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The following is a quote from the accident report of the Iowa crash.  It gives a lot of insight into the concern of the NTSB.  From work load to cognitive demand; and from lighting, temperature, noise level, caffeine, to adrenaline changes due to stressors; and from time pressure, social friction to monotony and repetitive motion-- the NTSB is leaving no stone unturned.       The NTSB is aware, however, of some general limitations regarding the use of these models. For instance, in general, biomathematical models have been calibrated to represent a population average rather than real-time fatigue levels of a specific NTSB Railroad Accident Report 50 individual.62 It is unclear how individual differences (such as age, sex, and operating experience) may affect the output of these models. Additionally, biomathematical fatigue models predict risk factors for an average healthy person; thus, the output may not accurately predict the risks to a crewmember who may have medical conditions or otherwise not be fully fit for duty. The NTSB further recognizes that biomathematical models may not consider all factors affecting fatigue such as workload (mental or physical, high or low cognitive demand), the operating environment (including lighting, temperature, and noise level), and pharmacological agents, for example, caffeine and changes in adrenaline levels due to stressors. Other factors that may not be represented in biomathematical models include stressors in the workplace (that is, time pressure, social friction) and aspects of the work (such as monotony and repetitive motion).63 Studies have pointed out the need for additional research to determine whether one or more of these work-related factors are important alone or in interaction with sleep/wake cycles and circadian dynamics, especially for risk-focused models.64 The NTSB notes that several studies have concluded that fatigue model predictions cannot be the sole means upon which fatigue risk management operational decisions are made.65 The NTSB concludes that because biomathematical models of fatigue are relatively new to the railroad industry, the use of this technology should be evaluated for its effectiveness within the context of railroads‘ fatigue management plans through independent scientific peer review. Therefore, the NTSB recommends that the FRA establish an ongoing program to monitor, evaluate, report on, and continuously improve fatigue management systems implemented by operating railroads to identify, mitigate, and continuously reduce fatigue-related risks for personnel performing safety-critical tasks, with particular emphasis on biomathematical models of fatigue.
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