react to incoming alarms…”  Guidance from subsequent FAQ E5-1a from PHMSA indicates that the process for determining workload must “have a sufficient degree of formality and documentation.  Controllers might implement this requirement by means of a job task analysis (JTA), formal workload study or other means.”  The FAQ also indicates that the analysis should incorporate potential differences in activity levels for different days of the week as well as different shifts.  Further, the monitoring should include tasks such as manual calculations, alarms, phone calls, training, etc.


Workload is a term that represents the cost of accomplishing a task for the controller. It reflects the interaction of such elements as task and system demand, controller processing capabilities and effort, subjective performance criteria, controller information processing behavior and strategies and finally controller training and prior experience. There is a clear need for the assessment of workload in complex jobs in order to avoid placing excessive demands on the controllers. The principal dimensions of workload include a time-based factor, a factor caused by the intensity of the demand for attentional resources (related to task difficulty) and a final factor attributed to the controller’s psychological/physiological state (e.g., anxiety, motivation, fatigue, consequence of failure).

Different techniques for the measurement of workload are available, including subjective ratings, performance measures and physiological measures.  Subjective procedures are based on the individual’s evaluation of the workload associated with a task. Performance-based techniques measure workload through the capability of the individual to perform a task. Physiological measures, such as the electrocardiogram, evaluate the physiological response of the individual to a task. In addition to these standard methods, some researches have included in their analysis data from the actual work that the individual performs.

The measurements need to be sensitive to the level and type of demand the task presents to the controller. To be applicable in real work situations, they need to be easy to administer as well as not interfering with the work demands. Subjective measures offer an easier and less time-consuming method than most of the performance and physiological measures.  Among the subjective scales, NASA Task Load Index (NASA-TLX)1  has been widely used in different environments, including control rooms2.

NASA Task Load Index (NASA-TLX)

The NASA Task Load Index (NASA-TLX ) is a multi-dimensional scale with six subscales: mental demand, physical demand, temporal demand, effort, performance and frustration. It assumes that a combination of these elements is likely to represent the workload experiencing by most people performing most tasks. To develop an overall workload score each subscale rating is multiplied by the appropriate weight. The weights are calculated by requiring the individual to choose which component of each paired combination of the six dimensions (subscales) is more related to their personal definition of workload.


The complete analysis will incorporate both evaluation of the subjective workload and evaluation of the operational and environmental work conditions.

The measurements will include:

  • NASA Task Load Index (NASA-TLX )
  • Diagnostic employee survey completed by the controllers, evaluating the tasks performed, the work environment and factors that may affect perceived workload (sleep deprivation, health issues, etc.)
  • Objective evaluation of controllers’ tasks (response to alarms, phone calls, etc), using company data

Collecting these different types of data will allow a more accurate analysis of how factors such as fatigue, circadian rhythms as well as experience of the individual controller affect the subjective workload.  It will also allow investigation of the relationship between objective and subjective workload.


The deliverables for any contracted portion of the proposal will include:

  • Fully documented report that will include all analyses, charts/graphs, and recommendations. 
  • One to two days on-site for instruction on completing the TLX forms, the survey (if elected), and gathering the operational data (i.e. alarms, calls, etc. if selected).

Next Steps

If you have questions, or would like to receive a quote for implemmenting CIRCADIAN's Workload Assessment Program to meet the regulation, please:

  • Fill-Out a contact form by clicking here.
  • Call 781-439-6300
  • Email: This email address is being protected from spambots. You need JavaScript enabled to view it.


1) Hart SG, Staveland LE. 1988. Development of NASA-TLX (Tasks Load Index): results of experimental and theoretical research. In: Hancock PA, Meshkati N (eds.) Human mental workload. North-Holland. Amsterdam.pp. 139-183.

2) Lang AW, Roth EM, Bladh K, Hine R. 2002.Using a benchmark-referenced approach for validating a powerplant control room: results from the baseline study. Proceedings of the 46th Annual meeting of the Human Factors and ergonomics Society. Santa Monica, CA:HFES. 1878-1882.



Providing education and programs for shiftworkers is an essential part of any fatigue management program.  Shiftworkers must have the tools, policies and education to manage their daily work and home lives to ensure that they come to work alert and well rested, as well as return home safely.  At the same time, employees must have the support of their managers and supervisors to be able to take full advantage of the alertness enhancing strategies.  Situations where employees do not have this kind of support can negate any potential improvements.  At a tank truck operation in the Southern United States, both employees and managers were trained on the methods for managing and minimizing fatigue.  Particular attention was given to train and educate the dispatchers of the operation, who ultimately set the driver schedules and workload.

Over the course of several months, CIRCADIAN® provided education on managing fatigue and how to develop dispatches that would provide drivers with the best opportunity to minimize their fatigue.  Using Circadian's proprietary software – the CIRCADIAN® Alertness System (CAS) - in combination with our consulting expertise the frequency and severity of accidents was greatly reduced.:

  • Managers and dispatchers in the trucking operation were provided with monthly analyses of the fatigue scores for every driver
  • Dispatchers were educated on how they could reduce CAS fatigue scores by adjusting the timing and duration of daily and weekly work and rest patterns
  • Senior management implemented a policy that made every dispatcher and terminal manager personally accountable for the monthly CAS fatigue scores of the drivers who reported to them.


  • A reduction in CAS fatigue score correlated with a reduction in the number and severity of accidents.
  • The total number of truck accidents dropped 23.3% from an average rate of 2.30/million miles for the three years prior to the intervention, to 1.76/million miles for the following year when CAS fatigue score management was instituted.
  • The average cost per accident dropped 65.8% from $14,088 to $4,820.
  • Severity accidents (over $20,000 cost) dropped 55% from an average rate of 0.20 /million miles to 0.09 / million miles.
  • Average cost of the severity accidents dropped 66.7% from $152,384 + per accident to $50,809 per accident over the same time frame.
  • The total cost for loss of attention accidents (defined as collisions, hit rear of another vehicle, loss of control) dropped 80.9% from $1,187,699/year to $226,627/year).

Moreover, driver retention was greatly reduced; turnover dropped from an unmanageable 107% to 69%.  This was in large part due to a better relationship between drivers and dispatchers as well as a driver dispatch schedule that was much more manageable for the driver’s work and home life.