NEI 06-11 [Revision 2] 

Managing Personnel 

Fatigue at Nuclear Power 

Reactor Sites 

April XXXXXX 20142016

Nuclear Energy Institute, 1776 I Street N. W., Suite 400, Washington D.C. (202.739.8000) 

NEI 06-11 [Revision 2] 

Nuclear Energy Institute 

Managing Personnel 

Fatigue at Nuclear Power 

Reactor Sites 

April XXXXXX 20142016
ACKNOWLEDGEMENTS 

This document, Managing Personnel Fatigue at Power Reactor Sites, NEI 06-11, was developed 

by members of the NEI Work Hours Task Force. These industry professionals, experts on access 

authorization programs, drawing upon practical lessons learned during the application of the 

previous requirements, provided valuable insights to update the program. The changes provide a 

more efficient and effective program. Additionally, NEI also wishes to acknowledge the 

extensive review and comment by those industry representatives who shaped this current 

revision of this document: 

Greg Halnon First Energy 

Lee Marabella PSE&G 

Frank Mascitelli Exelon 

Eddie Humphries Duke 

Jayne Pearson Wolf Creek 

Tom Miller First Energy 

Elizabeth Murtha Areva 

Jack Heyer IBEW 

Jim Wheeler Dominion 

Billie Rooks Southern Nuclear 

Nick Pappas NEI 

NOTICE 

Neither NEI, nor any of its employees, members, supporting organizations, contractors, or 

consultants make any warranty, expressed or implied, or assume any legal responsibility for the 

accuracy or completeness of, or assume any liability for damages resulting from any use of, any 

information apparatus, methods, or process disclosed in this report or that such may not 

infringe privately owned rights. 
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EXECUTIVE SUMMARY 

This document provides guidance for managing fatigue in accordance with 10 CFR 26, Subpart 

I, Managing Personnel Fatigue. The goals of this guide are to provide the tools needed to meet 

regulatory requirements while: 

x Maintaining reasonable assurance of industrial and nuclear safety. 

x Recognizing that a wide variety of work situations exist across the industry. 

x Supporting management flexibility and decision making when unplanned work is 

required. 

x Providing the records needed to allow the required performance evaluations to be 

performed efficiently. 

x Clarifying the rights and responsibilities of licensees and workers. 

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TABLE OF CONTENTS 

EXECUTIVE SUMMARY ........................................................................................................ i 

1 INTRODUCTION AND BACKGROUND .......................................................................... 1

1.1 INTRODUCTION AND BACKGROUND ...............................................................................1

1.2 BACKGROUND .................................................................................................................1

1.3 OVERVIEW OF FATIGUE MANAGEMENT ........................................................................2

TABLE 1: OTHER PART 26 SECTIONS APPLICABLE TO FATIGUE MANAGEMENT ................3

2 SCOPE (26.201) ........................................................................................................... 5

2.1 GENERAL APPLICATION .................................................................................................5

2.2 PERSONNEL SUBJECT TO FATIGUE MANAGEMENT .......................................................5

2.3 WORK HOUR CONTROLS ...............................................................................................5

TABLE 2A: SUBPART I REQUIREMENTS FOR DIFFERENT CATEGORIES OF INDIVIDUALS **6

TABLE 2B: INDIVIDUALS SUBJECT TO WORK HOUR CONTROLS (26.205(A)) ......................8

3 DEFINITIONS ................................................................................................................ 9

4 POLICY AND PROCEDURES (26.203) ....................................................................... 15

4.1 POLICY ........................................................................................................................15

4.2 PROCEDURES ................................................................................................................15

5 MANAGING FATIGUE (26.203) .................................................................................. 18

5.1 INDIVIDUAL SUBJECT TO FATIGUE MANAGEMENT .....................................................18

5.2 REQUIREMENTS ............................................................................................................18

6 WORK HOUR CONTROLS (26.205) ........................................................................... 19

6.1 INDIVIDUALS SUBJECT TO WORK HOUR CONTROLS ..................................................19

6.2 WORK HOUR SCHEDULING REQUIREMENTS AND PRINCIPLES (26.205 (C)) ..............22

6.3 WORK HOUR CONTROLS .............................................................................................23

6.3.1 Applying Work Hour (Ceiling) Limits .......................................................23

6.3.2 Applying Break Requirements ....................................................................23

6.4 METHODS OF WORK HOUR CONTROLS ......................................................................24

6.4.1 Minimum Days Off (MDO) ..........................................................................24

6.4.2 Maximum Average Work Hours (MAWH) aka On Line Averaging 

Method ...........................................................................................................26

6.5 DEVIATIONS AND COMPLIANCE ...................................................................................26

7 COUNTING WORK HOURS AND BREAK TIME (26.205) ........................................... 27
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7.1 PROCESS FOR EVALUATING A SCHEDULE ....................................................................27

7.2 ACCOUNTING OF WORK HOURS ..................................................................................28

7.3 DAYS OFF ......................................................................................................................32

TABLE 7: WHAT TO INCLUDE/EXCLUDE WHEN CALCULATING WORK HOURS ................34

8 APPLICATION OF MINUMUM DAYS OFF (MDO) AND/OR MAXIMUM AVERAGE 

(MAWH) WORK HOURS ALTERNATIVE (26.205 (D)(3),(D)(7)) .................................. 36

8.1 GENERAL INFORMATION ..............................................................................................36

8.2 MINIMUM DAYS OFF (MDO) METHOD .......................................................................37

8.2.1 Unexpected Outages .....................................................................................41

8.3 MAXIMUM AVERAGE WORK HOURS (MAWH) ..........................................................41

8.4 OUTAGE SPECIFIC GUIDANCE – WORK HOUR CALCULATIONS .................................43

9 EXAMPLES OF APPLYING ALL WORK HOUR CONTROLS (26.205) ........................ 45

9.1 GENERAL WORK HOUR REQUIREMENTS ....................................................................45

TABLE 9A: WORK HOUR CONTROLS – NORMAL OPERATIONS ..........................................46

TABLE 9B: WORK HOUR CONTROLS – OUTAGES ...............................................................48

TABLE 9C: APPLYING EACH CONTROL – WORK HOUR LIMITS AND REST BREAK 

REQUIREMENTS ............................................................................................................50

TABLE 9D: APPLYING EACH CONTROL – MDO AND MAWH REQUIREMENTS ................52

10 TRANSITIONS ............................................................................................................. 56

10.1 TYPES OF TRANSITIONS ................................................................................................56

TABLE 10: TRANSITIONS OUT OF AN OUTAGE ....................................................................59

11 WAIVERS (26.207) .................................................................................................... 60

11.1 INTRODUCTION .............................................................................................................60

11.2 APPLICABILITY .............................................................................................................60

11.3 WAIVER PROCESS .........................................................................................................60

11.4 SUPERVISORY ASSESSMENT FOR WAIVER OF REGULATORY WORK HOURS 

CONTROLS ....................................................................................................................62

11.5 SEQUESTRATION ...........................................................................................................63

TABLE 11A: WAIVER PROCESS ............................................................................................65

TABLE 11B: WAIVERS AND EXCEPTIONS TO WORK HOUR CONTROLS .............................67

12 SELF DECLARATIONS (26.209) ................................................................................. 69

12.1 APPLICABILITY AND GENERAL PROVISION .................................................................69
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12.2 SELF-DECLARATIONS DURING EXTENDED WORK HOURS UNDER WAIVER .............69

TABLE 12: SELF-DECLARATION PROCESS ...........................................................................70

13 FATIGUE ASSESSMENTS (26.211) ............................................................................ 71

13.1 INTRODUCTION .............................................................................................................71

13.2 CONDITIONS REQUIRING FATIGUE ASSESSMENT ........................................................71

13.3 FATIGUE ASSESSMENT ATTRIBUTES ............................................................................73

13.4 REQUIRED INFORMATION ............................................................................................74

13.5 PROCESS FOR CONDUCTING FATIGUE ASSESSMENT ...................................................74

TABLE 13A: FATIGUE ASSESSMENT PROCESS .....................................................................76

TABLE 13B: “SUPERVISORY ASSESSMENT OF FITNESS” FOR WAIVERS VS. “FATIGUE 

ASSESSMENT” ...............................................................................................................78

14 TRAINING AND EXAMINATIONS ............................................................................... 79

15 RECORDS ................................................................................................................... 80

TABLE 15: DOCUMENTS, REPORTS, AND REVIEWS REQUIRED UNDER SUBPART I ............81

16 REVIEWS.................................................................................................................... 84

16.1 ANNUAL WORK HOUR CONTROL EFFECTIVENESS REVIEW ......................................84

TABLE 16: WORK HOUR CONTROL EFFECTIVENESS REVIEW PROCESS ...........................86

17 REPORTING ............................................................................................................... 87

17.1 ANNUAL REPORTING REQUIREMENTS .........................................................................87

17.2 ANNUAL SUMMARY OF WAIVERS ................................................................................87

17.3 ANNUAL SUMMARY OF FATIGUE ASSESSMENTS .........................................................88

17.4 INCIDENT REPORTING REQUIREMENTS .......................................................................88

18 AUDITS ....................................................................................................................... 90

18.1 CONDUCT OF AUDITS ....................................................................................................90

18.2 AUDIT RESULTS ............................................................................................................90

19 PERSONNEL ACTIONS .............................................................................................. 91

20 EXAMPLES ................................................................................................................. 92

21 REFERENCES AND RESOURCES ............................................................................ 101

LIST OF TABLES ..................................................................................................................102

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MANAGING PERSONNEL FATIGUE AT NUCLEAR POWER 

REACTOR SITES 

1 INTRODUCTION AND BACKGROUND 

1.1 INTRODUCTION AND BACKGROUND

This guide provides an approach to meeting 10 CFR 26, Subpart I requirements related to 

managing personnel fatigue at power reactor sites. The management of fatigue is integrated into 

the industry’s fitness-for-duty program and is addressed in NEI 06-11, Managing Personnel 

Fatigue at Nuclear Power Reactor Sites, NEI 03-01, Nuclear Power Plant Access Authorization 

Program, and NEI 03-04, Guideline for Plant Access Training. 

These documents should be used by the licensee to develop policies, procedures and programs 

specific to their utility. Training, security and human resource policies as well as labor 

management and relations practices need to be considered as well in the development of the 

policies, procedures and programs. 

This document is presented in a format that will be closely aligned in sequence to 10 CFR 26. 

Tables are provided in each section for ease of reference to the applicable section in 10 CFR 26. 

These are for general information, and the actual rule should be referenced for explicit details. 

This guide also addresses the training and the comprehensive examination that is required by 

Part 26 for the following new knowledge and abilities (KAs): 

x Knowledge of the contributors to worker fatigue, circadian variations in alertness and 

performance, indications and risk factors for common sleep disorders, strategies that shift 

workers can use for obtaining adequate rest, and the effective use of fatigue 

countermeasures. 

x Ability to identify symptoms of worker fatigue and contributors to decreased alertness in 

the workplace. 

The training for other KAs associated with fitness-for-duty (FFD) is addressed in NEI 03-01 and 

NEI 03-04. 

1.2 BACKGROUND

An individual’s ability to safely and competently perform his or her duties is not solely based on 

the individual’s hours worked or whether the individual has had adequate rest. Fatigue can be 

caused by numerous factors including long hours of work, inadequate rest between work periods, 

sleep disorders, sedentary lifestyles, work problems or dissatisfaction, home finances and 

relationships, inadequate nutrition, emotional stress, physical stress, prescription drugs, and 

mental or physical illness. Fatigue may lead to decreased alertness. When an individual is alert, 

he or she may be more focused and better able to pay attention. Fatigue and decreased alertness 

can substantively degrade an individual’s ability to safely and competently perform his or her 

duties. 
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Fatigue can be defined as the degradation in an individual’s cognitive and motor functioning 

resulting from inadequate rest. 

When considering fatigue, the effects of acute fatigue (short-term) and cumulative fatigue (longterm) and an individual’s susceptibility to circadian variations should be considered. 

Fatigue may not be readily observable by a casual observer. Consistent with a station’s 

Behavioral Observation program, individuals should be observed for signs of fatigue which can 

include, but are not limited to: difficulty staying on task, irritable behavior, disorientation, 

becoming less communicative, forgetfulness, and tardiness. 

Fatigue management is vital to ensure that individuals are rested and capable of performing 

his/her daily tasks without error. An alert individual will be able to remain focused and engaged 

in their duties. 

1.3 OVERVIEW OF FATIGUE MANAGEMENT

Fatigue management is part of the licensee’s overall fitness-for-duty (FFD) program. 

In 1982 the Nuclear Regulatory Commission issued Generic Letter 82-12, Nuclear Power Plant 

Staff Working Hours, providing guidelines for managing the hours worked for individuals 

performing safety related work. The current rule was driven, in part, by the variation in 

approaches used across the industry to meet these guidelines. To meet the requirements in 

Subpart I, a detailed process, as described in this guide, is needed for consistent application of 

fatigue management principles across the industry. As an integral part of the fitness-for-duty 

program, sound fatigue management for individuals should be viewed as a way of doing business 

as opposed to requirements imposed by the NRC. 
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TABLE 1: OTHER PART 26 SECTIONS APPLICABLE TO FATIGUE MANAGEMENT 

[See rule for details - table provides only general summary of rule] 

Part 26 Section Notes on Connection to Subpart I

26.1 Purpose States purpose of Part 26 

26.3 Scope – entities Referenced explicitly in several sections of Subpart I; 

provides definitions of entities subject to Subpart I 

requirements 

26.4 Applicability – individuals Referenced explicitly in several sections of Subpart I; 

provides definitions of individuals subject to specific 

Subpart I requirements 

26.5 Definitions Provides definitions for terms used in Subpart I 

26.9 Specific exemptions States that the commission may allow exemptions 

26.21 FFD program States general licensee duty to establish, implement, and 

maintain FFD program 

26.23 Performance objectives Includes performance objectives related to managing the 

effects of fatigue and degraded alertness: 26.23(b) and 

(e) 

26.27 Written policy and procedures Referenced explicitly in Section 26.203(a) and (b); policy 

and procedures required under Subpart I are to be 

included as part of those specified in 26.27 

26.29 Training Referenced explicitly in Section 26.203(c); training and 

comprehensive examination required under Subpart I are 

to be included as part of those specified in 26.29 

26.33 Behavioral observation Impairment from fatigue is included as behavior to be 

detected 

26.35 Employee assistance program Provides for employee assistance program, which would 

include individuals subject to Subpart I 

26.37 Protection of information Provides protection of information, including information 

gathered under Subpart I 

26.39 Review process for FFD policy violations Provides process for policy violation review, including 

those under Subpart I 

26.41 Audits and corrective action Referenced explicitly in Section 26.203(f); licensees shall 

audit the management of worker fatigue as required by 

26.41 

26.77 Management actions regarding possible 

impairment 

Specifically addresses observed behavior or physical 

condition resulting from fatigue 

26.189 Determination of fitness Provides process for determining fitness, including 

possible impairment from fatigue; requires that 

determination be performed by a physician and/or MRO 

with the necessary clinical expertise 
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The regulatory approach to managing fatigue relies on two elements: limiting work periods (days 

and hours) and ensuring adequate time is allotted for breaks and days off. There are two 

protocols for managing cumulative fatigue: MDO (minimum days off) and MAWH (maximum 

average work hours). 

The work hours o schedules for f covered individuals schedules shall be consistent with the 

objective of preventing impairment from fatigue due to the duration, frequency or sequencing of 

successive work periods. 

Scheduling plays a vital role in fatigue management, as mentioned earlier and in further detail in 

Sections 6 and 7. 

It is the responsibility of each individual to report to work in condition to perform his/her duties 

safely and effectively and to maintain that condition while at work. 

Management and covered individuals should be equally responsible for properly managing work 

hours prior to the work being conducted. 
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2 SCOPE (26.201) 

2.1 GENERAL APPLICATION

This guide applies to licensees who are authorized to operate a nuclear power reactor under 

10CFR 50.57 and holders of a combined license under 10 CFR 52 after the commission has 

made the finding under 10 CFR 52.103(g). This guide also applies to new plant construction no 

later than upon receipt of special nuclear material in the form of fuel assemblies. This guide does 

not apply to decommissioned plants not authorized to operate. 

2.2 PERSONNEL SUBJECT TO FATIGUE MANAGEMENT

All persons who are granted unescorted access to nuclear power reactor protected areas. 

All persons who are required to physically report to the Technical Support Center or Emergency 

Operations Facility, in accordance with the site Emergency Plan and procedures (whether they 

have unescorted access or not). 

See Tables 1 2A and 2B for additional relevant information. 

2.3 WORK HOUR CONTROLS

10 CFR 26.205 Work Hours applies to covered individuals (a subset of the individuals to whom 

the Fatigue Management Program applies) who are granted unescorted access to nuclear power 

reactor protected areas. Any individual who performs duties within any of the following job 

categories is a covered individual subject to work hour controls: 

x Operating or on-site directing of the operation of systems and components that a riskinformed evaluation process has shown to be significant to public health and safety. 

x Performing maintenance, or on-site directing of the maintenance, or performing quality 

inspections during and following maintenance on systems, structures, and components 

(SSCs) that a risk-informed evaluation process has shown to be significant to public 

health and safety. 

x Performing health physics or chemistry duties required as a member of the on-site 

emergency response organization minimum shift complement. 

x Performing the duties of a fire brigade member who is responsible for understanding the 

effects of fire and fire suppressants on safe shutdown capability. The person specifically 

designated for understanding the effects of fire and fire suppressants on safe shutdown 

capability is considered the person responsible for understanding the effects of fire and 

fire suppressants on safe shutdown capability. The remaining fire brigade members are 

not considered as the person(s) responsible for understanding the effects of fire and fire 

suppressants on safe shutdown capability. 

x Performing security duties as an armed security force officer, alarm station operator, 

response team leader or watchman, hereinafter referred to as security personnel. 
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TABLE 2A: SUBPART I REQUIREMENTS FOR DIFFERENT CATEGORIES OF INDIVIDUALS ** 

[See rule for details - table provides only general summary of the rule] 

Subsection

Category of Individual Subpart I Coverage Note

26.4(a) All persons granted unescorted access to nuclear 

power reactor protected areas (including 

contractors/vendors) by the licensees in Section 

26.3(a) and, as applicable, (c), and who perform the 

following duties: 

 (1) Operating or on site directing the operation of 

systems and components that a risk-informed 

evaluation process has shown to be significant to 

public health and safety 

 (2) Performing health physics or chemistry duties as 

part of on-site emergency response organization 

minimum shift complement 

(3) Performing duties of fire brigade member 

responsible for understanding effects of fire and fire 

suppressants on safe shutdown capability 

(4) Performing maintenance or on-site directing of the 

maintenance or performing quality inspections during 

and following maintenance on systems, structures and 

components (SSCs) that a risk-informed evaluation 

process has shown to be significant to public health 

and safety. 

(5) Performing security duties as an armed security 

force officer, alarm station operator, response team 

leader, or watchperson (security personnel) 

26.203 - General 

provisions 

26.205 - Work 

hours 

26.207 - Waivers 

and exceptions 

26.209 - Selfdeclarations 

26.211 - Fatigue 

assessments 

This is the full fatigue 

management 

program, including 

work hour controls, 

waivers and 

exceptions, and selfdeclaration 

procedures when 

working under a 

waiver 

26.4(b) Persons granted unescorted access to nuclear power 

reactor protected areas by the licensees in Section 

26.3(a) and, as applicable, (c) and who do not 

perform the duties described in 26.4(a) 

26.203 - General 

provisions 

26.211 - Fatigue 

assessments 

Does not include 

work hour controls 

(26.205-209), but 

does include 

requirements for selfdeclaration 

procedures 

applicable to all 

individuals under 

Subpart I 
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26.4(c) Persons who are required by a licensee in Section 

26.3(a) and, as applicable, (c) to physically report to 

the licensee's Technical Support Center or Emergency

Operations Facility by licensee 

emergency plans and procedures 

26.203 - General 

provisions 

26.211 - Fatigue 

assessments 

Does not include 

work hour controls 

(26.205-209), but 

does include 

requirements for selfdeclaration 

procedures 

applicable to all 

individuals under 

Subpart I 

**NOTE: These requirements apply only to operational nuclear power plants
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TABLE 2B: INDIVIDUALS SUBJECT TO WORK HOUR CONTROLS (26.205(A)) 

[See rule for details - table provides only a general summary of the rule] 

SubsectionIndividuals* Duties Note

26.4(a)(1) Operators All persons with unescorted access 

operating or on site directing the 

operation of systems and components 

that a risk- informed evaluation process 

has shown to be significant to public 

health and safety 

26.4(a)(2) Health 

physics or 

chemistry 

staff 

All persons with unescorted access 

performing health physics or 

chemistry duties required as a 

member of on-site emergency 

response organization minimum shift 

complement 

Not necessarily all 

health physics or 

chemistry staff—only 

those who are 

performing duties of 

on-site emergency 

minimum shift 

complement 

26.4(a)(3) Fire brigade 

members 

All persons with unescorted access 

performing duties of fire brigade 

member responsible for understanding 

effects of fire and fire suppressants on 

safe shutdown capability 

Not necessarily all fire 

brigade members – 

only those specifically 

responsible for 

understanding the 

effects of fire and fire 

suppressants on safe 

shutdown capability 

26.4(a)(4) Maintenance All persons with unescorted access 

maintaining or on site directing or 

performing quality inspections of the 

maintenance of SSCs that a riskinformed evaluation process has shown 

to be significant to public health and 

safety 

See asterisk note 

below 

26.4(a)(5) Security 

Personnel 

All persons with unescorted access 

performing security duties as an 

armed security force officer, alarm 

station operator, response team 

leader, or watchperson 

Does not include 

security staff solely 

performing 

administrative duties 

*NOTE: Contractors, if performing the listed duties, are also covered, including maintenance 

contractors. 
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3 DEFINITIONS 

Terms Relevant to Fatigue Management 

Acute Fatigue means fatigue from causes (e.g., restricted sleep, sustained wakefulness, task 

demands) occurring within the past 24 hours. 

Alertness means the ability to remain awake and sustain attention. 

Averaging Period means the one- to six-week period over which an individual’s per week 

average work hours are to be calculated; this per week average shall not exceed 54 hours. The 

averaging period is set by the licensee and may range from one week to six weeks, with a 

specified beginning and ending time of day and day of week. The averaging period advances by 

seven consecutive calendar days at the finish of every averaging period. 

Break is the interval of time that falls between successive work periods, during which the 

individual does not perform any duties for the licensee other than shift turnover. 

Break Requirements are divided into the following: 

x Minimum Work Period Break Requirement: A 10-hour break between the previous work 

period, or an 8-hour break between the previous work period when a break of less than 10 

hours was necessary to accommodate a crew’s scheduled transition between work 

schedules or shifts. 

x Minimum 9-Day Break Requirement: A 34-hour break in the preceding 216-hour (9-day) 

period. 

Calculated Work Hours – see Work Hours

Calculation Period means the time interval specified in a work hour control requirement used to 

calculate whether a particular work hour control is met. 

Call-in means coming to the site to perform unscheduled work. 

Ceiling Limits – see Work Hour Limits 

Circadian variation in alertness and performance means the increases and decreases in 

alertness and cognitive/motor functioning caused by human physiological processes (e.g., body 

temperature, release of hormones) that vary on an approximately 24-hour cycle. 

Contractor/Vendor (C/V) is any company or any individual not employed by a licensee who is 

providing work or services to a licensee, either by contract, purchase order, oral agreement or 

other arrangement. 

Corrective Maintenance includes actions that restore—by repair, overhaul or replacement—the 

capability of a failed SSC to function within acceptance criteria. 
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Covered Individual means an individual subject to work hour controls. Any individual granted 

unescorted access to a nuclear power plant’s protected area that performs covered work. 

Covered SSC are systems, structures, and components that a Risk-Informed Evaluation Process 

has shown to be significant to public health and safety. The operational condition of the SSC is 

not relevant to the SSC covered status. See Section 20, Examples 2 and 3. 

Covered Work means the following: 

x Operating or on-site directing of the operation of systems and components that a riskinformed evaluation process has shown to be significant to public health and safety. 

x Performing maintenance or on-site directing maintenance or performing quality 

inspections of the maintenance of structures, systems, and components (SSCs) that a riskinformed evaluation process has shown to be significant to public health and safety. 

x Performing Health Physics or Chemistry duties required as a member of the on-site 

emergency response organization minimum shift complement. 

x Performing the duties of a Fire Brigade member who is responsible for understanding the 

effects of fire and fire suppressants on safe shutdown capability. 

x Performing security duties as an armed security force officer, alarm station operator, 

response team leader, or watchperson, hereinafter referred to as security personnel. 

See Section 20, Example 4A-E. 

Crew means a group of workers that are scheduled on the same shift and work together. 

Cumulative Fatigue means the increase in fatigue over consecutive sleep-wake periods resulting 

from inadequate rest. 

Day Off is a calendar day in which an individual does not start a work period. 

Deviation is a departure from the requirements included in 10 CFR 26 Subpart I. 

Directing means the exercise of control over a work activity by an individual who is directly 

involved in the execution of the work activity, and either makes technical decisions for that 

activity without subsequent technical review, or is ultimately responsible for the correct 

performance of that work activity. See Section 20, Example 4A-E. 

Fatigue means the degradation in an individual's cognitive and motor functioning resulting from 

inadequate rest. 

Incidental duties means unscheduled work activities, required by the licensee, performed offsite. 

Increased threat condition means an increase in the protective measure level, relative to the 

lowest protective measure level applicable to the site during the previous 60 days, as 

promulgated by an NRC advisory.
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Maintenance means, for the purposes of Section 26.4(a)(4), the following on-site maintenance 

activities: modification, surveillance, post-maintenance testing, and corrective and preventive 

maintenance. Predictive maintenance activities that do not result in a change of condition or state 

of a risk-significant SSC may be excluded from covered maintenance activities. Examples 

include: nondestructive examination, thermography, vibration analysis, and data collection and 

analysis. 

Maximum Average Work Hours (MAWH) is a method for managing cumulative fatigue that 

establishes a limit of 54 work hours per week that an individual may average over the licenseedefined averaging period of 1 to 6 weeks. This is sometimes referred to as on-line averaging. 

Minimum Days Off (MDO) is a method for managing cumulative fatigue that establishes the 

minimum number of days off that an individual is required to have during a given period of time. 

The required number of days off varies by plant operating status, shift schedule and job duties. 

Nap or Restorative Sleep is a brief opportunity and accommodations for restorative, 

uninterrupted sleep of at least one half hour in a designated area. 

Nominal means the limited flexibility that is permitted in meeting a scheduled due date for 

completing a recurrent activity that is required under this part, such as the nominal 12-month 

frequency required for FFD refresher training in Section 26.29(c)(2) and the nominal 12-month 

frequency required for certain audits in Section 26.41(c)(1). Completing a recurrent activity at a 

nominal frequency means that the activity may be completed within a period that is 25 percent 

longer or shorter than the period required in this part. The next scheduled due date would be no 

later than the current scheduled due date plus the required frequency for completing the activity. 

Off-site means any area not considered on-site. 

On-Line Averaging is an industry term synonymous with the average 54-hour-per-week 

limitations referred to as MAWH (Maximum Average Work Hours). 

On-Line Day is a day when the unit is not in an outage when the shift starts. 

On-site means within the owner controlled area of the nuclear power plant. 

Outage Day is a day when the unit is in an outage when the shift starts. 

Outage Worker is a worker supporting outage activities who is not part of a multi-unit minimum 

control room complement required by the operating unit on the same site. 

Predictive Maintenance is monitoring, diagnosing or trending SSC functional or condition 

indicators by observation, driven by the condition of the SSC or at specified intervals. Results 

indicate current and future functional ability or the nature of and schedule for planned 

maintenance, not real-time operations. Examples of activities that may be excluded from covered 

maintenance activities if they do not change the state or condition of these covered SSCs include, 

but are not limited to, nondestructive examination (NDE), thermography, vibration analysis, and 

data collection and analysis. 
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Preventive Maintenance includes actions that detect, preclude or mitigate degradation of 

functional structures, systems and components (SSC) to sustain or extend its useful life by 

controlling degradation and failures to an acceptable level. 

Protected Area has the same meaning as described in 10 CFR 73.2(g): An area encompassed by 

physical barriers and to which access is controlled. 

Quality Inspections are, for the purpose of determining covered individuals, those 

inspection/verification activities performed during and following maintenance on covered SSCs. 

Excluded from covered quality inspection activities are material and fuel receipt inspections and 

the directing of quality inspections.

Rest Break means an interval of time that falls between successive work periods during which 

the individual does not perform any duties for the licensee. Shift turnover can be considered as 

part of the break. Rest break requirements are one form of work hour controls. 

Risk-Informed Evaluation Process means an evaluation based on a probabilistic risk analysis 

approach such as the Maintenance Rule (50.65(a)(4)) or other similar process. 

Safety-Related Structures, Systems and Components (SSCs) mean, for the purposes of this part, 

those structures, systems, and components that are relied on to remain functional during and 

following design basis events to ensure the integrity of the reactor coolant pressure boundary, the 

capability to shut down the reactor and maintain it in a safe shutdown condition, or the capability 

to prevent or mitigate the consequences of accidents that could result in potential off-site 

exposure comparable to the guidelines in 10 CFR 50.34(a)(1). 

Security Personnel are armed security force officers, alarm station operators, response team 

leaders, and watchpersons. 

Shift Cycle means a series of consecutive work shifts and days off that is planned by the licensee 

or other entity to repeat regularly, thereby constituting a continuous shift schedule. 

Shift (Work Shift) is a regularly occurring work period which is normally of a consistent length 

(e.g., 8, 10 or 12 hours) and scheduled by the licensee or other entity as part of a shift schedule. 

Shift Schedule is a schedule that averages the hours described below over a shift cycle: 

x Eight (8)-hour shift schedule a schedule duration that averages not more than 9 hours 

per workday over the entire shift cycle. [Used for MDO calculations] 

x Ten (10)-hour shift schedule – a schedule duration that averages more than 9 hours, but 

not more than 11 hours, per workday over the entire shift cycle. [Used for MDO 

calculations] 

x Twelve (12)-hour shift schedule – a schedule duration that averages more than 11 hours, 

but not more than 13 12 hours, per workday over the entire shift cycle. [Used for MDO 

calculations]
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Shift Turnover Licensees may exclude from the calculation of an individual’s work hours 

that portion of shift turnover that occurs outside of an individual’s shift. Shift turnover includes 

those activities that are necessary to safely transfer information and responsibilities between two 

or more individuals between shifts. Shift turnover activities may include, but are not limited to, 

discussions of the status of plant equipment, arming and disarming of armed security officers, 

transit to and from turnover stations including compliance with radiological and personal safety 

requirements, and the status of ongoing activities such as extended tests of safety systems and 

components. The exclusion of turnover is limited to the transfer of security or safety 

responsibilities between two or more individuals working contiguous shifts. 

Shift turnover activities that may be excluded from work-hour calculations are only those 

activities that meet all three of the following criteria: 

1. The activity immediately preceded the beginning of the individual’s shift or immediately 

followed the end of an individual's shift; 

2. The activity was necessary to transfer safety and security responsibilities between two or 

more individuals on contiguous shifts; and 

3. The activity could not have reasonably been performed during the shift because of NRC 

requirements or other safety/security considerations. 

Tactical exercise is a force-on-force simulation used to evaluate and demonstrate the capability 

to defend target sets against selected attributes and characteristics of an adversary. A force-onforce tactical exercise includes all key program elements of a station’s protective strategy. 

Unit outage means that the reactor unit is disconnected from the electrical grid.means, for purposes 

of this part, the period from when the reactor unit is disconnected from the electrical grid until 

the reactor unit achieves 75 percent reactor power or until seven calendar days have elapsed 

since reconnecting the reactor unit to the electrical grid whichever is shorter.

Work day means a calendar day during which an individual starts a work period. 

Work hours means the amount of time an individual works performing duties for the licensee. 

Work hour controls are the work hour limits and rest break requirements in 10 CFR 26.205. 

Work hour limits, – (also referred to as Ceiling Limits) are the specific limits placed on the 

number of hours an individual can work within certain periods of time (24 hours, 48 hours and 7 

days), defined as the following: 

x 16 hours in a 24-hour period. 

x 26 hours in a 48-hour period. 

x 72 hours in a 7-day period or 168 hours. 

NOTE: The periods of “24 hours,” “48 hours” and “7 days” are considered rolling time periods. 

Rolling means the period is not re-zeroed or the “clock reset” following a day off or after 
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obtaining authorization to exceed the limits. The 24-hours,” “48-hour and “7-day periods do not 

restart after a day off; the periods continue to roll. 
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4 POLICY AND PROCEDURES (26.203) 

4.1 POLICY

The licensee shall establish a policy for the management of fatigue for all individuals who are 

subject to the licensee’s fitness-for-duty (FFD) program and incorporate the guidance into the 

site or corporate written FFD policy as required in 10 CFR 26.27(b). As related to fatigue 

management, the FFD policy should: 

x Address the effect of fatigue on FFD. 

x Provide a description of any program that is available to individuals who are seeking 

assistance in dealing with fatigue or other problems that could adversely affect an 

individual’s ability to safely and competently perform the duties that require an 

individual to be subject to this subpart. 

x State which method of on-line work hour controls is being used, on-line Minimum Days 

Off (MDO) or Maximum Average Work Hours (MAWH). 

x When complying with the on-line averaging method, state which work- hour counting 

system is being used relative to the start and end of the work day. See 10 CFR 

26.205(d)(7)(ii). 

x Describe the consequences of violating the policy. 

x Describe the responsibilities of managers, supervisors and escorts to report FFD 

concerns. 

x Describe the individual’s responsibility to report FFD concerns. 

x Describe the individual’s responsibility to maintain his/her FFD and make selfdeclaration if not fit for duty. 

4.2 PROCEDURES

The licensee shall develop, implement, and maintain procedures that describe the: 

x Process for implementing the work hour controls required for covered individuals. 

x Method of on-line work hour controls that is being used, MDO (minimum days off) or 

MAWH (maximum average hours worked). 

x Work hour counting system that is being used relative to the start and end of the work 

day, when complying with maximum average work hours. See 10 CFR 26.205(d)(7)(ii). 

x Individuals and licensees rights and responsibilities related to self-declaration. 

x Process to be followed when any individual covered by the FFD program makes a selfdeclaration that he or she is not fit to safely and competently perform his or her duties for 

any part of a work period as a result of fatigue. 
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x Requirements for establishing controls and conditions under which an individual may be 

permitted or required to perform work after that individual declares that he or she is not 

fit due to fatigue. 

x Process to be followed if the individual disagrees with the results of a fatigue assessment 

that is required. 

x Process to be followed in conducting fatigue assessments. 

x Disciplinary actions that the licensee may impose on an individual following a fatigue 

assessment, and the conditions and considerations for taking those disciplinary actions. 

The procedures, at a minimum, delineate the following responsibilities: 

x Operations shift manager or a site senior-level manager with requisite signature authority: 

o Determining the necessity of a waiver of work hour controls for an individual to 

mitigate or prevent a condition adverse to safety per 10CFR Part 26 .207 (a)(1)(i). 

o Maintaining staffing levels adequate to ensure that work hours can be managed 

consistent with the objective of preventing impairment from fatigue. 

x Security shift manager or a site senior manager with requisite signature authority: 

o Determining the necessity of a waiver of work hour controls to maintain site 

security per 10CFR Part 26.207 (a)(1)(e). 

o Ensure staffing levels are adequate to ensure work hours are managed consistent 

with the objective of preventing impairment from fatigue. 

x Plant Manager (generic title for top senior level site manager responsible for plant 

operations) 

o Responsible for ensuring a review is performed at least once per year to evaluate a 

full year of data evaluating the effectiveness of work hour controls. This review 

includes evaluation and review of: 

 Staffing levels to ensure individual work hours are managed with the 

objective of preventing impairment from fatigue due to the duration, 

frequency or sequencing of successive work periods. 

 The performance of individuals to ensure individual work schedules 

prevents impairment from fatigue. This includes evaluating the duration, 

frequency and sequencing of the hours that are worked by each individual 

relative to worker performance. 

 The performance of the station in adhering to work schedules for covered 

work groups: evaluate the number of schedule changes and reasons for the 

changes and assess whether or not schedules are being effectively 

implemented. 

x Supervisor (or manager) of the individual who will be issued a waiver: 

o Evaluating the employee’s fitness by performing a face-to-face supervisory 

assessment of fitness for a waiver. 
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o Evaluating the employee’s performance and continued fitness-for-duty while 

working under a waiver. 

o Ensuring the waiver is authorized prior to allowing an individual to exceed work 

hour controls being waived. 

NOTE: If evaluating for the issuance of a waiver and the individual’s supervisor or 

manager is not on site, this responsibility may be performed by any manager or 

supervisor who is qualified to oversee the work to be performed by the individual. 

x Department Head for departments with Covered Workers: 

o Providing guidelines for overtime selection process, including those required by 

the union contract and the FFD requirements outlined in this guide and in the 

licensee’s FFD Program. 

o Communicating the requirements to appropriate personnel within his/her 

department. 

o Maintaining a record of the shift schedules and shift cycles used for at least the 

past three years for those individuals who are subject to work hour controls. 

Records may be required longer than three years, if legal proceedings are 

ongoing. 

o Evaluating whether staffing levels are adequate to ensure individual work hours 

are managed with the objective of preventing impairment from fatigue due to the 

duration, frequency or sequencing of successive work periods. 

x Employee (licensee or contractor): 

o Evaluating his/her personal fitness to work based on impairment from fatigue. 

o Managing his/her work hours consistent with the objective of preventing 

impairment from fatigue. 

o Making a self-declaration of fatigue and discussing his/her concerns with 

supervision or management in cases when the individual feels his/her 

performance may be impaired. 

o Verifying his/her working hours are correctly documented regardless of whether 

he/she is paid for the hours worked. 

o Monitoring and reporting concerns related to other individuals’ fitness to work 

based on impairment from fatigue (i.e., behavioral observation program). 

o Being aware of the total hours worked in the previous 14 days and notifying 

management if work hour limits will be exceeded if asked to work additional 

hours. 
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5 MANAGING FATIGUE (26.203) 

5.1 INDIVIDUAL SUBJECT TO FATIGUE MANAGEMENT

Fatigue management requirements, with exception of work hour controls, apply to the following 

individuals: 

x All persons who are granted unescorted access to nuclear power reactor protected areas. 

x All persons who are required to physically report to the Technical Support Center or 

Emergency Operations Facility, in accordance with the site Emergency Plan and 

procedures. 

NOTE: Not all personnel that are subject to fatigue management will be subject to work 

hour controls. Individuals subject to work hour controls are specified in Section 6. 

5.2 REQUIREMENTS

Personnel subject to fatigue management will be trained and examined as part of the fitness-forduty training requirements for the following KAs: 

x Knowledge of the contributors to worker fatigue, circadian variations in alertness and 

performance, indications and risk factors for common sleep disorders, shift work 

strategies for obtaining adequate rest, and the effective use of fatigue counter measures. 

x Ability to identify symptoms of worker fatigue and contributors to decreased alertness in 

the workplace. 
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6 WORK HOUR CONTROLS (26.205) 

6.1 INDIVIDUALS SUBJECT TO WORK HOUR CONTROLS

Any individual granted unescorted access to a nuclear power plant’s protected area that performs 

covered work. These individuals shall be subject to a FFD program that meets the requirements 

of 10 CFR 26.4(a). See Table 2A and 2B. 

If a covered individual begins or resumes performing covered work during the calculation 

period, the licensee shall include in the calculation of the individual’s work hours all work hours 

worked for the licensee, including hours worked performing duties that are not considered 

covered work. These work hours apply to break requirements and ceiling limits as well as total 

hours worked for either the MDO or MAWH on-line averaging methods below. 

At a multi-unit site when one or more units is in an outage, only those licensed operators 

composing the minimum shift complement of operators required in the table below derived from 

10 CFR 50.54(m) are required to work under the on-line (MAWH or MDO) hours rules. 

Minimum Number of Individuals Per Shift Working Non-outage Schedules for Onsite 

Staffing of Operating Nuclear Power Units during Outages 

Number of 

operating 

nuclear 

power 

units1

Position 

Two-unit Site Three-unit Site 

One 

Control 

Room 

Two 

Control 

Room 

Two control rooms 

Three 

Control 

Rooms 

Single 

Control 

Room 

Unit In 

Outage 

Single 

Control 

Room 

Unit and 

One 

Unit 

Served 

by Dual 

Control 

Room In 

Outage 

One 

of the 

Units 

Served 

by Dual 

Control 

Room 

in 

Outage 

Two 

Units 

Served 

by Dual 

Control 

Room 

in 

Outage 

One 

Senior 

Operator 2 2 2 2 2 

Operator 2 2 2 2 2 

Two 

Senior 

Operator 2 3 3 

Operator 32 4 4 

1

 For the purpose of this table, a nuclear power unit is considered to be operating when it is 

connected to the grid. 
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If a worker (any classification) is dedicated to and solely working the operating unit, that worker 

is not eligible for outage work hour rules. 

In fuel handling operations, the operators making and approving reactivity changes are required 

to be on operations work hours rules if using the MDO method. 

At a minimum, this includes the operator on the manipulating bridge over the reactor vessel the 

fuel handling SRO in containment, and the control room reactor operator on the tag board (or 

equivalent). 

All others involved with fuel handling operations may be considered under the maintenance 

work hour rules. 

Predictive Maintenance on a covered system may be a covered activity. Predictive maintenance 

activities that do not result in a change of condition or state of a risk-significant SSC may be 

excluded from covered maintenance activities. Examples include: nondestructive examination, 

thermography, vibration analysis, and data collection and analysis. 

If a change in operational state of the equipment is necessary, the actual operation or 

maintenance activity to prepare for the predictive maintenance activity may be covered. 

Emergency response personnel who do not perform health physics or chemistry duties required 

as a member of the on-site emergency response organization minimum shift complement are not 

covered workers. 

For the purposes of determining the performing or directing of covered work, the following 

guidance should be applied: 

x Operating or on-site directing of the operation of systems and components that a riskinformed evaluation process has shown to be significant to public health and safety. 

x Performing maintenance or on-site directing of the maintenance or performing quality 

inspections during and following maintenance on systems, structures and components 

(SSCs) that a risk-informed evaluation process has shown to be significant to public 

health and safety. 

x Maintenance includes the following on-site maintenance activities: modification, 

surveillance, post-maintenance testing, and corrective and preventive maintenance of 

SSCs. Only maintenance activities that change the operational condition of the SSCs are 

included. 

x Directing is the exercise of control over a maintenance or operations covered work 

activity by an individual who is directly involved in the execution of the work activity 

and either makes technical decisions for that activity without subsequent technical review 

or is ultimately responsible for the correct performance of that work activity. 

x Miscellaneous interpretations: 

o Scaffolding – Erecting scaffolding is not considered a covered activity. 
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o Crane operations are often covered activities if part of covered work or operations 

dealing with safe load lifts as defined by NUREG 0612. 

o Insulation – Removal of insulation is not a covered activity. However, restoration 

of insulation material that brings a covered SSC back into compliance with its 

design is covered work. 
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6.2 WORK HOUR SCHEDULING REQUIREMENTS AND PRINCIPLES (26.205 (C)) 

Licensees shall schedule the work hours of covered individuals consistent with the objective of 

preventing impairment from fatigue due to the duration, frequency or sequencing of successive 

work periods. 

When establishing schedules the following should be applied consistent with the performance 

objective of preventing impairment from fatigue due to the duration, frequency or sequencing of 

successive work periods: 

x Duration of scheduled work period (not to exceed 12 hours). 

x Duration of break periods. 

x Consistent start times for work periods 

x Considerations of start times consistent with circadian factors. 

x Consistent stop times for work periods. 

x Consistent rotation (e.g., if working a 5-week shift cycle, the scheduled work days and 

days off are repeated every five weeks). 

x Rotating schedules provide suitable transition between shifts (days/nights, 

days/swings/nights), 8-hour shift rotations rotate forward or provide more than 24 hours 

between work periods to adjust circadian rhythm; 12-hour shift rotations provide 34 

hours off during day/night transitions. 

x Long range predictability is a key aspect of fatigue mitigation. 

x Circadian factors. 

x Training requirements. 

x Vacation scheduling. 

x Consideration of the impact of unscheduled overtime. 

x Stable 24-hour shift rotation (e.g., 3 X 8’s, 2 X 12’s, 2 X 10’s with four hours un-staffed). 

x The impact of backward shift rotation (rotation of the start of the shift from days to night 

to swings). 

Staffing levels should be sufficient so that schedules for the covered individuals can be 

maintained based on vacation and training demand without relying on waivers. It is expected and 

allowed that normal variation in vacation and training demands may occasionally require 

additional work hours to be used. Management is responsible for understanding the total 

vacation, training and workload demands and for maintaining sufficient staff to do the work. 
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6.3 WORK HOUR CONTROLS 

The first step in the fatigue management process is to identify all reasonably foreseeable factors 

that could contribute to worker fatigue. A variety of factors which can be cumulative, contribute 

to whether an individual experiences fatigue as well as the severity of that fatigue. The factors 

can include work scheduling, circadian adjustments, job demands, cumulative fatigue, acute 

fatigue1

 and sleep deprivation. 

In addition to carefully constructed work schedules and proper staffing, fatigue is managed by 

two basic strategies, limiting hours worked and mandating required break periods (also referred 

to as “rest breaks”). This is accomplished via scheduling protocols to limit both acute and 

cumulative impact. 

Work Hour Limits (Ceiling Limits) and Break Requirements – (Rest Breaks) 

Work hour limits (ceiling limits) are defined as the following: 

x 16 hours in a 24-hour period. 

x 26 hours in a 48-hour period. 

x 72 hours in a 7-day period or 168 hours. 

Ceiling limits and break requirements always apply when a worker is a covered individual except 

when specifically exempted in Section 12, Exceptions. 

6.3.1 Applying Work Hour (Ceiling) Limits 

The periods of “24 hours”, “48 hours” and “7-days” are considered rolling time periods. Rolling 

means the period is not re-zeroed or the “clock reset” following a day off or after obtaining 

authorization to exceed the limits. 

The “24-hour”,”48-hour” and “7-days” periods do not restart after a day off; the periods continue 

to roll. 

See Section 20, Example 7. 

6.3.2 Applying Break Requirements 

Minimum work period break is 10-hour break between the previous work period, or an 8-hour 

break between the previous work period when a break of less than 10 hours was necessary to 

accommodate a crew’s scheduled transition between work schedules or shifts. 

Minimum 9-day break requirement is a 34-hour break in the preceding 216-hour (9-day) period. 

When determining the 34-hour break in 9 days, a rolling 216-hour (9-day) period should be used. 

 

1

 Acute fatigue results from short-term sleep loss or from short periods of heavy physical or mental work. The 

effects of acute fatigue are of short duration and usually can be reversed by sleep and relaxation. 
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The licensee should continuously look forward from the start of the first period of work, 

immediately following a 34-hour break, to ensure there is a 34-hour break is scheduled in the 

subsequent 9 days or 216-hour period. 

Conversely, to ensure that the actual hours worked by the individual are in compliance, the 

licensee must verify that the individual has had a 34-hour break in the previous 9 days or 216-

hour period at the end of the work period. 

When calculating the duration of a break between work periods, turnover may be included as 

part of the break duration 

When accommodating a scheduled transition between rotating shift periods to a new work 

schedule (e.g., 10-hour shifts to 12-hour shifts) then a break period of 8 hours is acceptable for a 

crew’s transition from an outage to online operations.2

Break times may be required to be extended based on the travel time provisions in Section 7, 

Counting Work Hours and Break Times. 

6.4 METHODS OF WORK HOUR CONTROLS

Work hour limits are prescribed by either minimum days off (MDO) or maximum average work 

hour (MAWH) protocols.

The MDO method requires that in a shift cycle, the worker will receive an average number of 

days off equal to or greater than the MDO requirement for the applicable shift schedule. 

6.4.1 Minimum Days Off (MDO) 

The on-line MDO method requires that in a shift cycle, the worker will receive an average 

number of Days Off per week equal to or greater than the MDO requirement for the shift 

schedule that applies. 

Covered Individual 8-hour shift 10-hour shift 12-hour shift 

Actual Average 

Shift Hours 

8 to less than or 

equal to 9 hours 

Greater than 9 to 

less than or equal 

to 11 hours 

Greater than 11 and 

less than or equal to 

13 12 hours 

Maintenance 1 day off per week 2 days off per 

week 

2 days off per week 

Operations, HP, 

Chemistry, Fire 

Brigade 

1 day off per week 2 days off per 

week 

2.5 days off per week 

Security 1 day off per week 2 days off per 

week 

3 days off per week 

 

2

 Ref: Federal Register/ Vol 73 No 62. Page 17133, Section 26.205(d)(2)(i) - break period applies to a crew 

transition. 
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The planned shift schedule is used to establish the beginning minimum days off (MDO) 

requirement. If the actual hours worked do not deviate from the planned shift schedule, the 

required MDO will not change. 

Periodically, workers and supervisors may need to work unscheduled hours to meet station 

needs. An accumulation of unscheduled work hours over a shift cycle may affect the MDO 

requirement that applies to individuals or crews. 

The table provided is for a shift cycle schedule that is averaged over 42 days or fewer as 

applicable. If the worker averages more hours than previously scheduled the licensee must 

recalculate the average hours worked per shift to ensure the proper MDO (8, 10 or 12) is met 

prior to the end of the shift cycle. For actual shift rotation cycles greater than 42 days, the 

averages must be calculated over a period of 42 days or fewer. 

The licensee may elect to use a rolling or fixed (maximum) six-week period for the purposes of 

determining the minimum days off. The actual repeatability of the schedule rotation may exceed 

6 weeks; however, the shift cycle used for calculating the minimum days off cannot exceed 6 

weeks. 

Generally a rolling evaluation period for MDO evaluations takes into account the current day and 

looks back at the previous days in the evaluation period for compliance. For example, an 

individual on a 42-day (six-week) rolling evaluation period—for the purpose of compliance with 

the MDO requirement—he current day and the last 41 days of actual time are used to determine 

if the individual has had the required days off. When tomorrow is reached, it is that day and the 

previous 41 days, etc. For the purposes of predicting compliance, the current day and the next 41 

days of scheduled time are used. 

For a 42-day (six-week) fixed calculation period, an individual must meet the MDO requirement 

for their job function and average shift length for days 1 to 42. The day following day 42 is a 

new day 1, and a new 42-day evaluation period begins. These evaluation periods go in blocks 

from 1-42 and then start over. Once the schedule goes beyond day 42, the evaluation period 

looks ahead another 42 days and does not look back as does the rolling evaluation method. 

Guidance for details on administration of the MDO method is in Section 9. 
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6.4.2 Maximum Average Work Hours (MAWH) aka On Line Averaging Method 

The alternative approach to on-line MDO is a weekly maximum average of 54 hours worked, 

referred to as MAWH based on a rolling averaging period of up to 6 weeks. This alternative is 

applicable to all covered workers, regardless of classification. 

In a rolling period: 

x The averaging period starts “rolling” after a work history for a covered worker has been 

established equal to the length of the averaging period. 

x The averaging period rolls by one full week at a time. The week does not have to start on 

any specific day but must be consistent through the calculation period and documented in 

the controlling procedure. 

x Shifts that bridge the point in time during the week when the averaging period rolls 

forward one week may be counted in one of two ways and the method must be 

documented in the controlling procedure: 

o The hours for that shift may be included in the week the shift starts. 

o The hours may be included in the weeks the hours are worked. 

6.5 DEVIATIONS AND COMPLIANCE

A covered worker must be in compliance with all the specific work hour rules or be under an 

approved waiver prior to performing covered work. 

Whenever a covered worker finds that a violation of limits exists, then in order to reset from that 

deviation to permit further covered work, the worker must come into compliance with all: 

x Break requirements. 

x Ceiling limits. 

x The specific rules for the method of work hour calculation below prior to performing any 

further covered work. 

Each deviation must be documented in the licensee corrective action program: 

x Resets from deviations under MDO must additionally ensure that actions are in place to 

comply with MDO requirements by the end of the shift cycle if using the fixed-cycle 

method in work hour calculations. 

x Resets from deviations under MAWH must additionally ensure that actions are in place 

to comply with the 54-hour averaging limit by the end of the averaging period. 
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7 COUNTING WORK HOURS AND BREAK TIME (26.205) 

7.1 PROCESS FOR EVALUATING A SCHEDULE

This section orients the reader to how schedules are structured and gives some general strategies 

for reading them. 

Schedules are typically fixed or rotating, where operations, RP and chemistry will usually follow 

the same schedule, while maintenance and security will typically follow a fixed schedule. 

Examples of on-line schedules: 

Operations (5-section typical) 

D = Day 12-hour, N = Night 12-hour T = Training 10-hour 

Crew/Day 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35

MTWT F SSMTWT F SSMTWT F SSMTWT F SSMTWT F SS

1 TTTT NNN DDD NNNN DDDD

2N N N D D D N N N N D D D D T T T T

3D D D N N N N D D D D T T T T N N N

4 NNNN DDDD TTTT NNN DDD

5 DDDD TTTT NNN DDD NNNN

Security (4-section typical) 

Crew/Day 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 31 33 34 35

Day M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S

A DDDD DDDD DDDD DDDD DDD

B DDDD DDDD DDDD DDDD

C NNNN NNNN NNNN NNNN NNN

D NNNN NNNN NNNN NNNN

Maintenance may follow a standardized day or night protocol or work to a schedule similar to 

those illustrated. 

When a schedule is created or schedule change is proposed, the following items need to be 

considered prior to implementation: 

Begin by evaluating the existing and proposed schedule for continued compliance with 

restrictions of the rule (required breaks, consecutive days worked, transitioning, current work 

schedules, etc.) 

Items to be considered during schedule development: 

x Self-relieving shifts (absorb unexpected absences). 

x Minimizing changes (make schedules compliant with minimal changes). 

x Eight-hour shifts vs. 10- or 12-hour shifts. 

x Union contracts. 
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x Cumulative fatigue impacts. 

x Ability to fill an unexpected vacancy on any shift assuming the maximum allowable 

personnel are on vacation. 

7.2 ACCOUNTING OF WORK HOURS

Work hours mean the amount of time an individual performs duties for the licensee. This 

includes all work hours, with the following exceptions: 

x Shift turnover time. 

x Within-shift break and rest periods in which there is reasonable opportunity and 

accommodations for restorative sleep (e.g., a nap) may be excluded. 

x Unscheduled work hours for the purpose of participating in unannounced emergency 

preparedness exercises and drills may be excluded.

x The time the individual works unscheduled work hours for the purposes of responding to 

a declared plant emergency, as defined in the licensee’s emergency plan. 

Resuming or beginning covered work means the act of performing covered work, whether 

considered part of an earlier work day or resumption of covered work activities. 

If an individual begins or resumes performing for the licensee any covered work during the 

calculation period, the licensee shall include in the calculation of the individual’s work hours all 

work hours worked for the licensee, including hours worked performing duties that are not 

covered work. 

Exclusion and Inclusion Guidance for Work Hour Calculations 

Paid time not included in the work hour calculations: 

x Only the actual hours worked are included in the work hour calculations. Examples of 

paid hours not worked are as follows: 

x Vacation time is time away from work and is not included in the work hour calculation. 

x Sick leave is time away from work and is not included in the work hour calculation. 

x Personal leave is time away from work and is not included in the work hour calculation. 

x Holiday pay may be either time away from work or at work. If the time is at work, then 

only the actual hours worked are included in the work hour calculation. 

Declared plant emergencies as defined in the licensee’s emergency plan: 

x For the purposes of compliance with § 26.205(c) and (d), licensees may exclude from the 

calculation of an individual’s work hours the time the individual works unscheduled work 

hours for the purposes of responding toparticipating in a declared plant emergency, as 

defined in the licensee’s emergency plan. 
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x When the plant exits the emergency classification to a non-emergency state, this 

exclusion becomes not applicable. Licensees should evaluate the need for waivers and 

performing supervisory assessments of fitness. This exclusion applies to ceiling limits, 

break requirements, MDOs and MAWH limits. 

Unannounced emergency preparedness exercises and drills: 

x Licensees may exclude the time an individual works unscheduled work hours for the 

purpose of participating in the actual conduct of an unannounced emergency 

preparedness exercise or drill. If an individual is on a day off, it is still considered a day 

off. 

Force-on-force tactical exercises: 

x For those licensees using MDO: Licensees may exclude shifts worked by security 

personnel during the actual conduct of force-on-force tactical exercises evaluated by the 

NRC when calculating the individual’s number of days off. This includes security 

support personnel who may not be actual drill participants. 

x For those licensees using MAWH: Licensees may exclude shifts worked by security 

personnel during the actual conduct of NRC-evaluated force-on-force tactical exercises 

when calculating average hours worked. This includes security support personnel who 

may not be actual drill participants. See Table 7 for additional guidance. 

Common defense and security: 

x Licensees need not meet the work hour requirements when informed in writing by the 

NRC that these requirements, or any subset thereof, are waived for security personnel in 

order to assure the common defense and security, for the duration of the period defined 

by the NRC. 

Daylight Saving Time: 

x When working during the change from standard time to daylight savings time, the shift 

being worked during the time change may be counted as a 7-hour, 9-hour, or 11-hour 

shift. 

x When working during the change from daylight savings time back to standard time, the 

shift being worked during the time change may be counted as an 8-hour, 10-hour, or 12-

hour shift (i.e., the additional hour does not have to be included in the work hour 

calculations). 

x In addition to not counting the extra hour, the evaluation period (i.e., 24 hours, 48 hours, 

168 hours or 7 calendar days should not be impacted by the decrease or increase in actual 

time versus apparent time. 

Call-in work period: 
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x A call-in is considered an addition to the normal work schedule. The work hours can be 

accounted for using three different methods depending on timing and circumstances of 

the call-in work period. 

o The call-in hours can be considered a separate work period. Using this method, 

only the hours worked for the licensee will be counted. The method requires a 10-

hour break before the call in period and after the call-in period. 

o The call-in hours can be considered an extension to the preceding or succeeding 

work period. Using this method, the intervening hours of the extended work 

period must be counted. 

o A waiver can be processed for the required 10-hour break between successive 

work periods. The requirements of Section 9, Waivers, apply to this method. 

x See Section 20, Examples 8 and 9. 

Incidental duties performed off site: 

x Licensees may exclude from the calculation of an individual’s work hours unscheduled 

work performed off-site (e.g., technical assistance provided by telephone from an 

individual’s home or an unscheduled teleconference, calls between the licensee and a 

vendor or between parties on behalf of the licensee) provided the total cumulative 

duration of the work, which is required by the licensee, does not exceed a nominal 30 

minutes during any single break period. 

x For the purposes of compliance with the minimum break requirements and the minimum 

day off requirements, such duties (work periods less than nominal 30 minutes) do not 

constitute work periods or work shifts. 

x Professional time is not discouraged, for example after-hours study time that is not 

required by the licensee may be excluded from work-hour calculations. As with any 

academic setting and curriculum, after-hours study time varies from individual to 

individual. Appropriate after-hours study time complements the utility provided training 

to ensure the learning process occurs and optimal information retention is achieved. 

x This does not include short-duration, infrequent or irregular telephone calls that do not 

interrupt a sleep period to verify or discuss plant and equipment status, provided the 

cumulative duration of these calls does not exceed a nominal 30 minutes during any 

single break period. 

x See Section 20, Examples 10, 11, 12 and 17. 

Shift duration extensions (holdovers): 

x When considering shift extensions for individuals performing covered work, all hours 

worked by the individual shall be included. For example, if an individual has performed 

15 hours of non-covered work, and the individual is needed to perform additional covered 

work that extends beyond 16 hours in a 24-hour period, then a waiver to exceed the work 

hour limits shall be approved prior to the individual exceeding the 16-hour limit. 
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x On the other hand, if the individual has performed 14 hours of covered work and is 

needed to perform additional non-covered work, then the programmatic approvals of this 

document do not apply. However, the additional work hours are included in consideration 

of any other limits if the individual subsequently performs covered work. 

Official union time: 

x Unpaid Union business is considered personal time and not counted in work hour 

calculations (including no impact to breaks and ceiling limits). 

x Grievance meetings held pursuant to a contract between the Union and the licensee where 

personnel are required to be in attendance are considered time that must be considered in 

work hour calculations. 

Travel time: 

x Travel time that is required by the licensee is work performed for the licensee. 

o Should the worker be required to travel to another work location within the same 

licensee organization, the licensee needs to count the travel time in the work hour 

calculation. by applying the following:

o Travel time that is required by the licensee and occurs wholly within an 

individual’s normally scheduled work period should be counted as work hours 

and may be treated as time performing non-covered duties when applying work 

hour controls.

o A normal daily commute is not considered to be work performed for the licensee 

and should not be included in the calculation of work hours. Should the worker 

be required to travel to another work location, a nominal difference in the 

commute of 30 or fewer minutes need not be included in the calculation of work 

hours. Similarly, should the worker be required to travel to another work 

location within the same licensee organization that does not incur additional travel 

time using an established method, may be treated as a daily commute with no 

additional accrual of work hours. 

o If the worker is required to extend his/her shift schedule by traveling (either at the 

end or beginning of a work period), then extend the work period hours by the 

nominal travel time and apply the minimum break and ceiling rules accordingly. 

This time may be treated as non-covered work hours, when applying work hour 

controls...

o If the worker is required to travel on his/her own time, wholly outside of a normal 

work period, then consider this an extension to the preceding or succeeding work 

period and increase the minimum break time (either the minimum work period 

break of 10 hours or minimum 9-day break requirement as appropriate) by the 

nominal travel time to ensure adequate opportunity for a full rest period. 

o Nominal travel time is determined using an established Web-based mapping 

application. 
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See Section 20, Examples 5 and 6. 

Shift turnover: 

x Licensees may exclude from the calculation of an individual’s work hours that portion of 

shift turnover that occurs outside of an individual’s shift. Shift turnover includes those 

activities that are necessary to safely transfer information and responsibilities between 

two or more individuals preceding a shift or immediately following a shift. Shift turnover 

activities may include, but are not limited to, discussions of the status of plant equipment, 

arming and disarming of armed security officers, transit to and from turnover stations 

including compliance with radiological and personal safety requirements, and the status 

of ongoing activities such as extended tests of safety systems and components. 

o Shift turnover may be excluded from the calculation of an individual’s shift 

provided that the time excluded is limited to those activities necessary to transfer 

information and responsibilities. 

o The exclusion of turnover is limited to the transfer of security or safety 

responsibilities between two or more individuals working contiguous shifts. 

o Holdover time to cover for a late arrival or an early arrival for a meeting or 

special evolution may not be considered part of turnover and must be included in 

work hour calculations. 

x See Section 20, Examples 18A, B, C and D. 

7.3 DAYS OFF

A day off is a calendar day in which an individual does not start a work shift. 

Individuals may change shift schedules during the shift cycle. The following guidance applies: 

x For shift schedule transitions, licensees should calculate the average duration of the shifts 

worked and to be worked during a period of not more than six weeks that encompasses 

the schedule transition to determine the applicable day off requirement. If the average 

shift schedule is not more than 9 hours, then the minimum day off requirements for eighthour shift schedules would apply. If the average shift schedule is more than nine hours 

but not more than 11 hours then the requirements for a 10-hour shift would apply. If the 

average shift schedule is more than 11 hours then the requirements for a 12-hour shift 

apply. 

The following guidance should be applied in determining if a day off has been provided: 

For security personnel during the actual conduct of force-on-force tactical exercises evaluated by 

the NRC, if security personnel work on his/her day off, this work day may be counted as a day 

off in the calculation of minimum days off. 

x Licensees may exclude from the calculation of an individual’s work hours the time the 

individual works unscheduled work hours, above the normal scheduled work hours, for 

the purpose of participating in the actual conduct of an unannounced emergency 
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preparedness exercise or drill. If an individual is on a day off, it is still considered a day 

off. 

x Licensees may exclude from the calculation of an individual’s work hours unscheduled 

work performed off-site (e.g., technical assistance provided by telephone from an 

individual’s home) provided the total duration of the work, which is required by the 

licensee, does not exceed a nominal 30 minutes during any single break period. For the 

purposes of compliance with the minimum break requirements and the minimum day off 

requirements, such duties do not constitute work periods or work shifts. 

x After-hours study time during training weeks shall be excluded from work hour 

calculations. As with any academic setting and curriculum, after-hours study time varies 

from individual to individual. Appropriate after- hours study time complements the utility 

provided training to ensure the learning process occurs and optimal information retention 

is achieved. 

x Activities initiated by the individual (not required by the licensee) may be performed at 

home on a day off and not be considered “work,” (e.g., studying, reading work-related 

material, reading email). 
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TABLE 7: WHAT TO INCLUDE/EXCLUDE WHEN CALCULATING WORK HOURS

[See rule for details - table provides only general summary of the rule] 

Sub-section Item Must Include May Exclude

26.205(b) Performing 

duties for 

licensee 

Must include amount of time 

individual performs duties for 

the licensee, including from offsite locations in some 

circumstances (see below 

26.205(b)(5)) 

May exclude off-hours voluntary study 

time, as long as it is not required or 

performed for the licensee (from Reg 

Guide 5.73)

26.205(b)(1) Shift 

Turnover 

Must include (examples; not 

exhaustive list): 

x Hours worked during 

turnovers between 

individuals within a shift 

period due to rotations or 

relief within a shift 

x Shift holdovers to cover 

for late arrivals of 

incoming shift members 

x Early arrivals for 

meetings, training, or preshift briefings for special 

evolutions 

x Holdovers for interviews 

needed for event 

investigations 

May exclude: 

x Those activities necessary to 

safely transfer information and 

responsibilities between 

contiguous shifts 

x Arming and disarming for security 

personnel (from Reg Guide 5.73)

x Personnel donning/doffing 

radiation protective gear and 

transiting to and from a job site 

where continuous monitoring is 

required, which also limits this 

exclusion to turnover activities 

between contiguous shifts 

26.205(b)(2) Within-shift 

break and rest 

periods 

Must include break or rest 

periods during which there is 

no reasonable opportunity and 

accommodation for restorative 

sleep, such as most lunch 

breaks 

May exclude that portion of a break or 

rest period during which there is 

reasonable opportunity and 

accommodation for restorative sleep 

26.205(b)(3) Beginning or 

resuming 

duties subject 

to work hour 

controls 

Must include (count) all hours 

performing duties for the 

licensee, including hours 

worked on duties that are not 

subject to work hour controls if 

the individual performs any 

covered duties during the 

calculation period 

The hours worked before the beginning 

or resumption of covered work are not 

subject to work hour controls 

themselves, even though they must be 

included in the count once covered work 

is begun or resumed 
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Sub-section Item Must Include May Exclude

26.205(b)(4) Unannounced 

emergency 

preparedness 

exercises and 

drills 

Must include hours spent 

preparing for the exercises and 

drills, but only if the individual 

also performs covered duties 

during the calculation period 

May exclude from calculation the 

unscheduled work hours to participate in 

the actual conduct of such exercises or 

drills 

26.205(b)(5) Incidental 

duties 

performed off 

site 

Separate unscheduled phone 

calls that together exceed the 

nominal 

30 minutes (e.g., 2 phone calls 

of 20 min. each, 2 hours apart) 

must be included as a 

separate work period or as 

part of a previous or upcoming 

work shift 

May exclude unscheduled work 

performed off site if total duration does 

not exceed nominal 30 minutes during 

any single break period 

This work also does not constitute “work 

periods” or “work shifts” when calculating 

rest breaks or MDOs 

(From NRC 

Guidance)

Travel time Must include travel time in 

cases where: 

x The individual is 

performing work for the 

licensee 

x The travel is in excess of 

the individual’s regular 

commute 

May exclude travel time if: 

x The individual is not performing 

work for the licensee 

x The travel is no longer than, or is 

part of the individual’s regular 

commute 

x Individual has initially reported to 

the site to begin work and has not 

yet been granted unescorted 

access 

x Travel time that is not directed by 

the licensee may likewise be 

excluded 

26.207(b) Force-onforce tactical 

exercises 

exception 

Must include hours spent 

preparing for the exercises and 

drills, but only if the individual 

also performs covered duties 

during the calculation period 

May exclude shifts worked by security 

personnel (may or may not be actual drill 

participants) during the actual conduct of 

NRC-evaluated force-on-force tactical 

exercises when calculating individual’s 

number of days off (as per MDO 

requirements, or when calculating 

weekly average hours worked (as per 

the MAWH requirements)** 

** In practice, licensees should exclude from the calculation of hours worked during the actual 

conduct of NRC-evaluated force-on-force tactical exercises only those hours worked in excess of 

54 hours during the week of the exercise. 
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8 APPLICATION OF MINUMUM DAYS OFF (MDO) AND/OR MAXIMUM 

AVERAGE (MAWH) WORK HOURS ALTERNATIVE (26.205 (D)(3),(D)(7)) 

NOTE: Ceiling limits and break requirements apply to covered workers under all circumstances 

when determining work hours to be worked unless waived or specifically exempted. See Section 

7 and Table 7 for specific guidance on exclusions and inclusions impacting work hour 

calculations. 

8.1 GENERAL INFORMATION

In order to prevent workers from experiencing the effects of cumulative fatigue, a licensee may 

implement the minimum days off (MDO) or maximum average work hours (MAWH) protocol. 

A licensee may not utilize a combination of the two protocols simultaneously (e.g., operations 

staff on MDO and maintenance staff on MAWH). 

During unit outages, a licensee may implement either method of fatigue management. This may 

differ from the on-line protocol (e.g., on line may be using MAWH, where in an outage the 

MDO method would normally be employed). 

Station policies should delineate the chosen method for applying work hour controls to manage 

fatigue during on-line and outage conditions. 

The following guidance applies to both MDO and MAWH methods of work hour control: 

x Work hours are calculated as the amount of time an individual performs any duties for 

the licensee including but not limited to the following: 

o All within-shift break times and rest periods during which there is no reasonable 

opportunity or accommodations appropriate for restorative sleep (e.g., a nap). 

o Shift holdovers to cover for late arrivals of incoming shift members. 

o Early arrivals of individuals for licensee required meetings, training or pre-shift 

briefings for special evolutions. (These activities are not considered shift turnover 

activities.) 

o Holdovers for interviews needed for event investigations. 

x Within-shift breaks and rest periods: 

o Time spent at lunch, although non-productive, is included in the work hour 

calculations. 

o Break time allowed during the scheduled work day is included in the work hour 

calculation. 

o That portion of a break or rest period during which there is a reasonable 

opportunity and accommodation for restorative sleep on site (e.g., a nap of at least 

30 minutes) may be excluded. 
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x Shift turnover: 

o Licensees may exclude shift turnover from the calculation of an individual’s total 

work hours. 

o The level of precision in determining the time duration for turnover should not be 

greater than 15 minutes. 

8.2 MINIMUM DAYS OFF (MDO) METHOD

Minimum Day Off (MDO) 

MDO is a method for managing cumulative fatigue that establishes the minimum number of days 

off that must be taken in order to comply with the appropriate on-line or outage work hour 

controls. The required number of days off varies by plant operating status, shift schedule and job 

duties. 

Applying MDO Method 

The licensee may elect to use a rolling or fixed (maximum of) six-week period for the purposes 

of determining the minimum days off. The actual repeatability of the schedule rotation may 

exceed six weeks; however, the shift cycle used for calculating the minimum days off cannot 

exceed six weeks. 

Generally a rolling evaluation period for MDO evaluations takes into account the current day and 

looks back at the previous days in the evaluation period for compliance. For example, an 

individual on a 42-day (six-week) rolling evaluation period—for the purpose of compliance with 

the MDO requirement—the current day and the last 41 days of actual time are used to determine 

if the individual has had the required days off. When tomorrow is reached, it is that day and the 

previous 41 days, etc. For the purposes of predicting compliance, the current day and the next 41 

days of scheduled time are used. 

For a 42-day (six-week) fixed evaluation period, an individual must meet the MDO requirement 

for their job function and average shift length for days 1 to 42. The day following day 42 is a 

new day 1 and a new 42-day evaluation period begins. These evaluation periods go in blocks 

from 1-42 and then start over. Once the schedule goes beyond day 42, the evaluation period 

looks ahead another 42 days and does not look back like the rolling evaluation method does. 
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The on-line MDO method requires that in a shift cycle, the worker will receive an average 

number of Days Off per week equal to or greater than the MDO requirement for the shift 

schedule that applies. 

Covered Individual 8-hour shift 10-hour shift 12-hour shift 

Actual Average 

Shift Hours 

8 to less than or 

equal to 9 hours 

Greater than 9 to 

less than or equal 

to 11 hours 

Greater than 11 and 

less than or equal to 

13 12 hours 

Maintenance 1 day off per week 2 days off per 

week 

2 days off per week 

Operations, HP, 

Chemistry, Fire 

Brigade 

1 day off per week 2 days off per 

week 

2.5 days off per week 

Security 1 day off per week 2 days off per 

week 

3 days off per week 

The planned shift schedule is used to establish the beginning minimum days off (MDO) 

requirement. If the actual hours worked do not deviate from the planned shift schedule, the 

required MDO will not change. 

Periodically, workers and supervisors may need to work unscheduled hours to meet station 

needs. An accumulation of unscheduled work hours over a shift cycle may affect the MDO 

requirement that applies to individuals or crews. 

The above table is for a shift schedule that is averaged over a shift cycle of 42 days or less as 

applicable. If the worker averages more hours than previously scheduled the licensee must 

recalculate the average hours worked per shift to ensure the proper MDO (8, 10 or 12) is met 

prior to the end of the shift cycle. For actual shift rotation cycles greater than 42 days, the 

averages must be calculated over a period of 42 days or less. 

If the individual works for a licensee for a period less than one week, the MDO requirement is 

not applicable. 

Calculating Work Hours Using the MDO Method 

Licensees shall ensure that individuals have, at a minimum, the number of days off specified for 

their shift schedule. 

Resets from deviations must additionally ensure that actions are in place to comply with MDO 

requirements by the end of the shift cycle if using the fixed-cycle method in work hour 

calculations. 
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Transitions Between On-Line Schedules 

Licensees may transition individuals or crews between shift schedules by ending a shift cycle 

and starting a new shift cycle with a different shift schedule. The following guidance applies: 

x Terminating the shift cycles: Ensure that the individuals meet the MDO requirement 

applicable to the shift schedule that the individuals were working before it was 

terminated. 

In these instances, for the purpose of determining compliance with the MDO 

requirements, the licensee may average the individuals’ work hours over a period 

immediately preceding the transition that is equal in length to the shift cycle the 

individuals were working before the transition (e.g., six weeks, if the shift cycle was six 

weeks in length). The licensee should then ensure that the individual meets the applicable 

MDO requirement for the new shift schedule going forward from the beginning of the 

new shift cycle. A shift cycle may be as short as one week. There are no MDO 

requirements for shift cycles less than seven days. 

Transitions Between On-Line and Outage Schedules 

The ceiling and break requirements apply during the transitions. The outage MDOs only apply 

while in a unit outage. On-line MDO rules take effect the first shift after the reactor unit achieves 

75 percent reactor power or until seven calendar days have elapsed since reconnecting 

reconnects the reactor unit to the electrical grid, whichever is shorter. For the first 42 days after 

an outage (for six-week cycles), the employee must be evaluated using the fixed shift cycle 

method. 

Transitions Between Covered Groups or Onto a Covered Shift 

If an individual begins or resumes performing for the licensee any covered work during the 

calculation period, the licensee shall include in the calculation of the individual’s work hours all 

work hours worked for the licensee, including hours worked performing duties that are not 

covered work and control the individual’s work hours. 

Ceiling limits and break requirements always apply. 

A minimum of one day off in the preceding seven-day period is acceptable for individuals to 

begin or resume covered duties and for individuals who have been working an 8-hour shift 

schedule, as either day or shift workers, and are transitioning (1) from a non-covered group to a 

covered group or (2) from a covered group to another covered group that has more stringent 

MDO requirements. 

A minimum of two days off in the preceding seven-day period is acceptable for individuals who 

have been working a 10- or 12-hour shift schedule, as either day or shift workers, and transition 

(1) from a non-covered group to a covered group or (2) from a covered group to another covered 

group with more stringent MDO requirements. 

A minimum of two days off in the preceding seven-day period is acceptable for operators at a 

multi-unit site with one or more units in an outage, if the operators have been working outage 
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hours on 10- or 12-hour shifts before they transition to an operating unit as members of the 

minimum shift complement described in Section 6.1. 

There is no minimum day off requirement for transitioning from a non-covered to covered work 

if the previous schedule was less than seven days in length. 

See Section 20, Example 7. 

Unit Outage, Security System Outage or Increased Threat Condition Work Hour Controls 

– MDO Methodology 

NOTE: During a unit outage, the options for control of work hours for covered workers are 

outage MDOs or staying with on-line work hour controls (MDO). 

NOTE: If an individual is performing work under multiple categories, the most restrictive work 

hour controls apply 

During the first 60-day period of a unit outage, the Covered Worker under outage rules will 

receive an average number of Days Off equal to or greater than the MDO requirement for the 

shift schedule that applies. 

Covered 

Individual** 

8-hour shift 

Days off 

10-hour shift 

Days off 

12-hour shift 

Days off 

Actual Average 

Shift Hours 

8 to less than or 

equal to 9 hours 

Greater than 9 to 

less than or equal 

to 11 hours 

Greater than 11 

and less than or 

equal to 13 12 

hours 

Maintenance 1 day off per week 1 day off per week 1 day off per week 

Operations, HP, 

Chemistry, Fire 

Brigade 

3 days off in each 

successive (i.e., 

non-rolling) 15-day 

period 

3 days off in each 

successive (i.e., 

non-rolling) 15-day 

period 

3 days off in each 

successive (i.e., 

non-rolling) 15-day 

period 

Security 4 days off in each 

successive (i.e., 

non-rolling) 15-day 

period 

4 days off in each 

successive (i.e., 

non-rolling) 15-day 

period 

4 days off in each 

successive (i.e., 

non-rolling) 15-day 

period 

**If the worker averages more hours than previously scheduled, the licensee must 

recalculate the average hours worked per shift to ensure the proper MDO (8, 10 or 12) is 

met prior to the end of the listed period. 

During the first 60-day period of an unplanned security system outage or increased threat 

condition, the requirements for MDOs for security personnel do not apply. 

Extensions of 60-day period may be provided to individuals in seven-day increments for each 

non-overlapping seven-day period in which the individual has worked not more than 48 hours 

during the unit or security system outage or increased threat condition. 
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This extension can be made any time in the outage period after the less-than-48-hour work week. 

This extension is calculated by a week defined as seven days. 

If every week of the initial 60 days is used for the extension only 56 days (eight weeks) are 

available for the extension. 

The 48-hour allowance can only be banked during the first 60 days of the outage and used no 

later than day 116 of the outage. 

See Section 20, Examples 13 and 14. 

8.2.1 Unexpected Outages 

Unexpected outages can impact the licensee’s ability to demonstrate compliance with the normal 

MDO requirements. During an outage, days off are required on a day basis every rolling sevenday period for personnel performing maintenance activities and every non-rolling 15-day period 

for all other covered workers for the duration of the outage and not on an average basis as when 

on-line. 

When entering an unexpected outage, the licensee shall be considered to be in compliance with 

the rule if the schedule for the shift cycle would have provided for the required minimum days 

off. 

8.3 MAXIMUM AVERAGE WORK HOURS (MAWH)

Maximum Average Work Hours (MAWH) Method 

The alternative approach to on-line MDO is a weekly maximum average of 54 hours worked, 

based on a rolling averaging period of up to six weeks. This alternative is applicable to all 

covered workers, regardless of classification. 

The rolling periods used in the MAWH calculations roll by one full week at a time. The week 

may start on any specific day and must be consistent through the calculation period and 

documented in the controlling procedure. 

Rolling Period 

The averaging period starts “rolling” after a work history for a covered worker has been 

established equal to the length of the averaging period. 

The averaging period rolls by one full week at a time. The week does not have to start on any 

specific day but must be consistent through the calculation period and documented in the 

controlling procedure. 

Shifts that bridge the point in time during the week when the averaging period rolls forward one 

week may be counted in one of two ways and the method must be documented in the controlling 

procedure: 
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x The hours for that shift may be included in the week the shift starts. 

x The hours may be included in the weeks the hours are worked. 

Calculating the Average 

While the calculation of the average work hours worked occurs at the end of the averaging 

period, there is a need to be continually calculating the average looking forward to identify work 

hours that will potentially exceed the limit so that work hours can be adjusted or, as appropriate, 

waivers can be prepared in advance of exceeding the limit. 

One simple method is to add up the work hours from the previous five weeks and subtract from 

324, giving the worker the maximum amount of hours that can be worked the upcoming week. 

Beginning a Rolling Averaging Period 

In the case of a worker who has not been performing on-line covered work and will be 

transitioning to on-line covered work, there are two options for setting up the schedule to start 

the averaging period: 

x The schedule established for the worker for the initial averaging period (e.g., initial six 

weeks) can be set up as a fixed period which averages 54 hours or less. The first week 

after this (e.g., seventh week worked) is the start of the rolling schedule. 

x The number of weeks in the averaging period for the worker is determined and the hours 

for the past number of work weeks that is equal to the averaging period are calculated to 

establish the history needed to begin rolling. 

Partial Averaging Periods 

Partial averaging periods occur when a worker will not be working a full averaging period. 

If the individual is working for the licensee for less than a full week, then only ceiling limits and 

break requirements apply. 

If greater than one full week, but less than a full averaging period, then the licensee must limit 

the average work hours to 54 hours per week or less averaged over the partial averaging period. 

Truncated Schedules 

If the fixed schedule is truncated due to unforeseeable events outside the control of the licensee, 

the worker will be considered to be in compliance with the rule if the schedule for the averaging 

period would have met the on-line averaging limit should the truncation not have occurred. 

Examples of unforeseeable events include: 

x Unexpected unit outage. 

x A declared emergency as defined by the licensee’s emergency plan. 

x Duties of the worker are terminated. 
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x An unplanned security system outage (security only). 

x An increased threat condition (security only). 

Following such an event, the licensee may start a new averaging period or choose not to truncate 

the averaging period. 

An extended absence is not considered an interruption or truncation of an averaging period but is 

considered part of the averaging period. 

Unit Outage, Security System Outage or Increased Threat Condition Work Hour Controls 

– MAWH Methodology 

During a unit outage, the options for control of work hours for covered workers are outage 

MDOs (Section 8.2.4) or staying with MAWH work hour controls. 

In cases of an unexpected outage, which is anticipated to last only a short time, remaining on 

MAWH may be administratively beneficial. 

8.4 OUTAGE SPECIFIC GUIDANCE – WORK HOUR CALCULATIONS

Detailed guidance for transitioning from on-line to outage and vice-versa is contained in Section 

10, Transitions, and Table 10. 

Contract and Licensee Outage Workers 

Licensee employees and contractor/vendor personnel may go from an outage at one site to an 

outage at another site. 

When a licensee employee or contractor/vendor performs covered work for a licensee during two 

or more unit outages or security system outages (or a combination thereof), and the interval(s) 

between successive outages is less than 9 days, the receiving licensee should make a reasonable 

judgment as to the individual’s fitness-for-duty relative to fatigue. 

Licensees are not responsible for tracking individual’s hours between outages for different 

licensees. No MDOs are required for individuals working for the licensee for a period of less 

than one week. 

If the Contractor does not have unescorted access, then the work performed is not covered. See 

Section 20, Example 1. 

Operator Relief at Multi-Unit Sites 

An operator who has been working outage work hours and has had two days off in the previous 

seven-day period may provide relief to the operator at the controls or the senior operator in the 

control room, if an appropriately qualified operator who has been working non-outage work 

hours is not immediately available to provide relief. 
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If an operator who has been working outage work hours and has had two days off in the previous 

seven-day period is not immediately available, an operator who has been working outage hours 

may provide: 

x Short-term relief (up to two hours) for the operator at the controls or the senior operator 

in the control room without a waiver. 

x Longer-term relief (more than two hours) under a waiver of the MDO or MAWH 

requirement that is applicable to the shift schedule (i.e., 8-, 10-, or 12-hour shifts) for 

personnel assigned to the operating unit. 
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9 EXAMPLES OF APPLYING ALL WORK HOUR CONTROLS (26.205) 

9.1 GENERAL WORK HOUR REQUIREMENTS

If a work hour limit will be exceeded, it shall be identified before the hours are worked. To 

determine if the minimum days off requirements will be met (before working the additional 

hours) a licensee may use one of the following methods: 

x Calculate the minimum days off based on a backwards look of the previous five weeks 

and determine if the extra hours worked in the sixth week would still meet the 

requirement (rolling six-week cycle method). 

x Ensure that sufficient days off still exist (within the shift cycle) to meet the minimum 

days off requirements (fixed shift cycle method).

Hours worked should be evaluated to determine if any limit will be exceeded based on the work 

schedule by picking a future time (T) on the work schedule and asking, “how many hours will 

have been worked during the T-24 hours, T-48 hours, or T-168 hours (T-7 calendar days).” 

The limit for 72 hours in a seven-day period may be calculated using a rolling 168-hour window 

or based on seven calendar days (i.e., a backwards look at the number of hours that have or will 

have been worked based on a time in the future). 

The period is not re-zeroed or the “clock reset” following a day off or after obtaining 

authorization to exceed the limits.

Licensees shall establish the accounting practices to be used in monitoring hours worked. In 

many cases this will parallel the established system for compensation. However, the accounting 

practices may be different from record keeping for payroll purposes. Work periods should be 

rounded consistently.

Work hour records should show the number of hours worked each calendar day. Work period 

start and stop times should be documented in a consistent manner. The level of precision in 

determining start and end times should not be greater than nominal 15 minute increments.

See Section 20, Examples 5-7, for clarifications. 
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TABLE 9A: WORK HOUR CONTROLS – NORMAL OPERATIONS

[See rule for details - table provides only a general summary of the rule] 

Subsection

Item Controls for Individuals Performing Duties

Subject to Work Hour Controls

Note

26.205(d)(1) Work hour limits Ensure that the individual’s work hours do not 

exceed: 

x 16 hours in any 24-hour period 

x 26 hours in any 48-hour period 

x 72 hours in any 7-day period 

x Rolling limits 

x 7-day period can be 

calculated as 168 hours or 

7 calendar days 

26.205(d)(2) Rest break 

requirements 

Ensure that the individual has at minimum: 

x 10-hour break between successive work 

periods 

o May use 8-hour break when needed 

to accommodate scheduled crew 

shift transition and transition 

between work schedules 

x 34-hour break in any 9-day period 

x Rest break is the interval 

of time between 

successive work periods 

during which individual 

does not perform any 

duties for licensee 

x Break time may include 

shift turnover 

x 9-day period can be 

calculated as 216 hours or 

9 calendar days 

26.205(d)(3) Minimum Days 

Off (MDO) 

If using the MDO method, ensure that the 

individual has at minimum the following days 

off per week averaged over shift cycle: 

x 8-hour shift schedule: 1 day off/week 

average 

x 10-hour shift schedule: 2 days off/week 

average 

x 12-hour shift schedule: per week: 

o 2.5 days off average for those 

performing duties listed in 

26.4(a)(1)-(3) [Ops/HP-Chem/Fire 

brigade] 

o 2 days off average for those 

performing duties listed in 

26.4(a)(4) [maintenance and quality 

inspections of maintenance] 

o 3 days off average for those 

performing duties listed in 

26.4(a)(5) [security]

x Day off defined as a 

calendar day during which 

individual does not start a 

work period 

x Duration of shift cycle may 

not exceed 6 weeks for 

purpose of calculating 

days off 

x Shift cycle may not be less 

than 1 week [RG 5.73]

x Days off per week average 

is calculated as: (# days 

off in shift cycle) divided by

(# weeks in shift cycle) 
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26.205(d)(7) Maximum 

Average Work 

Hours (MAWH) 

Alternative to 

MDOs 

If using the maximum average work hours 

(MAWH) method, ensure that individuals work 

no more than a weekly average of 54 hours 

x Averaged over period up to 6 weeks 

x Averaging period advances by 7 

consecutive calendar days at finish of 

every averaging period 

For shifts that span 2 calendar 

days, either: 

Count all hours worked as if they 

were worked on the day the shift 

started, or 

Count hours on calendar days 

they were actually worked 

26.205(d)(8) State Alternative 

Used 

Clearly state in the FFD policy and procedures 

which requirements are being applied during 

both operations and outages: MDO or MAWH 

requirements 
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TABLE 9B: WORK HOUR CONTROLS – OUTAGES

[See rule for details - table provides only a general summary of the rule] 

SubsectionItem Controls for Individuals Performing

Duties Subject to Work Hour Controls

Note

26.205(d)(1) Individual work 

hours 

Ensure that the individual’s work hours do 

not exceed: 

x 16 hours in any 24-hour period 

x 26 hours in any 48-hour period 

x 72 hours in any 7-day period 

Rolling limits 

7-day period can be calculated as 168 

hours or 7 calendar days 

26.205(d)(2) Rest break 

requirements 

Ensure that the individual has at minimum: 

x 10-hour break between successive 

work periods 

x May use 8-hour break between work 

periods when break of less than 10 

hours is needed to accommodate a 

crew’s shift schedule transition from 

unit outage to operation. 

x 34-hour break in any 9-day period 

A rest break is the interval of time 

between successive work periods 

during which the individual does not 

perform any duties for licensee 

Break time may include shift turnover 

9-day period may be calculated as 

216 hours or 9 calendar days 

26.205(d)(4) Unit outage – 

minimum days 

off 

– Operations, 

HP/Chem/Fire 

brigade 

If using the MDO method, ensure that the 

individuals working on outage activities and 

performing duties listed in 26.4(a)(1)-(3) 

[operations, HP/chem., fire brigade] have at 

minimum the following days off: 

x 3 days off each successive 15-day 

period 

Requirement applies for the first 60 

days of a unit outage 

Requirement applies to successive 

15-day periods (i.e., non-rolling) 

Applies only to individuals working on 

outage activities 

26.205(d)(4) Unit outage – 

minimum days 

off 

– maintenance

and quality 

inspections of 

maintenance

If using the MDO method, ensure that the 

individuals working on outage activities and 

performing duties listed in 26.4(a)(4) 

[maintenance and quality inspections of 

maintenance] have at minimum the 

following days off: 

x 1 day off in any 7-day period 

Requirement applies for the first 60 

days of a unit outage 

Requirement applies to rolling 7-day 

periods 

Applies only to individuals working on 

outage activities 
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26.205(d)(5) Unit outage, 

security system 

outage, or 

increased treat 

condition – 

minimum days 

off 

– security 

If using the MDO method, ensure that the 

individuals performing duties listed in 

26.4(a)(5) [security] have at minimum the 

following days off: 

x For unit outage (planned or 

unplanned) or for planned security 

system outage: 4 days off each 

successive 15-day period 

x For unplanned security system 

outage or increased threat condition: 

no minimum days off are required 

Requirement applies for the first 60 

days of a unit outage, security system 

outage, or increased threat condition 

Requirement applies to successive 

15-day periods (i.e., non-rolling) 

Applies only to individuals working on 

outage activities 

26.205(d)(6) Extension of 

outage/threat 

condition 

requirements 

If using the MDO method, the 

outage/increased threat MDO requirements 

may be extended on an individual basis in 

7-day increments beyond the 60-day limit 

For each non-overlapping 7-day 

period during an outage or increased 

threat condition in which the individual 

did not work more than 48 hours 

Applies only to individuals working on 

outage activities 

26.205(d)(7) Alternate method 

of control of work 

hours 

Licensees may, as an alternative to 

complying with the minimum days off 

requirements in § 26.205(d)(3), comply with 

the requirements for maximum average 

work hours 

Licensee may elect to remain on 

MAWH during an outage vice Outage 

MDO 

For short-term outages it may be 

administratively beneficial 

26.205(d)(8) FFD program 

requirements 

Each licensee shall state, in its FFD policy 

and procedures required by § 26.27 and § 

26.203(a) and (b), the requirements with 

which the licensee is complying: the 

minimum days off requirements in § 

26.205(d)(3) or maximum average work 

hours requirements in § 26.205(d)(7) 

Licensee may not allow one work 

group to apply MDO and another to 

apply MAWH 

The site must apply the selected 

method of compliance to all work 

groups 
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TABLE 9C: APPLYING EACH CONTROL – WORK HOUR LIMITS AND REST BREAK REQUIREMENTS

Topic 16 hours in 24 26 hours in 48 72 hours in

7 days/168 hours

10-hour rest break 34-- rest break in 9- 

day/216-hr

Limit applies to: All covered workers All covered workers All covered workers All covered workers All covered workers When limits apply: At all times individual 

is performing covered work for the licensee 

At all times individual 

is performing covered work for the licensee 

At all times individual is 

performing covered work for the licensee 

Before the start of a work period in which the individual is performing covered work for the licensee 

At all times an individual is 

performing covered work for the licensee 

Work hour limits and break requirements 

16 work hours 26 work hours 72 work hours 10 hour rest break 

(continuous 10 hour 

34 hour rest break (continuous 34 hour break) 

Allowed deviations None None None An 8 hour rest break is 

allowed when needed to accommodate a crew’s shift schedule transition from unit outage to operation. 

None 

Apply hours worked to: 24 hours 48 hours 7 days or 168 hours The time between the 

end of one work period and the start of the next work period 

 9 days or 216 hours 

Calculation period Rolling Rolling Rolling Sequential Rolling
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Topic 16 hours in 24 26 hours in 48 72 hours in

7 days/168 hours

10-hour rest break 34-- rest break in 9- 

day/216-hr

 Calculation Period The calculation 

period has no designated starting or ending time relative to the calendar or clock. It continues through work hours and breaks and ends 24 hours after it starts For individuals starting or resuming covered work, the 24-hour calculation period begins 24hours before the start of covered work 

The calculation period has no designated starting or ending time relative to the calendar or clock but continues through work hours and breaks and ends 48 hours after it starts For individuals starting or resuming covered work, the calculation period begins 48 hours before the start of covered work 

If using a 7-day period, the calculation period starts at 12 am of a calendar day, and ends at 11:59 p.m. 7 calendar days later If using 168-hour period, the calculation period has no designated starting or ending time relative to the calendar or clock. It continues through work hours and breaks and ends 168 hours after it starts For individuals starting or resuming covered work, the calculation period begins 7 days or 168 hours before the start of covered work 

The calculation period begins at the end of one work period and ends at the start of the next (subsequent) work period For individuals starting or resuming work the calculation period begins at the end of the previous work period 

If using a 9-day period, the calculation period starts at 12am of a calendar day, and ends at 11:59 pm 9 days later. If using a 216 hour period the calculation has no designated starting or ending time relative to the calendar or clock. It continues through work hours and breaks and ends 216 hours after it starts. For individuals starting or resuming covered work, the calculation period begins 9 days or 216 hours before the start of covered work. 

By what increments does the calculation period move? 

It rolls in hour-byhour increments It rolls in hour-by-hour increments If using 7-day period, it rolls in day-by-day increments 

If using 168-hour period, it rolls in hour-by-hour increments 

It moves sequentially from break period to break period. 

- If using 9-day period, it rolls in day-by-day increments - If using 216-hour period, it rolls in hour-by-hour increments 
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TABLE 9D: APPLYING EACH CONTROL – MDO AND MAWH REQUIREMENTS

Information needed to apply either MDO or the MAWH requirements 

Topic MDO – Normal Operations MDO – Outage

Conditions – Ops, 

HP/Chem, Fire Brigade

MDO – Outage Conditions 

– Maintenance and 

Quality Inspections

MDO – Outage

Conditions – Security

MAWH 54-hr Alternative

To whom does it apply? 

All covered workers 

To determine specific number days off required, determine both individual’s duties as well as applicable shift schedule (based on average hours worked per day over shift cycle) 

All covered workers performing duties listed in 26.4(a)(1)-(3) 

All covered workers performing duties listed in 26.4(a)(4) 

All covered workers performing duties listed in 26.4(a)(5) 

All covered workers, irrespective of duties or shift schedule 

When does it apply? 

At all times the individual is 

performing covered work for the licensee during normal operations 

At all times the individual is performing covered 

work for the licensee 

under outage conditions; 

some exceptions for operators at multi-unit 

sites 

At all times the individual is performing covered work for the licensee under outage 

conditions 

At all times the individual is performing covered work for the licensee under outage conditions 

At all times the individual is performing covered work for the licensee 
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Topic MDO – Normal Operations MDO – Outage

Conditions – Ops, 

HP/Chem, Fire Brigade

MDO – Outage Conditions 

– Maintenance and 

Quality Inspections

MDO – Outage

Conditions – Security

MAWH 54-hr Alternative

What is the limit or value to track? 

Days off (defined as a calendar day during which individual does not start a work shift), as follows: 

x 8-hour shift schedule: 

1 day off/week average 

x 10-hour shift schedule: 

2 days off/week average 

x 12-hour shift schedule: 

per week: o 2.5 days off 

average for those 

performing duties listed in 

26.4(a)(1)- (3) [OPS/HP/Chem/ Fire brigade] 

o 2 days off average 

for those performing duties listed in 26.4(a)(4) [maintenance] 

o 3 days off average 

for those performing duties listed in 26.4(a)(5) [security] 

3 days off (defined as a calendar day during 

which individual does not 

start a work shift) in each successive 15-day 

period 

1 day off (defined as a calendar day during which 

individual does not start a 

work shift) in any 7-day 

period 

4 days off (defined as a calendar day during which 

individual does not start a 

work shift) in each successive 15-day period 

for unit outages (planned 

or unplanned) or for 

planned security system 

outages 

Average may not exceed 54 work hours per week over 

the rolling averaging period. 
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Topic MDO – Normal Operations MDO – Outage

Conditions – Ops, 

HP/Chem, Fire Brigade

MDO – Outage Conditions 

– Maintenance and 

Quality Inspections

MDO – Outage

Conditions – Security

MAWH 54-hr Alternative

Specific exceptions to the limit or value of this requirement [Note-this is an exception to the limit or value of the control, not the exceptions to the calculation of work hours specified in 26.205(b) and 26.20(d)(7)II)] 

No MDOs are required for individuals working for the licensee for a period of less than one week If a shift cycle during normal operations is cut short due to the unit transitioning into an outage or increased threat condition, MDO requirements are considered met if an individual’s scheduled days off during the truncated period would have provided the required days off for the shift cycle To accommodate a change in shift schedules, the licensee may end a shift cycle and start a new one. MDO requirements and compliance of individuals working the shortened shift 

No MDOs are required for individuals working for the licensee for a period of less than one week Some exceptions for operators at multi-unit sites The 60-day period during which these MDO requirements apply may be extended for each individual in 7-day 

increments for each nonoverlapping 7-day period 

the individual has worked not more than 48 hours during the outage 

No MDOs are required for individuals working for the licensee for a period of less than one week. The 60-day period during which these MDO requirements apply may be extended for each individual in 7-day increments for 

each non-overlapping 7-day

period the individual has worked not more than 48 hours during the outage 

No MDOs are required for individuals working for the licensee for a period of less than one week. During the first 60 days of an unplanned security system outage or increased threat condition: no minimum days off are required (security personnel only) The 60-dayperiod during which these MDO requirements apply may be extended for each individual in 7-day 

increments for each nonoverlapping 7-day period the individual has worked not more than 48 hours during the outage 

During the first 60 days of an unplanned security system outage or increased threat condition: the maximum average work hour limits need not be met. 

 Cycle may be determined 

by looking back a period that is equal in length to the shift cycle the individual was working before the change (e.g., the past 6 weeks) 
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Topic MDO – Normal Operations MDO – Outage

Conditions – Ops, 

HP/Chem, Fire Brigade

MDO – Outage Conditions 

– Maintenance and 

Quality Inspections

MDO – Outage

Conditions – Security

MAWH 54-hr Alternative

What is its calculation period? 

Shift cycle, which is set by the licensee, cannot be less than one week nor exceed 6 weeks, but can vary within these limits 

15-day period 7-day period 15-day period Averaging period, which 

cannot exceed 6 weeks, and is defined in days 

How does the calculation period move? 

Sequential Sequential Rolling Sequential Rolling 

What/when is the beginning and end of the calculation period? 

The calculation period starts at the beginning of the shift cycle and ends at the end of the shift cycle; days off per week average is calculated as: (# days off in shift cycle) divided by (# weeks in shift cycle) 

The calculation period starts at the beginning of each 15-day period and ends at the end of the 15-day period 

The calculation period starts at the beginning of each 7-day period and ends 

at the end of the 7-day period 

The calculation period starts at the beginning of each 15-day period and 

ends at the end of the 15- day period 

The calculation period starts on the first day of averaging period and ends on the last day of the averaging period. Licensee must specify the time of day the averaging period starts and stops. Note that for shifts that span 2 calendar days, licensee can either: 

 Count all hours worked as 

if they were worked on the day the shift started, or 

 Count hours on calendar 

days they were actually worked 

By what increments does the calculation period move? 

By shift cycle By 15-day period Day-by-day By 15-day period By 7 consecutive calendar 

days (i.e., rolling weeks) 
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10 TRANSITIONS 

10.1 TYPES OF TRANSITIONS

NOTE: Maintain compliance through transitions. 

Transitions Between On-Line Schedules 

Licensees may transition individuals or crews between shift schedules by ending a shift cycle 

and starting a new shift cycle with a different shift schedule. The following guidance applies: 

x Terminating the shift cycles: 

o Ensure that the individuals meet the MDO requirement applicable to the shift 

schedule that the individuals were working before it was terminated. 

o In these instances, for the purpose of determining compliance with the MDO 

requirements, the licensee may average the individuals’ work hours over a period 

immediately preceding the transition that is equal in length to the shift cycle the 

individuals were working before the transition (e.g., six weeks, if the shift cycle 

was six weeks in length). The licensee should then ensure that the individual 

meets the applicable MDO requirement for the new shift schedule going forward 

from the beginning of the new shift cycle. A shift cycle may be as short as one 

week. There are no MDO requirements for periods of less than seven days. 

Transitions Between On-Line and Outage Schedules 

The ceiling and break requirements apply at all times when transitioning between outage and online schedules. The outage MDOs only apply while in a unit outage. On-line work hour controls 

(MDO or MAWH) take effect the first shift after the reactor unit achieves 75 percent reactor 

power or until seven calendar days have elapsed since reconnecting reconnects the reactor unit to 

the electrical grid whichever is shorter. For the first 42 days after an outage (for six-week cycles) 

the employee must be evaluated using the fixed-shift cycle method. 

Transitions Between Covered Groups or Onto a Covered Shift 

If an individual begins or resumes performing for the licensee any covered work during the 

calculation period, the licensee shall include in the calculation of the individual’s work hours all 

work hours worked for the licensee, including hours worked performing duties that are not 

covered work and control the individual’s work hours. 

x A minimum of one day off in the preceding seven-day period is acceptable for 

individuals to begin or resume covered duties and for individuals who have been working 

an eight-hour shift schedule, as either day or shift workers and are transitioning from a 

non-covered group to a covered group or from a covered group to another covered group 

that has more stringent MDO requirements. 
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x A minimum of two days off in the preceding seven-day period is acceptable for 

individuals who have been working a 10- or 12-hour shift schedule, as either day or shift 

workers, and transition from a non-covered group to a covered group or from a covered 

group to another covered group with more stringent MDO requirements.

x A minimum of two days off in the preceding seven-day period is acceptable for operators 

at a multiunit site with one or more units in an outage, if the operators have been working 

outage hours on 10- or 12-hour shifts before they transition to an operating unit as 

members of the minimum shift complement described in Section 6.1. 

x No MDOs are required for individuals working for the licensee for a period of less than 

one week 

See Section 20, Example 7. 

NOTE: Ceiling limits and break requirements apply under all circumstances unless waived or 

specifically exempted in Section 7. 

NOTE: During a unit outage, the options for control of work hours for covered workers are 

outage MDOs or staying with on line work hours controls. 

NOTE: If an individual is performing work under multiple categories, the most restrictive work 

hour controls apply. 

Transitioning to a Planned Outage Using the MDO Method 

Rolling shift cycles: Since the rolling evaluation method is a backwards look at days worked, 

online MDOs are in compliance when entering a planned outage. 

Fixed shift cycles: The working hours must be carefully managed working towards the beginning 

of an outage. In the last week prior to the outage, the number of days off must meet the on-line 

MDO requirement for the applicable shift schedule. These individual may either need additional 

days off or have their working hours adjusted to meet the required MDOs for a fixed evaluation 

period prior to entering the planned outage. 

Schedules can also be abbreviated to less than a full shift cycle, even if this results in in a shift 

cycle that contains partial weeks. In these cases the required number of MDOs is prorated over 

the abbreviated schedule. For example, 30 days is 4.3 weeks. A 12-hour shift operator shift 

would require 4.3 x 2.5 MDO/week or 11 days off during the 30 days to be in compliance with 

the rule. 

Transitioning From a Planned Outage to On-Line Using the MDO Method 

Return to on-line work hour limitations starts a new shift cycle. As long as the worker has not 

exceeded the maximum number of allowed work days for the final calculation period of the 

outage (seven-day rolling or 15-day fixed), the licensee shall be considered to be in compliance 

with the rule. 
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Transitioning to a Planned Outage Remaining in the MAWH Method 

No additional guidance needed. 

Transitioning from a Planned Outage to On-Line Using the MAWH Method 

See Table 10 for guidance on transitioning out of an outage. 
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TABLE 10: TRANSITIONS OUT OF AN OUTAGE

Control Outage On-Line OperationsNo more than 16 hours worked in 24 hours 

Must remain in compliance through outage Look back and roll forward without interruption—no 

difference across transition 

No more than 26 hours worked in 48 hours 

Must remain in compliance through outage Look back and roll forward without interruption—no 

difference across transition 

No more than 72 hours worked in 7-days/168 hours 

Must remain in compliance through outage Look back and roll forward without interruption—no 

difference across transition 

10 hour break between successive work periods 

Must remain in compliance through outage Look back and then move forward to next break without 

interruption— no difference across transition 

34 hours break in any 9- day period 

Must remain in compliance through outage Look back and roll forward without interruption—no 

difference across transition 

Minimum Days Off (MDO) to MDO 

Must be in compliance with outage requirements throughout and at time of transition out of outage 

New shift cycle starts at point of transition; no look back 

MDO during outage to Maximum Average Work Hour (MAWH) requirements during normal operations 

Must be in compliance with outage requirements throughout and at time of transition out of outage 

Establish fixed initial averaging period after the transition, then roll forward in seven-day increments and continue to roll forward by seven-day increments If a partial week occurs, the hours worked during the partial week are not included in the MAWH calculation averaging period 

MAWH during outage to MAWH during normal operations 

Must remain in compliance through outage No difference across transition, continue to roll forward by 

seven-day increments, maintaining compliance throughout 
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11 WAIVERS (26.207) 

11.1 INTRODUCTION

There will be unforeseen circumstances that may require issuance of a waiver. The issuance of a 

waiver is expected to meet a high threshold and be infrequent. Waivers are only applicable to 

covered workers and should not be considered a routine methodology to circumvent work hour 

controls. 

The annual assessment evaluates the use of waivers and requires a determination of adequate 

staffing if multiple waivers are issued through the year. 

Tables 13A and 13B are provided for reference. 

11.2 APPLICABILITY

A waiver is only permitted when necessary to mitigate or prevent a condition adverse to safety, 

or to maintain site security. 

Waivers can be issued for the work hour controls of break requirements, ceiling limits, minimum 

days off and the maximum average work hours limit as applicable. 

Each limit requires a distinct and separate waiver, although they can be processed together on 

one form at the discretion of the licensee’s program. 

To the extent practicable, licensees shall rely upon the granting of waivers only to address 

circumstances that could not have been reasonably controlled. 

If the covered work authorized under a waiver is completed prior to the expected time, the 

specific worker under the waiver should be sent home for a required break period to reset his/her 

work hours/schedule. 

11.3 WAIVER PROCESS

The process for granting waivers includes the following distinct steps: 

x Licensee identifies need and describes basis for waiver. Either: 

o Operations shift manager determines a waiver is necessary to mitigate or prevent 

a condition adverse to nuclear safety. 

o A security shift manager determines that the waiver is necessary to maintain site 

security. 

o A site senior-level manager with requisite signature authority makes either 

determination. 

o Name of the individual for which a waiver is requested. 

o Date and time the request is initiated. 
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o Work hour controls/limits for which a waiver is required. 

o Date and time waiver will start. 

o Duration of the waiver. For example, how many hours worker will exceed the 

work hour controls? 

o Description of the work to be performed. This should be in adequate detail to 

support the face-to-face supervisory assessment of fitness for a waiver. 

o Circumstances that caused the job extension. 

x Review and approval by the operations shift manager or security shift manager as 

appropriate. 

o Basis for approval. 

o Name, signature, date and time. 

Supervisory Assessment of Fitness for a Waiver

NOTE: The Supervisory Assessment of Fitness for a Waiver shall be completed before the start 

of a waiver period and no more than 4 hours prior to the beginning of work under a waiver. 

Review the work history for the past 14 days as reported by the individual for whom the waiver 

is requested and determine if the individual has worked for a licensee who is subject to Subpart I 

of Part 26 over the past 14 days, as documented by that licensee. 

A statement of how the following were considered: 

x Potential for acute fatigue—time since last 10-hour break. 

x Potential for cumulative fatigue—review work history above. 

x Circadian factors—time of day and recent work cycle. 

x Observation and statements of the individual. 

x How fatigue could affect the work quality, if at all. 

x Nature of work to be performed. 

x Are controls and conditions on work required? If yes, describe. 

x Name, signature, date, and time review supervisory assessment completed by supervisor. 

Waiver Closeout 

In many cases, waivers are generated as a contingency for a job and not used. The information in 

this section is to support the periodic reviews that are required. 

x Hours actually worked, beyond the work hour limits, under this waiver. 

x Did the individual perform satisfactorily? 

x Job supervisor’s name, signature and date close out waiver review. 
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Granting Waivers 

In order to grant a waiver, the licensee shall meet the following requirements: 

x Shift Manager or Security Shift Manager Approval: 

An operations shift manager determines that the waiver is necessary to mitigate or prevent a 

condition adverse to safety, or a security shift manager determines that the waiver is necessary to 

maintain site security, or a site senior-level manager with requisite signature authority makes 

either determination. 

x Supervisory Assessment of Fitness for a Waiver: 

o A supervisor assesses the individual face to face and determines that there is 

reasonable assurance that the individual will be able to safely and competently 

perform his or her duties during the additional work period for which the waiver 

will be granted. 

o The supervisor performing the assessment shall be trained in accordance with the 

requirements of §§ 26.29 and 26.203(c) and shall be qualified to direct the work 

to be performed by the individual. 

o If there is no supervisor on site who is qualified to direct the work, the 

supervisory assessment may be performed by a supervisor who is qualified to 

provide oversight of the work to be performed by the individual. The supervisor, 

if knowledgeable of the work activity, can be a second level supervisor or a 

manager in the chain of command. 

NOTE: Supervisory Assessments of Fitness for Waivers differ from Fatigue Assessments. For a 

comparison, Refer to Table 13B in Section 13, Fatigue Assessments. 

11.4 SUPERVISORY ASSESSMENT FOR WAIVER OF REGULATORY WORK HOURS CONTROLS

A Supervisory Assessment of Fitness for a Waiver is required to evaluate the capability of an 

individual to safely and competently perform covered work during any work period or shift when 

a waiver is being used to allow the work hour limits (10 CFR 26.205) to be exceeded. 

Although a waiver applies to an operational plant condition or to maintain site security and may 

involve multiple individuals over multiple shifts, the supervisory assessment of fitness applies to 

an individual and is valid for one work period or shift for that individual. 

A separate supervisory assessment of fitness for a waiver must be conducted for each individual 

working under the waiver and for each work period. 

The face-to-face portion of the supervisory assessment of fitness for a waiver must be performed 

within a four-hour window prior to commencing work under the waiver and must support a 

reasonable conclusion regarding the potential for worker fatigue during the work period or shift 

covered by the supervisory waiver assessment. 
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At a minimum, the supervisory waiver assessment must address the potential for acute and 

cumulative fatigue during the period covered by the waiver, considering the individual’s work 

history for at least the past 14 days, the potential for circadian degradations in alertness and 

performance considering the time of day for which the waiver will be granted, the potential for 

fatigue-related degradations in alertness and performance to affect risk-significant functions, and 

whether any controls and conditions must be established under which the individual will be 

permitted to perform work. This is both a real time assessment and predictive assessment of 

potential for fatigue. 

The licensee should consider and establish additional fatigue counter-measures to further 

mitigate the potential for fatigue during the work period or shift. 

A new supervisory assessment of fitness is required prior to each subsequent work period or shift 

that the affected individual performs covered work in excess of the work hour limits as allowed 

by an approved waiver. 

The individual’s obligation and rights to self-declare fatigue remain in effect while working 

under a waiver. 

The supervisor performing the supervisory assessment of fitness for a waiver must be qualified 

to direct the work being performed under the waiver. 

If the job supervisor is not on site, a supervisor qualified to perform oversight of the work being 

performed must conduct the supervisory assessment of the individual to work under a waiver. 

11.5 SEQUESTRATION

Personnel may be sequestered prior to and during significant adverse weather (e.g., hurricane, 

major snow storm, etc.). Waivers may be used to meet minimum staff positions. Waivers are not 

required to meet the The break requirements for personnel sequestered can be met on site 

provided they are assigned no duties during the break and they are afforded the opportunity, as 

well as reasonable accommodations, to obtain restorative sleep. Reasonable accommodations 

would include a sleep surface (e.g., bed, recliner, etc.) in a darkened, quiet room. 

Licensees need not meet the requirements of 10CFR 26.205 (c) and (d) for up to 96 hours when 

acts of nature or a disaster is declared. 

An act of nature or a disaster would be defined by an active warning from an independent 

government agency indicating that access to the licensee’s site may be restricted or individual 

travel to the site may be hazardous. 
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This exception expires when the licensee can adequately staff the site within the provisions of 

26.205 (c) and (d) within 6 hours or the beginning of the next normally scheduled shift rotation, 

whichever is greater,3 from the time when the active warning is canceled.

 

3

 The 6-hours post-warning cancellation will provide enough time for relief staff to access the site or for the appropriate supervisory assessments 

to be performed for waivers. Six hours would provide the ability for restorative sleep for relieving workers. Providing additional flexibility to 

extend the provision of 26.207 (e) allows an orderly transition to normal covered work schedules. 
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TABLE 11A: WAIVER PROCESS

[See rule for details - table provides only a general summary of the rule] 

Sub-section Waiver Requirement Note

26.207(a) Licensee may grant a waiver to any 

work hour controls listed in 

Section26.205(d)(1) through (d)(5)(i)

and 205(d)(7) 

In cases where more than one work hour control is 

affected, each control must be waived explicitly 

26.207(a)(1)(i) To grant waiver, a determination 

must be made that the waiver is 

necessary to mitigate or prevent a 

condition adverse to safety or 

necessary to maintain site security 

The determination must be made by either: 

x an operations shift manager, for conditions 

adverse to safety 

x a security shift manager, for conditions 

necessary to maintain site security 

x a site senior-level manager with requisite 

signature authority, for either condition 

26.207(a)(1)(ii) To grant waiver, a determination 

must be made that there is 

reasonable assurance the 

individual will be able to safely and 

competently perform his/her duties 

during the additional work period 

under waiver 

The determination must be made by a supervisor 

assessing the individual face to face. 

The supervisor must be both: 

x trained under Section 26.29 and Section 

26.203(c) 

x qualified to direct the work, or if none 

available on site, then one qualified to 

provide oversight of the work 

The assessment must address at minimum: 

x potential for acute and cumulative fatigue, 

considering work history for at least past 

14 days 

x potential for circadian degradations in 

alertness and performance considering 

time of day 

x potential for fatigue to affect risk-significant 

functions 

x whether controls or conditions must be 

established 

26.207(a)(2) To extent practicable, waivers 

should be used only to address 

circumstances that could not have 

been reasonably controlled 

Waiver is not intended for use to address inadequate 

staffing or work planning, or other circumstances a 

licensee could reasonably foresee (see FRN, March 

31, 2008, p.17147) 

26.207(a)(3) Timing of face-to-face supervisory 

assessment must support a valid 

assessment of potential for worker 

fatigue during period of time 

covered by waiver 

In all cases, the face-to-face assessment may not be 

performed more than 4 hours before beginning work 

under the waiver 
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26.203(d)(3) 

and 

26.207(a)(4) 

Licensees must document 

individual waivers granted 

Each work hour control that is waived must be 

documented 

The documentation must describe the basis for the 

waiver, including: 

x a description of circumstances requiring the 

waiver 

x a statement of the scope of work and time 

period for which waiver approved 

x the bases for the determinations in 

26.207(a)(1)(i) and (ii) 

26.203(e)(1) 

and 

26.203(e)(2) 

Include summaries of waivers 

granted and corrective actions 

taken in the Annual FFD Program 

Performance Report (26.717) 

Provide a summary report of waivers from the 

previous calendar year for each nuclear power plant, 

as well as a summary report of corrective actions, if 

any, resulting from the analyses of waiver data 
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TABLE 11B: WAIVERS AND EXCEPTIONS TO WORK HOUR CONTROLS

[See rule for details - table provides only a general summary of the rule] 

Sub-section Type of Waiver or

Exception

Relevant to Which

Individuals

Requirements

Affected

Implementation

Details

26.207(a) Licensee waiver of 

work hour controls 

All individuals subject to 

work hour controls 

26.205(d)(1) through 

(d)(5)(i) – work hour 

control requirements 

Waiver of 

requirements: 

Continue to 

count/calculate work 

hours; requirements 

are waived for 

specific limits as 

detailed in waiver 

26.207(b) NRC-evaluated 

force-on-force 

tactical exercises 

exception 

All security personnel 

(not just those taking 

part in exercise) 

26.205(d)(3) – 

Minimum days off 

26.207(d)(7) 

Maximum 

Average Work 

Hours 

Affects work hour 

calculation: May 

exclude shifts worked 

during the actual 

conduct of these 

exercises when 

calculating 

individual’s number 

days off (as per MDO 

requirements, or 

when calculating 

weekly average hours 

worked (as per the 

MAWH requirements) 

26.207(c) Common defense 

and security 

exception 

All security personnel 26.205, or any 

specified subset 

thereof – i.e., work 

hour scheduling and 

control requirements 

Exception to work hour 

controls: When 

informed in writing by 

NRC, specified 

requirements need not 

be met for the duration 

of the period defined by 

NRC** 

26.207(d) Plant emergency 

exception 

All individuals subject to 

work hour controls 

26.205(c) and (d) – 

work hour scheduling 

and work hour controls 

May exclude from the 

calculation 

unscheduled work 

hours for the purposes 

of responding to a 

declared plant 

emergency, as defined 

in the licensee’s 

emergency plan. ** 
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26.205(b)(4) Unannounced 

emergency 

preparedness 

exercises or drills 

Individuals participating 

in actual conduct of 

exercises or drill 

26.205(d) – work hour 

control requirements 

Affects work hour 

calculation: 

Unscheduled work 

hours performed while 

participating in the 

actual conduct of 

exercises or drills may 

be excluded from work 

hour 

counts/calculations 

**All scheduled hours worked are still accounted for and entered into the software. 
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12 SELF DECLARATIONS (26.209) 

12.1 APPLICABILITY AND GENERAL PROVISION

It is the individual’s responsibility to make a clear self-declaration of fatigue. 

Site procedures should clearly identify how a self-declaration will be made and leave no room 

for confusion. 

x A casual statement to a supervisor or fellow employee that an individual is tired is not a 

self-declaration. 

x The process shall leave no confusion that a declaration was made and when it was made. 

x It should also be clear that a fatigue assessment is not needed if the supervisor agrees 

with the individual and provides a rest break of at least 10 hours. 

Any on-site individual covered by the FFD program can self-declare whether or not they are 

performing covered work. 

See Section 15.4 (b) Table 12 for Self-Declaration follow-up requirements. 

12.2 SELF-DECLARATIONS DURING EXTENDED WORK HOURS UNDER WAIVER

If an individual is performing, or being assessed for, work under a waiver of the work hour 

controls and declares that, due to fatigue, he or she is unable to safely and competently perform 

his or her duties, the licensee shall immediately stop the individual from performing any covered 

work.

The exception to this is if the individual is required to continue performing those duties under 

other requirements of the regulations, e.g., meet minimum licensed operator staffing. 

If the subject individual must continue performing the covered work until relieved, the licensee 

shall immediately take action to relieve the individual. 

Following the self-declaration or relief from performing covered work, as applicable, the 

licensee: 

x May reassign the individual to duties other than covered work, but only if the results of a 

fatigue assessment indicate that the individual is fit to safely and competently perform 

those other duties. 

x Shall permit or require the individual to take a break of at least 10 hours before the 

individual returns to performing any covered work. 
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TABLE 12: SELF-DECLARATION PROCESS

[See rule for details - table provides only a general summary of the rule] 

Sub-section Self-declaration Requirement Note

26.203(b)(1) Establish written procedure to follow when 

an individual makes a self-declaration that 

he/she is not fit to safely and competently 

perform duties for any part of a work 

period as a result of fatigue, including: 

x Individual’s rights and responsibilities 

x Requirements for controls 

and conditions 

x Process to follow if individual 

disagrees with results of fatigue 

assessment 

Applies to all individuals who have 

unescorted access to nuclear power plant 

protected areas—not just the categories 

of workers who are subject to work hour 

controls 

Self-declaration must be formalized, not 

a simple statement of being “tired” 

26.209(a) Take immediate action in case of a selfdeclaration while the individual is 

performing or being assessed for work 

under a waiver: 

x Immediately stop individual from 

performing duties listed in Section 

26.4(a) 

x Exception: If individual is required to 

perform covered duties, based on 

other requirements of Title 10 CFR, 

then immediately take action to 

relieve individual 

Applies only to self-declaration by 

individuals performing covered work 

under a waiver, or being considered for 

work under a waiver 

26.211(a)(2) Conduct a fatigue assessment 

Exception: If the individual is required or 

permitted to take a rest break of at least 

10 hours, then a fatigue assessment is 

not required 

Required in response to self-declaration 

to supervisor that individual is not fit to 

safely and competently perform duties for 

any part of a work period because of 

fatigue 

26.209(b) Subsequent to self-declaration: 

Individual may be reassigned to duties 

other than those listed in Section 26.4(a) 

if results of fatigue assessment indicate 

individual can safety and competently 

perform those other duties 

Individual must be permitted or required to 

take a break of at least 10 hours prior to 

returning to covered work 

Applies only to self-declaration by 

individuals performing covered work 

under a waiver or being considered for 

work under a waiver 

26.211(a)(4) Conduct follow-up fatigue assessment in 

cases when individual is returned to 

performing any duties following a break of 

less than 10 hours 

Individual must be reassessed for fatigue 

and the need for controls and conditions 

must be determined before the individual 

can resume duties 
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13 FATIGUE ASSESSMENTS (26.211) 

13.1 INTRODUCTION

A fatigue assessment is an evaluation of an individual by an authorized trained fatigue assessor 

to make a determination regarding that individual’s ability to perform any assigned duties within 

the scope of the fitness-for-duty program with respect to fatigue. Fatigue assessments while 

similar to supervisory assessments of fitness for waivers, have distinct attributes including when 

they will be performed, what qualifications are needed to perform a fatigue assessment and the 

requirements to not have a conflict of interest. Additional information is provided in Tables 13A 

and B. 

13.2 CONDITIONS REQUIRING FATIGUE ASSESSMENT

There are four conditions under which a fatigue assessment is required for all personnel under 

general requirements of the fitness-for-duty program: 

x For-cause. 

x Self-declaration. 

x Post-event. 

x Follow-up. 

For-Cause

x A for-cause fatigue assessment is initiated by a supervisor based on direct behavioral 

observation or based on credible information provided by others. 

x Observation for fatigue should not be applicable during an individual’s break period. 

x The fatigue assessor may not be the individual who observed the condition of impaired 

alertness. 

x The drug and alcohol testing requirements of the FFD program may also apply in a forcause situation. 

x If the observed condition is impaired alertness with no other behaviors or physical 

conditions creating a reasonable suspicion of possible substance abuse, then the 

drug/alcohol testing is not required. 

x If the affected individual is performing covered work and a break period is not provided, 

then a fatigue assessment is required to evaluate the individual’s ability to safely and 

competently continue with covered work duties. 

x If a break period is provided, that is less than 10 hours, a follow-up fatigue assessment is 

required before the individual can resume covered work duties. 
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Self-Declaration 

x Self-declaration of fatigue is a provision of the fatigue management program that allows 

individuals to formally notify supervision that they are not or may not be able to safely 

and competently perform their duties due to fatigue. 

x This provision is not unlike similar notifications that an individual may make regarding 

the need to use medication and the possible resultant impact on fitness-for-duty. 

x Licensee procedures must make a clear distinction between formal declarations of fatigue 

under the fatigue management program and casual comments such as being up late, being 

tired, etc. 

x A fatigue assessment must be conducted in response to an individual’s self-declaration to 

his or her supervisor that he or she is not fit to safely and competently perform his or her 

duties for any part of a work period because of fatigue, except if, following the selfdeclaration, the licensee permits or requires the individual to take a break of at least 10 

hours before the individual returns to duty. 

NOTE: Additional information regarding self-declaration is provided in Chapter 1412. 

Post-Event 

x A post-event fatigue assessment is required in conjunction with drug / alcohol testing, 

which is invoked in response to events or circumstances as described in the licensee’s 

FFD Program (refer also to 10 CFR 26.31(c)(3)(i) through (iii)). 

x The primary purpose of the fatigue assessment is to determine if worker fatigue 

contributed to the event. 

x If the event entails an injury to the affected individual, then necessary medical treatment 

must not be delayed in order to perform the fatigue assessment. 

x In cases where the fatigue assessment is delayed by 10 or more hours, a fatigue 

assessment may not be useful in determining if worker fatigue contributed to the event. 

However, in these cases the fatigue assessment must still be performed. 

x If medical treatment is not an issue and the affected individual is required to remain in a 

work capacity without a 10-hour break period, then the fatigue assessment is required to 

determine if that individual can safely and competently perform the assigned work duties 

without impairment due to fatigue. 

x The Fatigue Assessor for a Post-Event fatigue assessment may not have: 

o Performed or directed (on-site) the work activities during which the event 

occurred. 

o Performed, within 24 hours before the event occurred, a fatigue assessment of the 

individuals who were performing or directing (on-site) the work activities during 

which the event occurred. 
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o Evaluated or approved a waiver of the limits for any of the individuals who were 

performing or directing (on-site) the work activities during which the event 

occurred, if the event occurred while such individuals were performing work 

under that waiver. 

Follow-Up 

The purpose of the follow-up fatigue assessment is to determine if the individual is capable of 

safely and competently performing the assigned work duties without impairment due to fatigue. 

A follow-up fatigue assessment is required if a previous fatigue assessment was conducted for 

cause or due to a self-declaration, and if the individual is being returned to duty after a rest break 

of less than 10 hours, the need for controls and conditions must be assessed before permitting the 

individual to resume any duties. 

13.3 FATIGUE ASSESSMENT ATTRIBUTES

The fatigue assessment consists of two components:

x A review of data pertaining to fatigue contributors. 

x A face-to-face interview. 

Licensee policies typically describe the obligation on the part of the individual to be fit for duty. 

In the same way that drug and alcohol testing protocols provide a mechanism for measuring FFD 

with respect to substance abuse, the fatigue assessment protocol provides a mechanism for 

measuring FFD with respect to fatigue. 

The fatigue assessment may, in some circumstances, provide the basis for subsequent actions or 

sanctions under the licensee’s fatigue management or disciplinary policies. 

The fatigue assessment is required to determine whether the individual is capable of safely and 

competently performing assigned duties without degraded alertness due to fatigue. 

There are certain restrictions on who may perform fatigue assessments. 

The fatigue assessments must be performed by FFD personnel or by a supervisor who is an 

authorized, trained fatigue assessor. 

If the individual being assessed is a contractor/vendor, the fatigue assessor may be a supervisor 

in the affected contractor/vendor organization, provided the supervisor is an authorized, trained 

fatigue assessor at that site. 

Fatigue Assessors 

The minimum training and examination requirements for a fatigue assessor are the same 

requirements as those described in Section 14 for all individuals who are in the FFD population. 
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Among other FFD program topics this training addresses: 

x Contributors to worker fatigue and decreased alertness in the workplace. 

x Symptoms of worker fatigue. 

x Indications and risk factors for common sleep disorders. 

x Effective use of fatigue countermeasures. 

Licensees and contractor/vendors may require additional optional training for fatigue assessors, 

such as that available through the National Academy for Nuclear Training electronic learning 

portal (NANTeL). 

NOTE: See post-event conditions below for further restrictions on fatigue assessors. 

The licensee may not conclude that fatigue has not or will not degrade the individual’s ability to 

safely and competently perform his or her duties solely on the basis that the individual’s work 

hours have not exceeded any of the work hour limits or that the individual has had the minimum 

breaks or minimum days off, as applicable. 

Following a fatigue assessment, the licensee shall determine and implement the controls and 

conditions, if any, which are necessary to permit the individual to resume performing duties for 

the licensee, including the need for a break. 

13.4 REQUIRED INFORMATION

At a minimum, the fatigue assessment must address the following factors: 

x Acute fatigue. 

x Cumulative fatigue. 

x Circadian variations in alertness and performance. 

Individuals shall provide complete and accurate information that may be required by the licensee 

to address the required factors. 

Licensees shall limit any inquiries to only the personal information from the subject individual 

that may be necessary to assess the required factors. 

Review of individual performance as applicable. 

13.5 PROCESS FOR CONDUCTING FATIGUE ASSESSMENT

NOTE: See specific requirements in the applicable sections of this guidance to ensure all 

attributes of the assessment are met for the specific condition requiring the fatigue assessment. 
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The process for conducting a fatigue assessment includes the following steps: 

x Identification of condition requiring a fatigue assessment: 

x Name of the individual. 

x Date and time. 

x Narrative supporting the condition requiring the fatigue assessment: 

o For Cause—Description of observed behavior. 

o Self-declaration—Description of current job duties, time in a duty status, and 

scheduled end of work period. 

o Post-event—Description of the event and the individual’s involvement. 

o Follow-up—Length of rest period, reason for early return, and expected duties. 

x Name, date, time, signature of individual completing this section. 

x Work history for past 14 days as reported by the individual. 

x Work history for the past 14 days as documented by the licensee. 

x Statement of how the following were considered: 

o Potential for acute fatigue—time since last 10-hour break. 

o Potential for cumulative fatigue—review work history above. 

o Determine if the individual has had the opportunity for two restorative rest 

periods, 34 hours off in the last seven days. 

o Circadian factors-time of day and recent work cycle. 

o Observation and statements of the individual. 

o Nature of work to be performed. 

x Results of evaluation: 

o Individual is fit for duty—return to full work status. 

o Individual is not fit for duty due to fatigue—provide a minimum of a 10-hour 

break. 

o Individual is returned to duties with the following restrictions. Restrictions can 

include assignment to non-covered work, a nap before continuing covered work, 

etc. 

x Name, date, signature of fatigue assessor. 
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TABLE 13A: FATIGUE ASSESSMENT PROCESS

[See rule for details – table provides only a general summary of the rule] 

SubsectionFatigue Assessment

Requirement

Note

26.203(b)(3) Develop procedure for 

fatigue assessments 

Applies to individuals performing duties listed in Section 

26.4(a)-(c) (i.e., all individuals subject to Subpart I) 

26.203(b)(4) Develop procedure for 

disciplinary actions following 

a fatigue assessment 

Must include conditions and considerations for taking those 

disciplinary actions 

26.211(a) Conduct fatigue assessment 

under the following 

conditions: 

- for cause 

- self-declaration 

- post-event 

- follow-up 

For cause: in cases of an observed condition of impaired 

alertness, creating a reasonable suspicion, except during a 

break period 

Self-declaration: in cases of self-declaration unless the 

individual is permitted or required a rest break of at least 10 

hours 

Post-event: in cases where post-event drug and alcohol 

testing is required 

Follow-up: if a previous fatigue assessment was conducted for 

cause or due to a self-declaration and if the individual is being 

returned to duty after a rest break of less than 10 hours; the 

need for controls and conditions must be assessed before 

permitting the individual to resume any duties 

26.211(b) Ensure persons conducting 

the Fatigue Assessment are 

trained and not subject to 

conflicts of interest 

Fatigue Assessment must be conducted face to face 

Supervisors and FFD program personnel conducting Fatigue 

Assessments must be trained under Section 26.29 and 

26.203(c) 

For cause and post-event: the person conducting the 

assessment must be free of conflicts of interest, such as 

having approved a waiver prior to the event; see 26.211(b)(1) 

and (2) for details 

26.211(c) Ensure fatigue assessment 

provides information 

necessary for management 

decisions and actions 

The assessment must address: 

x acute and cumulative fatigue 

x circadian variations in alertness and performance 

The inquiry must be limited to relevant information; the 

Individual must provide complete and accurate information 

26.211(d) Licensee may not conclude 

that fatigue has not or will not 

degrade individual’s 

performance solely on the 

basis that the individual did 

not exceed work 

hour control requirements 
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SubsectionFatigue Assessment

Requirement

Note

26.211(e) Determine and implement 

controls and conditions 

necessary to resume duties 

Controls and conditions may include such things as: a rest 

break; peer-review and approval of job tasks; or assignment to 

job tasks that are non-repetitive (see SOC p.17153) 

26.203(d)(5)

and 

26.211(f) 

Document fatigue 

assessment results 

Must document the reasons for and results of any fatigue 

assessment conducted, the circumstances, and the controls 

and conditions implemented 

26.203(d)(5)

and 

26.211(g) 

Prepare annual summary 

report 

Prepare the annual summary report of fatigue assessments 

conducted for covered individuals during the previous calendar 

year at each NPP site; see 26.211(g)(1)-(4) for details 
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TABLE 13B: “SUPERVISORY ASSESSMENT OF FITNESS” FOR WAIVERS VS. “FATIGUE 

ASSESSMENT” 

[See Rule for details - table provides only a general summary of the rule] 

Item Supervisory Assessment 

of Fitness for Waivers –

26.207(a)(1)(ii)

Fatigue Assessment –

26.211

Purpose Assess individual for a 

waiver 

 Following these conditions: 

o For cause 

o self-declaration 

o post-event 

o follow-up (before return 

to duty in certain 

specified cases) 

 See 26.211(a)(1)-(4) for 

specific details 

Who can 

perform 

Supervisor trained and 

qualified to direct or oversee 

work 

 Trained supervisor or trained 

FFD program personnel with 

no conflict of interest

How Face-to-face  Face-to-face 

 Requires accurate info from 

worker and constrains 

licensee to ask only pertinent 

questions 

Timing Not more than 4 hours before 

the individual begins 

performing any work under 

the waiver 

 Depends on the triggering 

condition 

 Post-event fatigue 

assessment must occur as 

soon as practical after event 

Scope  Acute and cumulative 

fatigue, circadian variations 

 Whether already fatigued 

 Whether will be fatigued by 

end of period waiver covers 

 Acute and cumulative 

fatigue, circadian variations 

 Not to be determined solely 

by compliance status with 

work hour controls 
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14 TRAINING AND EXAMINATIONS 

Licensees shall add the following KAs to the content of the training that is required in § 26.29(a) 

and the comprehensive examination required in § 26.29(b): 

x Knowledge of the contributors to worker fatigue, circadian variations in alertness and 

performance, indications and risk factors for common sleep disorders, shift work 

strategies for obtaining adequate rest, and the effective use of fatigue countermeasures. 

x Ability to identify symptoms of worker fatigue and contributors to decreased alertness in 

the workplace. 

Employees and contractors of the licensee should be aware of the trustworthiness and reliability 

requirements for unescorted access to the protected area, the importance of being fit for duty, 

understand the potential consequences of working while fatigued, and work in compliance with 

the station FFD policy. 

Workers should be able to: 

x Demonstrate knowledge of the basic fatigue management requirements for workers. 

x Recognize the personal, public health, and safety hazards associated with fatigue. 

x Discuss the company fatigue management policy. 

x Discuss individual roles and responsibilities under the company fatigue management 

policy. 

x Demonstrate knowledge of the contributors to worker fatigue, circadian variations in 

alertness and performance, indications and risk factors for common sleep disorders, shift 

work strategies for obtaining adequate rest, and the effective use of fatigue 

countermeasures. 

x Demonstrate understanding of identifying symptoms of worker fatigue and contributors 

to decreased alertness in the workplace. 

x Demonstrate understanding of fatigue management techniques. 

x Discuss the methods used to implement the company fatigue management policy. 

x Discuss the consequences of not following the company fatigue management policy. 

x Discuss individual and company rights regarding the company fatigue management 

policy. 

Each test is to include at least one question from each KA. The rest of the test should be a 

random sample of questions from all the remaining KAs. 
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15 RECORDS 

Licensees shall retain the following records for at least three years or until the completion of all 

related legal proceedings, whichever is later: 

x Records of work hours for individuals who are subject to the work hour controls. 

x Records of shift schedules and shift cycles of individuals who are subject to the work 

hour controls. 

x The documentation of waivers including the bases for granting the waivers and the 

supervisory assessments. 

x The documentation of work hour reviews. 

x The documentation of fatigue assessments. 

Table 15 is provided for reference. 
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TABLE 15: DOCUMENTS, REPORTS, AND REVIEWS REQUIRED UNDER SUBPART I 

[See rule for details - table provides only a general summary of rule] 

Item Sub-section Type of Document, 

Report, Review

Description

1 26.203(a) Policy on Fatigue 

Management 

Written policy for the management of fatigue for all 

persons subject to FFD Program 

Include as part of the written FFD policy required 

under 26.27 

2 26.203(b)(1) Procedure for Selfdeclaration Written procedure describing the process to follow 

when an individual makes a self-declaration that 

he/she is not fit to safely and competently perform 

duties as a result of fatigue; see details in 

26.203(b)(1)(ii)-(iii) 

3 26.203(b)(2) Procedure on Work Hour 

Controls 

Written procedure describing the process for 

implementing work hour controls under 

Section 26.205 

4 26.203(b)(3) Procedure for Fatigue 

Assessments 

Written procedure describing the process for 

conducting fatigue assessments under 

Section 26.211 

5 26.203(b)(4) 

and 

26.77(b)(2) 

Procedure for Disciplinary 

Actions 

Written description of the disciplinary actions and 

the conditions and considerations that may be 

imposed following a fatigue assessment 

6 26.203(c) Additions to FFD Training 

Program 

Addition of specific knowledge and abilities (KAs) 

on fatigue management to the FFD training 

requirements under Section 26.29(a); see details 

of KAs to be included in 26.203(c)(1)-(2) 

7 26.203(c) Additions to 

Comprehensive FFD 

Examination 

Addition of specific KAs on fatigue management to 

the FFD comprehensive examination 

requirements under Section 26.29(b); see details of 

KAs in 26.203(c)(1)-(2) 

8 26.203(d)(1) Records of work hours Records of work hours of individuals subject to 

Section 26.205 must be created and retained for 

3 years or until completion of all legal 

proceedings 

9 26.203(d)(2) Records of shift schedules 

and shift cycles 

Records of shift schedules and shift cycles of 

individuals subject to Section 26.205 must be 

created and retained for 3 years or until completion 

of all legal proceedings 
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Item Sub-section Type of Document, 

Report, Review

Description

10 26.203(d)(3) 

and 

26.207(a)(4) 

Documentation of waivers Documentation of waivers granted under Section 

26.207, including bases for granting the waiver and 

supervisory assessment must be created 

11 26.203(d)(4) 

and 

26.205(e)(3)- 

(4) 

Documentation of work hour 

reviews (effectiveness 

reviews) 

Documentation of work hour reviews required under 

Section 26.205(e), including methods used, results, 

problems, and trends and corrective actions 

12 26.203(d)(5) 

and 

26.211(f) 

Documentation of fatigue 

assessments 

Documentation of the results of any fatigue 

assessment conducted, including circumstances 

and controls and conditions implemented 

13 26.203(d)(5) 

and 

26.211(g) 

Annual Summary of Fatigue 

Assessments 

Annual summary report of fatigue assessments 

conducted during the previous calendar year for any 

individual identified in Section 26.4(a)-(c); required 

for each NPP site; see 26.211(g)(1)-(4) for details 

14 26.203(e)(1) 

and 

26.717 

Addition to Annual FFD 

Program Performance 

Report: Summary of Waivers 

of Work Hour Controls 

A summary of waivers from the previous calendar 

year for each NPP site; see 26.203(e)(1)(i)-(iii) for 

details, included in the Annual FFD Program 

Performance Report 

15 26.203(e)(2) 

and 

26.717 

Addition to Annual FFD 

Program Performance 

Report: Corrective Actions 

Summary 

A summary of the corrective actions, if any, resulting 

from the analyses of waiver data, included in the 

Annual FFD Program Performance Report 

16 26.203(f) Addition to audit process An audit of the management of worker fatigue is part 

of the FFD audit requirements in Section 26.41 

17 26.205(d)(8) Policy and Procedure 

Regarding Use of MDOs 

and/or 54-Hour Alternative 

The FFD policy and procedures should state which 

alternative the licensee is complying with: MDO or 

maximum average work hour (MAWH) requirements 
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Item Sub-section Type of Document, 

Report, Review

Description

18 26.719 Significant FFD policy 

violations or programmatic 

failures 

Violations of Subpart I or failures of a licensee’s 

Fatigue Management Program are reported 

according to the procedures in 26.719 (Note that this 

requirement is not specifically referenced in 

Subpart I) 
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16 REVIEWS 

Licensees shall evaluate the effectiveness of their control of work hours of individuals who are 

subject to this section. 

16.1 ANNUAL WORK HOUR CONTROL EFFECTIVENESS REVIEW

Licensees shall conduct the reviews once per calendar year. 

If any plant or security system outages or increased threat conditions occurred since the licensee 

completed the most recent review, the licensee shall include in the subsequent review an 

evaluation of the control of work hours during the outages or increased threat conditions. 

Licensees shall complete the review within 30 days of the end of the review period. The review 

period should be defined by the licensee. 

Content of Annual Review 

x Review the actual work hours and performance of covered individuals during the entire 

review period, including any plant or security system outages or increased threat 

conditions, for consistency with the work hours scheduling requirement objective of 

preventing impairment from fatigue due to the duration, frequency, and sequencing of 

hours worked. 

o The review should be based on information in, but not limited to, the corrective 

action program. 

o At a minimum, this review should address the following: 

 When using the on-line MDO method, individuals whose actual hours worked 

during the review period exceeded an average of 54 hours per week in any 

shift cycle. 

 When using the on-line averaging method, individuals whose actual hours 

worked exceeded an average of 54 hours per week in any averaging period of 

up to 6 weeks. 

 Individuals whose actual hours worked during the review period exceeded an 

average of 54 hours per week in any shift cycle while the individuals’ work 

hours were subject to the non-outage day-off requirements. 

 Individuals who were granted more than one waiver during the review period. 

 Individuals who were assessed for fatigue during the review period. 

x If work under a waiver occurred, review the individuals’ hours worked and the waivers 

under which work was performed to evaluate staffing adequacy for all jobs subject to the 

work hour controls. 

x Review performance of the station in adhering to work schedules for covered work 

groups: evaluate whether or not the schedule is effectively being implemented. 
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o Is the schedule being adhered to? 

o Are the changes understood and reasonably consistent with a properly managed 

schedule? 

o Does the overtime utilized support efficient utilization of resources? 

o Are the available resources properly aligned with the scheduled work load? 

o Is unplanned work or outages indicative that other corrective actions are 

necessary? 

o Does the level and pattern of overtime support a determination that staff size is 

appropriate for the schedule and work? 

o Are chronic self-declarations due to scheduling deficiencies? 

Documentation and Follow-up 

Document the methods used to conduct these reviews and the results of the reviews. 

Record, trend and correct, under the licensee’s corrective action program, any problems 

identified in maintaining control of work hours consistent with the specific requirements and 

performance objectives of the rule. 

NOTE: Refer to Table 15 in Section 15, Records, for a general summary of documents, reports 

and reviews required under 10 CFR 26 Subpart I. 
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TABLE 16: WORK HOUR CONTROL EFFECTIVENESS REVIEW PROCESS 

[See rule for details - table provides only a general summary of the rule] 

Sub-section Review Requirement Purpose Note

26.205(e) Conduct work hour 

control effectiveness 

reviews once per 

calendar year 

Evaluate the effectiveness of 

control of work hours of 

individuals subject to the work 

hour control requirements 

Include in the review any plant 

or security system outages or 

increased threat conditions that 

occurred since the last review 

Review must be completed 

within 30 days of the end of the 

review period 

26.205(e)(1) Review actual work 

hours and performance 

of certain covered 

individuals for 

consistency with 

scheduling requirements 

of 

26.205(c) 

Review actual hours worked 

and worker performance to 

examine if licensee scheduling 

practices meet objective of 

preventing impairment from 

fatigue due to duration, 

frequency or sequencing of 

shifts (26.205(c)) 

At minimum, review must 

include individuals: 

 whose actual hours worked 

exceeded an average of 54 

hours per week in either: 

o any shift cycle with 

covered work subject to

26.205(d)(3) MDOs or 

o any averaging period up 

to 6 weeks (as per 

licensee averaging 

period) for covered 

work subject to 

26.205(d)(7) 

 who were granted more than 

one waiver 

 who were assessed for fatigue 

while being considered for a 

waiver under 26.211 [fatigue 

assessment] 

26.205(e)(2) Review individuals’ hours 

worked and waivers 

under which work was 

performed 

Evaluate staffing adequacy for 

all jobs subject to work hour 

controls 

Only waivers under which work 

was performed must be 

reviewed; if waiver was granted 

but not utilized, it does not need 

to be included in the review 

26.205(e)(3) Document the methods 

used to conduct the 

review and the results of 

the review 

Provide basis for evaluation 

and corrective action 

26.205(e)(4) Record, trend and 

correct, under the 

corrective action 

program, any problems 

identified 

Address problems identified in 

maintaining control of work 

hours consistent with specific 

requirements as well as 

performance objectives of Part 

26 
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17 REPORTING 

17.1 ANNUAL REPORTING REQUIREMENTS

Licensees shall report fatigue rule information in a standard format in the annual FFD program 

performance report required under § 26.717. 

Reports related to fatigue management can be integrated into the overall FFD report and can be 

submitted electronically. 

Licensees and other entities shall submit the FFD program performance data (for January 

through December) to the NRC annually, before March 1 of the following year. 

Fitness-for- Duty reporting consists of one of two methods: 

x Electronic Information Exchange (EIE) Using the General Submission Portal. This is the 

preferred and easiest method of reporting and consists of licensees completing one or 

more of the three types of FFD forms using the General Submission portal. The 

completed forms will be in a .pdf format, which the licensee can submit electronically to 

the NRC. In order to satisfy the annual reporting requirement for Fatigue Management, 

use the FFD Form linked below when making an electronic submittal through the EIE 

General Submission portal: http://pbadupws.nrc.gov/docs/ML1135/ML113530456.pdf. 

x Hard Copy. Although this is the less desirable method, licensees may still submit hard 

copy FFD performance reports. This is the least desirable method because the FFD hard 

copy reports are in site-specific formats, nomenclature and level-of-detail making it 

difficult for the NRC staff to understand and evaluate site-specific corrective actions and 

results and data contained within the hard copied reports needs manual data extraction 

methods to facilitate industry-wide trending. 

17.2 ANNUAL SUMMARY OF WAIVERS

A summary shall be provided for each nuclear power plant site of all instances during the 

previous calendar year in which the licensee waived the work hour controls for individuals 

described in Section 5, Managing Fatigue, and Section 6, Work Hour Controls. 

The summary must include only those waivers under which covered work was performed. 

If it was necessary to waive more than one work hour control during any single extended work 

period, the summary of instances shall include each of the work hour controls that were waived 

during the period. 

For each category of individuals specified in § 26.4(a), the licensee shall report: 

x The number of instances in which each work hour control was waived for individuals not 

working on outage activities.
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x The number of instances in which each work hour control was waived for individuals 

working on outage activities. 

x A summary that shows the distribution of waiver use among the individuals within each 

category (e.g., a table that shows the number of individuals that received only one waiver 

during the reporting period, the number of individuals that received a total of two waivers 

during the reporting period, etc.). 

x A summary of corrective actions, if any, resulting from the analyses of these data, 

including fatigue assessments. 

NOTE: Refer to Table 15 in Section 15, Records, for a general summary of documents, 

reports and reviews required under 10 CFR 26 Subpart I. 

17.3 ANNUAL SUMMARY OF FATIGUE ASSESSMENTS

Licensees shall prepare an annual summary for each nuclear power plant site of instances of 

fatigue assessments that were conducted during the previous calendar year for any individual 

identified in § 26.4(a) through (c). Each summary must include: 

x The conditions under which each fatigue assessment was conducted (i.e., self-declaration, 

for cause, post-event, follow-up). 

x A statement of whether or not the individual was working on outage activities at the time 

of the self-declaration or condition resulting in the fatigue assessment. 

x The category of duties the individual was performing, if the individual was performing 

the duties described in § 26.4(a)(1) through (a)(5) at the time of the self-declaration or 

condition resulting in the fatigue assessment. 

x The management actions, if any, resulting from each fatigue assessment. 

NOTE: Refer to Table 15 in Section 15, Records, for a general summary of documents, reports 

and reviews required under 10 CFR 26 Subpart I. 

17.4 INCIDENT REPORTING REQUIREMENTS

Within a 24-hour limit, licensees are required to report significant FFD policy violations or 

programmatic failures under § 26.719(b). 

NOTE: The requirements in § 26.719(b)(1) and (b)(2) originated in the previous FFD rule and 

refer to drug and alcohol issues. 

The requirement at § 26.719(b)(3) addresses any intentional act that casts doubt on the integrity 

of the FFD program. 
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Since no reporting requirements were specifically identified for fatigue management incidents, 

an equivalency judgment will need to be made when an incident occurs. A few examples are as 

follows: 

x A conflict of interest when performing a fatigue assessment may reach the threshold of a 

significant FFD policy violation. 

x Events or a series of events which, in the judgment of management, indicate a significant 

systemic failure of the fatigue management program, procedures or policies or failure to 

meet key objectives related to safety. 

x A significant attempt by a supervisor to subversively violate the fatigue management 

program. 

NOTE: Refer to Table 15 in Section 15, Records, for a general summary of documents, reports 

and reviews required under 10 CFR26 Subpart I. 
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18 AUDITS 

Licensees shall audit the management of worker fatigue as required by § 26.41. 

18.1 CONDUCT OF AUDITS

Audits shall focus on the effectiveness of the FFD program element, Fatigue Management, and 

shall be conducted by individuals who are qualified in the subject(s) being audited. 

The individuals performing the audit of the program shall be independent from both the subject 

FFD program's management and from personnel who are directly responsible for implementing 

the FFD program. 

Audits shall be conducted each 24 months in accordance with the license’s audit program. 

18.2 AUDIT RESULTS

The result of the audits, along with any recommendations, shall be documented and reported to 

senior corporate and site management. 

Each audit report shall identify conditions that are adverse to the proper performance of the FFD 

program, the cause of the condition(s) and, when appropriate, recommended corrective actions. 

The licensee or other entity shall review the audit findings and take corrective actions, including 

re-auditing of the deficient areas where indicated to preclude, within reason, repetition of the 

condition. 

The resolution of the audit findings and corrective actions shall be documented. 

NOTE: Refer to Table 15 in Section 15, Records, for a general summary of documents, reports 

and reviews required under 10 CFR 26 Subpart I. 
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19 PERSONNEL ACTIONS 

Individuals that exhibit chronic self-declaration that they are not fit for duty as a result of fatigue 

should be considered for referral to the employee assistance program. 

Individuals who exhibit chronic self-declaration that they are not fit for duty as a result of 

fatigue, absent a sound medical reason, may be subject to disciplinary action. 

Personnel are required to be fit for duty and getting sufficient rest is required to ensure a person 

is not subject to fatigue. 

Persons who make choices that result in less than the sleep necessary for that person to remain 

alert and avoid fatigue are not meeting their obligation per this rule. 

The refusal on the part of an individual to submit to a supervisory assessment or fatigue 

assessment shall subject the individual to disciplinary action and possible removal from 

unescorted access. 

Facts to be considered in assessing disciplinary action shall include the employee’s job 

assignment, past work record and work schedule. 

Personnel subject to the fatigue assessments who refuse to be assessed will be considered 

fatigued and unable to perform their duties. Time away from work for fatigue management 

recovery shall be classified as vacation, personal time (if available) or non-paid time. 
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20 EXAMPLES 

Example 1: Unescorted Access 

If a non-badged contractor is brought on site to do emergent critical specialty work on a risksignificant component (such as a contractor who is sealing a risk-significant valve), is that 

contractor subject to the work hour limitations? Note that the contractor would be escorted.

Answer: Personnel under escort (i.e., non-badged individuals) are not subject to work hour 

limitations. 

Example 2: Removal of Risk-Significant Component From a System 

A risk significant component is removed from site to be refurbished or repaired. Is the off-site 

work on this component considered covered work? 

Answer: No, work on a component that is off site is not covered work. The work for removal, 

installation and testing the component is covered work. 

Example 3: Risk Significance Status When in Outage 

Part 26 states to use 10 CFR 50.65(a)(4) for determining safety significance of systems but many 

items in a(4) are not safety-significant during outages. For example, auxiliary feedwater is not 

risk-significant during an outage. Must the work be covered during an outage? 

Answer: The auxiliary feed water system is safety significant when the unit is operating. If an 

individual works on the auxiliary feed water system either during an outage or operations, the 

individual would be considered to be subject to the work hour controls. 

Example 4: Directing 

Example 4A: 

On Sunday morning at 0400, while running the #1 Diesel Generator (DG), a problem develops 

that requires the system engineer to return to site to provide technical assistance. The 

maintenance crew performing work on the #1 DG is being supervised by a first-line maintenance 

supervisor. The system engineer provides technical information and makes recommendations to 

the maintenance supervisor. Is the system engineer a covered individual? 

Answer: The system engineer is providing information to the supervisor of a maintenance crew. 

The maintenance supervisor in this case would be responsible for deciding what information is to 

be acted on and for directing the maintenance activities associated with the job. The system 

engineer is not directing and therefore not performing covered work. 
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Example 4B: 

A DG system engineer is supporting a diesel generator system window by providing technical 

decisions in the field directly to workers who are acting on the input without subsequent review 

or challenge by the job supervisor. Is the system engineer directing? 

Answer: Yes, the system engineer is directing as defined by the rule as the covered workers are 

taking and acting on the input provided by the engineer without subsequent review, challenge or 

decision-making processing by a supervisor. 

Example 4C: 

The reactor engineer is required by station procedures to be present during fuel movement. The 

reactor engineer’s function is to observe the fuel movement activity and provide technical 

recommendations to the fuel-handling SRO. Is the reactor engineer a covered individual? 

Answer: The reactor engineer is not directing; they are providing technical information and 

observing and therefore not conducting covered work. The fuel-handling SRO would be 

directing and is a covered individual. 

Example 4D: 

The reactor engineer is required by station procedures to be present during reactor startup. The 

Reactor Engineer’s function is to provide information to the control room supervisor on the 

reactivity of the reactor during the approach to criticality. Is the reactor engineer a covered 

individual? 

Answer: The reactor engineer is not directing; they are providing technical information and 

therefore not conducting covered work. The control room supervisor would be directing and is a 

covered individual. 

Example 4E: 

Give clarification of what activities the supervisor is a covered employee due to directing. 

Answer: The following tasks are examples generally considered NOT directing:

x Engineering tasks. 

x Supervision in the plant of the maintenance on a non-risk-significant SSC. 

x Supervision at the second-level supervision. 

NOTE: Position alone should not be the deciding factor. For example a shift manager 

is a second-level supervisor but, in practice and as defined in 10 CFR 26.4, has the 

authority to direct covered activities. Careful analysis, evaluating all the criteria, 

should occur prior to determining applicability or exclusion. 

x Conducting Work Control Center documentation activities. 
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x Writing a work procedure. 

x Preparing a work or modification package. 

x Review by senior management of work plans. 

x Training of personnel during which time the trainee is not operating or performing 

maintenance activities. 

x Providing recommendations from vendors and engineers on test performance, 

component and system operation or other similar technical inputs. 

x Review and approval of documents. 

x Any work that is not operations or maintenance on risk-significant SSCs. 

x Technical staff providing only recommendation to control room staff. 

Example 5: 34-Hour Break

Assume that John Doe is a staff engineer in the operations department who holds an active 

license. John works a nominal eight-hour day. John's normal work duties are NOT within the 

scope of the work hours rule. Over the last six weeks, John has had weekends off except for the 

sixth week. During the sixth week (i.e., last week) John worked Monday through Friday, came in 

on Saturday for 4 hours to catch up on work, and also came in Sunday for four hours. John 

resumed his normal duties on Monday this week. Today (Tuesday) John is asked to stand an 

eight-hour shift schedule SRO watch. Can he stand the watch since Tuesday is the ninth day in a 

row that John will be working?

Answer: No, John has not had a 34-hour break in the last 216-hour (9-day) period nor has John 

had a day off in the last 7 days. 

Example 6: 34-Hour Break and MDO 

Assume that Jane Doe is a staff engineer in the operations department who holds an active 

license. Jane works a nominal 8-hour day. Jane's normal work duties are NOT within the scope 

of the work hours rule. Over the last six weeks Jane has had weekends off, except that Jane, as a 

normal routine works hours every Saturday morning. Jane resumed her normal duties on Monday 

this week. Today (Tuesday) Jane is asked to stand a 12-hour shift schedule SRO watch. Can she 

stand the watch? 

Answer: Yes, Jane has had a 34-hour break in the last 216 hours (9 days). Jane also has worked 

less than 72 hours in the last 168-hour (7-day) period. Jane works an 8-hour shift and a look back 

over the last 7 days shows that she does meet the minimum 1 day off requirement to transition to 

covered work. 

Example 7: Average Shift Length MDO Requirement and Other Limits 

Assume that John Smith works in the energy delivery part of his company and sometimes is 

needed to perform covered work in the switchyard of the nuclear plant. He has unescorted access 

to the plant, but only works here occasionally when needed. The rest of the time, he works out on 
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the distribution system. What are the requirements for John to start performing covered work in 

the switchyard? 

Answer: If John’s average shift length in the preceding 7 days is 9 hours or less, he requires 1 

day off in the preceding 7 days. If his average shift length is greater than 9 hours, he requires 2 

days off in the preceding 7 days. In addition the following maximum work hours and minimum 

breaks apply prior to performing covered work: 

x 16 work hours in the preceding 24-hour period. 

x 26 work hours in the preceding 48-hour period. 

x 72 work hours in the preceding 168-hour (7-day) period. 

x A 10-hour break between the previous work period or an 8-hour break between the 

previous work period when a break of less than 10 hours was necessary to accommodate 

a crew’s scheduled transition from an outage to online operations. 

x A 34-hour break in the preceding 216-hour (9-day) period. 

Example 8: Call-In Work Period 

An individual’s normal schedule is from 0700 to 1530 (8-hour day) and the individual is called 

back to work (emergent site security issue) at 1900 and he/she works until 2100. 

The separate work period method cannot be used since a 10-hour break is not available prior to 

the call-in period. 

The call-in is considered an extension of the previous work period, 0700 to 1530. The hours 

counted for this work period would be 14. A 10-hour break is required prior to the individual 

starting an additional work period; therefore, the individual could return at the normal start of 

their work period at 0700 the next day. 

A waiver to the 10-hour break between successive work periods could be performed. The hours 

counted for the work day would be 10.5. The individual could return at the normal start of their 

work period at 0700 the next day. 

Example 9: Call-In Work Period 

An individual’s normal schedule is from 0700 to 1530 (8-hour day), and the individual is called 

back to work from 0200 to 0400 the next day. 

The call-in period is considered a separate work period. The 2 hours worked for the licensee is 

counted. The individual had a 10-hour break prior to the start of the work period and must be 

given a 10-hour break following the end of the work period. 

The call-in is considered an extension of the succeeding work period, 0700 to 1530. The hours 

counted for this work period would be 13.5. 

A waiver should not be necessary in this example. 
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Example 10: Phone Call at Home – Incidental Duties

An individual performs risk-significant work for 10 hours (0700-1700) and goes home. At 2200 

he/she receives a call from work and talks for 1-hour until 2300. Can he/she return to work at 

0700 the next day?

Answer: The individual did not have a 10-hour break prior to receiving the call. The hours from 

1700 through 2200 do not count with respect to calculating hours worked. The individual worked 

a total of 11 hours with the work period ending at 2300. However, the individual cannot return to 

work at 0700 the next day; he/she would not meet the 10-hour break requirement. The individual 

could begin work at 0900 the next day.

Example 11: Phone Call at Home – Incidental Duties

If an individual is on a day off and is required to talk with licensee personnel at the plant on 3 

occasions, with each call lasting 20 minutes, totaling one hour, can that day still be considered a 

day off since that one hour shall be included in the work hour total? 

Answer: The total time spent on the phone shall be counted since it exceeds a nominal 30 

minutes during a single break period; therefore, the total time spent on the telephone call must be 

documented as an hour worked for MAWH. The day is considered a work day for MDO 

purposes. 

Example 12: Day-Off and Work at Home

What "work-related" activities may be done at home on a day off without violating the "day off" 

intent? For example, may an individual read procedures, catch up on administrative tasks or 

study for a license requalification exam for a number of hours and still count that day as a "day 

off”?

Answer: Activities initiated by the individual (not required by the licensee) may be performed at 

home on a day off and not be considered “work,” e.g., studying, reading work-related material, 

reading email. These activities would not violate the 30-minute incidental duties requirement and 

would, therefore, not be counted toward the work hour total. 

Example 13: Outage Minimum Day Off Extension 

If during the first 60 days, a covered worker gets a 7-day block where he works not more than 48 

hours, you can extend the 60-day period by 7 days. If the worker gets two 7-day blocks where he 

does not work more than 48 hours and the two periods do not overlap, can you extend the 60-day 

period by 14 days? 

Answer: Yes, you can extend the 60-day period by 14 days. This extension can be made any 

time in the outage period after the less than 48-hour work week. Since this extension is 

calculated by a week defined as seven days and if every week of the initial 60 days is used for 

the extension only 56 days (eight weeks) are available for the extension. The 48-hour allowance 

can only be banked during the first 60 days of the outage and used no later than day 116 of the 

outage. 
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Example 14: Outage Minimum Day Off Extension 

An individual has not worked for a licensee on a nuclear unit outage with work hour controls for 

14 days. The individual starts work on outage day 15. Can the worker be placed under the outage 

work hour controls only for a period of 45 days? 

Answer: The 60-day period is defined by the start of the outage. The worker can be placed under 

the outage work hour controls only for a period of 45 days. The worker may also be available for 

a 14-day extension if the worker did not work more than 48 hours during each of the prior 

weeks. A worker that was on vacation during the 14-day period would be eligible for a 14-day 

extension. This extension for outage work hour controls cannot be extended into non-outage 

periods. 

Example 15: Forced Outage Truncating On-Line Shift Cycle

What does it look like to be in compliance if the schedule would have been in compliance should 

the forced outage not have occurred? 

Conditions: Plant Online Week 1 (Days 1-7), Forced Outage Weeks 2-5 (Days 8-35). After 

Week 1, crews adopt outage schedule, adhering to outage work hour restrictions. 

Work schedule 

Plant status = Normal Operations

Typcal Schedule - Operations Crews

D = 12-hour day shift from 7 a.m. to 7 p.m.

N = 12-hour night shift from 7 p.m. to 7 a.m.

T = 10-hour training shift from 7:30 a.m. to 5:30 p.m.

Total cycle is for a 5-crew, 35-day rotation.

Crew/Day 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35

MTWTFSSMTW T F S S M T W T F S S M T W T F S S M T W T F S S

A N NN N D D D D T T T T D D D N N N

B D NNNN N N N D D D D T T T T D D

C T T T T DDD N N N N N N N D D D D

D D D DD T T T T D D D N N N N N N N

E NNN DD D D T T T T D D D N N N N

Legend

Day Shift Night Shift Training

Days Off Per Week, Averaged Over Shift Cycle During Periods of Normal Operations (i.e., 

During Week 1) 

Crew A: 6 

Crew B: 3 

Crew C: 1 

Crew D: 3 

Crew E: 4 
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Answer: The above schedule shows that the licensee was currently in compliance and would 

have been in compliance with the minimum days off over the remainder of the shift cycle and 

thus is considered in compliance with the rule when transitioning to the unplanned outage work 

hours. Each crew has an average of 3.4 days off per week over the five weeks (17 days off/five 

weeks). The licensee then must meet the outage work hour requirements during the outage. 

Example 16: Outage Activities 

Provide some actual activities that are considered outage activities. 

Answer: Outage activities are activities associated with the outage unit and common systems 

including covered and non-covered tasks performed while the unit is disconnected from the 

electrical grid.

Examples of unit outage activities include but are not limited to the following: 

x Activities included in the outage schedule. 

x Planning and scheduling activities. 

x Emergent work that impacts the outage unit. 

x Review and impact of activities included in the outage schedule. 

x Switchyard activities. 

x Corrective maintenance. 

x Elective maintenance. 

x Preventive maintenance. 

x Calibrations. 

x Safety tagging. 

x Staging of equipment and tools. 

x Valve lineups and verifications. 

x System readiness inspections. 

x Post-maintenance testing. 

x Surveillance testing. 

x System walk-downs. 

x Containment mobilization and demobilization. 

x Refueling. 

x Fuel movement in the spent fuel pool. 

x Housekeeping walk-downs and inspections. 

x FME activities. 
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x Management observations. 

x Operation, monitoring and alarm response of outage systems and common systems. 

x Operation, monitoring and alarm response of stand-alone systems required to support the 

outage unit such as auxiliary boiler. 

x Construction activities. 

x Scaffold installation and removal. 

x Temporary power installation and removal. 

x Decontamination activities. 

x Radiation protection activities. 

x Processing of waste water. 

x Outage work control and communication. 

x Participation in pre- and post-job briefs for outage tasks and common systems. 

x Outage unit project coordination. 

x Testing of component on the outage unit or common systems. 

x Pre- and post-shift turnover briefing of outage unit and common systems. 

x Sampling of outage unit and common systems. 

x Chemical addition to outage unit and common systems. 

x Post-event investigation for outage unit and common systems. 

x Receipt of materials in support of the outage. 

x Just in time training of outage activities. 

Example 17: Infrequent Status Checks

After leaving site, a reactor operator who was relieved “at the controls” receives a telephone call 

about a component switch on the control board with a red tag that became unattached. The 

telephone call lasts less than 10 minutes and was before the relieved operator entered his 

traditional sleep period. Does this count as incidental time?

Answer: No, if the call was one time only of short duration (less than 30 minutes), then there is 

no impact to fatigue and can be excluded from consideration of incidental time. If the telephone 

call interrupted the operator’s sleep period, then the supervisor authorizing the call should 

consider the impact of fatigue if the operator is required to be at work the next work shift. 

Example 18A: 

A Freeze Seal watch is in containment to ensure that the freeze seal is being maintained in order 

to provide a safe work boundary per the stations clearance and tagging program, while the 

reactor coolant system is open for maintenance. His actual turnover takes approximately 15 
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minutes; however, due to the congestion at the control point, RP dress out at shift change, took 

another 30 minutes. Can the total time for turnover and dress-out be excluded from work hour 

calculations? 

Answer: Yes. In this case the relief was between two individuals on contiguous shifts that 

needed to be face-to-face, and the compliance with radiological safety requirements must be 

adhered to. 

Example 18B: 

Valve services technicians are working in containment, on a component that is on critical path 

for the outage schedule. At the end of their shift, they plan on relieving “on-station” to adhere to 

the stations outage schedule. The incoming technicians will need to dress out (15 minutes) and 

conduct relief (15 minutes) at the valve location inside containment. Can the 30 minutes be 

considered turnover? 

Answer: No. In this case, a face-to-face turnover was desired to maintain schedule adherence. 

The work could have been stopped, and the turnover could have been conducted in the shop or 

outside containment. In summary, a face-to-face turnover between contiguous shifts was not 

required. 

Example 18C:

A security officer is stationed at a remote post on the perimeter of the owner-controlled area of a 

site. In addition to the normal time for turnover of the security post, 20 additional minutes are 

accrued in transit back to security headquarters to dis-arm. Can the 20 minutes in transit be 

excluded as part of turnover? 

Answer: Yes. 

Example 18D:

An outgoing plant chemist is turning over to the oncoming shift chemist. The individuals are part 

of minimum shift staffing. There is no sampling in progress. The site provides a nominal 20 

minutes of turnover time for the chemists. Can the turnover time be excluded, although no 

safety-related activity is in progress? 

Answer: Yes. It is recognized that covered individuals may not be performing a covered activity 

every moment they are on shift. It is acceptable to provide nominal turnover time regardless of 

the activity in progress. 
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21 REFERENCES AND RESOURCES 

10 CFR 26 Fitness for Duty Programs 

Regulatory Guide 5.73 Fatigue Management for Nuclear Power Plant Personnel 

Federal Register Notice Volume 73, Page 16966, dated March 31, 2008 

SECY 06-0244 Final Rulemaking – Part 26 Fitness for Duty Programs 

SECY 09-0183 Inclusion of QC/QV Personnel Within Scope of Subpart I 

SECY 11-0028 Alternative to MDO provisions of 10CFR26 Subpart I 

NUREG CR-4248 Recommendations on Scheduling and Overtime for NPP 

NUREG-1912 Summary and Analysis of Public Comments for 10CFR Part 26 

FFD Programs 

ML11189A177 Managing Personnel Fatigue at Nuclear Power Reactor Sites 

ML12320A581 Summary of Public Meeting, Oct. 18, 2012, for Part 26 Subpart I 

EGM-09-008 Enforcement Manual Change Notice – Dispositioning Violations 

of NRC Requirements for Work Hour Controls Before and 

Immediately After a Hurricane Emergency Declaration,” dated 

Sept. 24, 2009

ML13052A776 Summary of Public Meeting, Jan 28, 2013, for Part 26 Subpart I 

ML13127A414 Summary of Public Meeting, Apr.11, 2013, for Part 26 Subpart I 

ML13211A211 Summary of Public Meeting, Jul. 16,, 2013, for Part 26 Subpart I 

ML13290A524 Summary of Public Meeting, Sept 18,2013, for Part 26 Subpart I 

ML13364A030 Summary of Public Meeting, Dec 4, 2013, for Part 26 Subpart I 

ML14015A198 1 14 14 NRC Staff review of NEI 06 11 Rev 2f. 
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NEI 06-11 Rev 2 

Reference Aids – Tables and Graphics 

Definitions Terms Relevant to Fatigue Management 

LIST OF TABLES

Table 1 Other Part 26 Sections Applicable to Subpart I 

Table 2A Subpart I Requirements for Different Categories of Individuals 

Table 2B Individuals Subject to Work Hour Controls 

Table 7 What to Include/Exclude When Calculating Work Hours 

Table 9A Work Hours Controls – Normal Operations 

Table 9B Work Hours Controls – Outage 

Table 9C Applying Each Control – Work Hour Limits and Rest Break Requirements 

Table 9D Applying Each Control – MDOs and 54-Hour Alternative 

Table 10 Transitions Out of Outage 

Table 11A Waiver Process 

Table 11B Waivers and Exceptions to Work Hour Controls 

Table 12 Self-Declaration Process 

Table 13A Fatigue Assessment Process 

Table 13B Supervisory Assessment of Fitness” for Waivers vs “Fatigue Assessment” 

Table 15 Documents, Reports, and Reviews Required under Subpart I 

Table 16 Work Hour Control Effectiveness Review Process 

Graphic 1 Fatigue Management as Part of Overall FFD Strategy 

Graphic 2 Minimum Shift Complement During Outage – From Reg. Guide 5.73