Frequently Asked Questions About Managing Fatigue - 10 CFR 26.211 - Fatigue Assessments

• Fatigue Assessments
  • Q1. What are the training requirements for a person who performs a fatigue assessment? The rule says only that the person performing the assessment must be trained under 26.209 and 26.23 are allowed to perform fatigue assessments. Neither of these describes fatigue assessment specific training requirements.
  • Q2. Please define the term "qualification" as it applies to an assessor. In other words, what in the eyes of the NRC constitutes qualification?
  • Q3. I'd like to see some discussion of details surrounding waivers and fatigue assessments. There seems to be some question as to whether the face-to-face assessment required before issuing a waiver is the same thing as the fatigue assessment that is required for cause/post-incident.
  • Q4. How will 26.31(b)(1)(ii), which provides general requirements for who may perform assessment or evaluation procedures, apply to fatigue assessments?

Fatigue Assessments

Q1. What are the training requirements for a person who performs a fatigue assessment? The rule says only that the person performing the assessment must be trained under 26.209 and 26.23 are allowed to perform fatigue assessments. Neither of these describes fatigue assessment specific training requirements.

Correct, there are no additional rule based training requirements for the individuals performing fatigue-assessment.

Q2. Please define the term "qualification" as it applies to an assessor. In other words, what in the eyes of the NRC constitutes qualification?

Simply stated, there are no additional training requirements for a fatigue assessor other than the required general training. The supervisor performing the fatigue assessment shall be qualified to direct the work to be performed by the individual. If there is no supervisor on site who is qualified to direct the work, the assessment may be performed by a supervisor who is qualified to provide oversight of the work to be performed by the individual.

Q3. I'd like to see some discussion of details surrounding waivers and fatigue assessments. There seems to be some question as to whether the face-to-face assessment required before issuing a waiver is the same thing as the fatigue assessment that is required for cause/post-incident.

A fatigue assessment is performed for cause, after a self-declaration, post-event, and as follow-up. These are generally after the fact and the assessment should be designed to address the circumstance for which the assessment is needed. An assessment required to grant a waiver is predictive. The allowance to perform a predictive fatigue assessment acknowledges there are individual differences regarding the onset of fatigue. It is also acknowledged that once onset, the same performance degradations will be seen in all individuals. Therefore a predictive assessment should not simply try to understand if the person is currently fatigued (as a for cause assessment might) but that the person will not become fatigued over the work period in question.

Q4. How will 26.31(b)(1)(ii), which provides general requirements for who may perform assessment or evaluation procedures, apply to fatigue assessments?

10 CFR 26.31(b)(1)(ii) does not apply to fatigue assessments. Like all of 10 CFR 26.31, this section applies only to drug and alcohol testing. By contrast, Section 26.211(b) specifies those individuals who may and may not perform fatigue assessments, Section 26.211(b)(1) provides the requirements regarding for-cause fatigue assessments, and Section 26.211(b)(2) provides the requirements for who may perform post-event fatigue assessments.

Note: The information herein is provided as a public service and solely for informational purposes and is not, nor should be deemed as, an official NRC position, opinion or guidance, or "a written interpretation by the General Counsel" under 10 CFR 26.7, on any matter to which the information may relate.  The opinions, representations, positions, interpretations, guidance or recommendations which may be expressed by the NRC technical staff responding to your inquiry are solely the NRC technical staff's and do not necessarily represent the same for the NRC.   Accordingly, the fact that the information was obtained through the NRC technical staff will not have a precedential effect in any legal or regulatory proceeding.