The Washington Metrorail Safety Commission says in a new audit that Metro isn’t tracking the annual physical health and properly managing the fatigue of its train operators, possibly putting both operators and passengers at risk.

The independent safety commission, established in 2019, says Metro cannot “reasonably ensure employees… conducting safety sensitive duties are free from impairment that could cause incapacitation.” Among the issues: physical health, lack of alertness and impairment from fatigue, and effects from drug and alcohol use.

The audit handed down 11 required correction action plans and four recommendations on “fitness of duty” that Metro must address in the next 30 days. Metro did not yet have a comment on the report, as it was just released on Tuesday morning.

Auditors say Metro isn’t enforcing much of its fatigue management policy, including the minimum rest period that operators must have between shifts. The National Transportation Safety Board recommends at least eight hours of uninterrupted sleep between shifts, and officials found that lack of sleep likely contributed to crashes and other incidents in the system. Metro requires 10 hours between shifts, but it doesn’t always happen.

Transit industry organizations also recommend that operators shouldn’t work more than six days in a row. WMATA also isn’t documenting these requirements, so the safety commission couldn’t evaluate how well it is following the practice. It demands Metro keep clock-in and clock-out times to better track the issue.

The safety commission says impairments have contributed to incidents in the rail system, like a 2004 train rollback that resulted in a collision with another train at the Woodley Park station.

Metro also isn’t doing required annual physicals, the commission says.

“This creates a risk that safety sensitive employees are operating trains with undiagnosed or untreated conditions such as diabetes, hypertension and obstructive sleep apnea that, when not properly managed, increase the risk of loss of consciousness,” it said in the audit.

In the future, Metro must communicate, conduct, and track all physicals, the commission says.

The safety commission did give Metro kudos for its drug and alcohol testing program — which goes beyond what the U.S. Department of Transportation requires — but it did note that Metro needs written criteria for when testing is done after an incident.

The commission has found that while some personnel were tested after incidents, others weren’t. They also couldn’t find records of some tests or if they were completed, as well as documentation on whether employees were removed from service as required.