Rail · NR/L2/OHS/003 · ORR · HSE FRI
Fatigue management for rail operators and contractors
NR/L2/OHS/003 mandates FRI-based fatigue assessment for all workers on Network Rail infrastructure. The thresholds are published. The compliance date has passed. Train operators sit under a different framework, set out further down. Here is what a conforming system looks like for both.
The published NR/L2/OHS/003 action thresholds
These are the thresholds specified in the standard. Exceeding them requires documented additional controls - not just awareness.
Source: NR/L2/OHS/003 FRI module. The FRI risk score of 1.6 is a separate output of the HSE RR446 algorithm representing relative risk of errors compared to a baseline shift.
Score one duty against these figures now, free and without signup, on the rail fatigue calculator, which opens on the NR/L2/OHS/003 profile, or print the roster checklist.
Supply chain scope: this applies to contractors, not just Network Rail staff
NR/L2/OHS/003 now covers the entire Network Rail supply chain - not just directly employed staff. If your company places workers on Network Rail infrastructure for any purpose, including engineering, maintenance, signalling, or civils, those workers are within scope. Principal contractors are responsible for ensuring their supply chain meets the standard.
The regulatory framework
The Network Rail fatigue standard
Network Rail's fatigue risk management standard adopts a modular approach. The FRI module is mandatory for anyone managing staff with safety-critical competencies or who drive as part of their duties. The standard was developed over two years, with a final compliance date of October 2022. The scope was subsequently extended: the previous standard covered safety-critical workers only; the current framework applies to all workers across the Network Rail supply chain.
Office of Rail and Road enforcement
The ORR is the independent safety and economic regulator for Britain's railways. ORR's guide to managing rail staff fatigue sets out its expectations for duty holders under the Railways and Other Guided Transport Systems (Safety) Regulations 2006. ORR expects a work pattern to be assessed against its published fatigue factors, using a fatigue assessment tool alongside them and understanding that tool's limitations. ORR is explicit that it does not compel, endorse or advocate the use of any one tool over another.
The duty holder obligation
Under the Railways and Other Guided Transport Systems (Safety) Regulations 2006, infrastructure managers and train operators must manage all foreseeable risks to safety, including fatigue risk. The Safety Management System must demonstrate how fatigue is identified, assessed, and controlled. An SMS that references fatigue risk without a scoring methodology to back it up is unlikely to satisfy an ORR inspection.
Train operators: a different framework
Network Rail's standard governs work on the infrastructure. It does not govern how a train operating company builds its traincrew rosters. There, the framework is ORR's guidance supporting regulation 25 of ROGS, and it asks for something broader than an index.
What ORR actually expects
Three things used together, not one tool used alone. A work pattern assessed against ORR's published fatigue factors. A bio-mathematical tool, used with its limitations understood. And feedback from the people working the pattern. ORR does not endorse any particular tool.
What changed in January 2026
RAIB reported on a buffer stop collision at London Bridge where the driver experienced a microsleep. It found that relying on the fatigue and risk index alone to assess a base roster is not in line with ORR good practice, and that the roster contained six ORR fatiguing factors. Its recommendation covered roster design, the limitations of bio-mathematical models, and the monitoring and control of rest day and extended hours working.
Planned hours are not enough
RSSB guidance cited in the same report calls for reviewing fatigue risk against hours actually worked, not planned hours alone. RotaPulse scores both when it has them, and shows the gap between the two.
For a base roster, that means every duty checked against the ORR fatigue factors before the roster is published rather than after an incident, rest day working and extended hours tracked as their own risk rather than buried in a weekly total, actual hours compared against planned so the divergence is visible, and an exportable record of what was assessed, when, and by which version of the method. RotaPulse is decision support for the people who design and approve rosters. It does not certify compliance, and it does not replace the judgement of a competent person.
What a conforming system looks like
NR/L2/OHS/003 does not specify which software to use. It requires that you use a recognised tool, apply the published thresholds, document the results, and have a response process for scores that exceed them. A spreadsheet, provided it implements the RR446 algorithm correctly and produces auditable records, is technically conforming. In practice, an unversioned spreadsheet with no audit trail will not satisfy a principal contractor or an ORR inspector.
A conforming system needs: correct FRI algorithm implementation, version control on the scoring engine, dated records for each scored roster, plain-English documentation of flags raised and actions taken, and an exportable PDF for SMS evidence files.
How RotaPulse helps
FRI scoring at the correct thresholds
RotaPulse scores against the HSE RR446 method, with component weights published on the methodology page, and applies the NR/L2/OHS/003 thresholds: amber at FI 22, red at FI 40 for generic profiles; configurable to 35/45 for rail-specific compliance. Every score is reproducible and stored with the engine version.
Plain-English flags managers can act on
Instead of a raw FI score, your shift supervisor sees: Night shift after 9 hours rest, Seventh consecutive shift, Post-night shift start too early. These map directly to the violation types NR/L2/OHS/003 expects you to control.
PDF compliance evidence for ORR audits
Export a dated PDF for any period. It shows each worker's FRI scores, the flags raised, and the engine version. This is the documented evidence your SMS needs to demonstrate fatigue is being actively assessed.
Supply chain roster scoring
Upload rosters from any scheduling system as a CSV or XLSX, or connect a rostering system directly through the API. Score an engineering possession team's week before they go on site - in under a minute.
Swap check before the swap is signed off
When a cover request or shift swap lands, score the proposed shift against the worker's previous 21 days, so whoever approves it can see what it does to the pattern. It informs the decision, it does not make it. It checks the pattern, not the person: rest gap, cumulative load, consecutive nights. Not a fitness-for-duty verdict.
Walk away with the fixed rota
The solver proposes the smallest change to each flagged shift; you accept or reject each one, and RotaPulse rebuilds the week with your accepted changes applied and every shift re-scored. Download the corrected roster as a CSV and hand it back to your planner.
What RotaPulse does not do
RotaPulse scores against the HSE RR446 method with published component weights. It does not replace a human fatigue risk assessment for specific possession scenarios, substitute for a qualified fatigue specialist review on complex engineering blockades, or guarantee NR/L2/OHS/003 conformance. It provides the scored, versioned, exportable evidence that your SMS documentation requires. Threshold configuration for the rail-specific 35/45 levels is available on the Growth plan and above.
Score your next possession roster before it goes on site
Free plan covers one week for up to 10 workers. No credit card. Upload a CSV and you have FRI scores in under a minute.