The requirement to develop and implement strategies to control risks associated with employee fatigue is found in Regulation 410, which is a duty for all mine operators.
You must read the legislation in addition to this guidance.
Fatigue in the mining industry
Fatigue is more than feeling tired or sleepy. In the OHS Regulations, fatigue means an acute or ongoing state of tiredness that exposes anyone at the mine to a health and safety risk. Fatigue leads to physical, mental or emotional exhaustion and stops people from functioning safely.
Mining often involves:
- demanding and repetitive tasks
- long hours of work
- night shifts
These factors can all contribute to fatigue. Fatigue poses a health and safety risk to employees and those around them.
Risks associated with fatigue
There are three broad categories of fatigue:
- Physical.
- Mental.
- Emotional.
These can occur together or separately.
Fatigue becomes dangerous in a workplace when it leads to:
- loss of concentration
- impaired reaction times
- reduced coordination
- increased error rates
- reduced performance
- impaired judgement and decision making
- susceptibility to micro sleeps
- reduced capacity to communicate effectively, increasing the risk of serious incidents
Long term, fatigue can cause health risks such as:
- anxiety and depression
- drug and alcohol use
- digestive problems
- high blood pressure
- diabetes
- heart disease
- lowered fertility
Hazards that may increase the risks
- Sleep debt
If a person doesn't get enough sleep, they build up what's known as a 'sleep debt'. Each day without enough sleep increases the debt, which can lead to fatigue.
A person can fix the effects of sleep deprivation by recovering the debt. It may take a few nights of adequate sleep to recover from a large sleep debt.
- Working nights
It's common for night-shift employees to experience disrupted sleep patterns. Our natural sleep-wake cycle (circadian rhythm) pushes us to be awake during the day and asleep at night. This can make it hard to sleep during the day.
Night shift employees may also feel pressure to stay awake during the day to spend time with family and friends. This results in a sleep debt and potentially fatigue.
- Extended shifts
Extending an employee's shift can increase the risk of them becoming fatigued. The risk is there not only during the shift but also afterwards. This is because changes to an employee's routine can disrupt their sleep time, which may result in a sleep debt.
- Type of work
Certain types of work are more likely to cause fatigue. This includes work that:
- is physically demanding
- is remote or isolated
- occurs in uncomfortable working conditions, such as environments exposed to:
- loud noises
- vibrations
- cold or heat
- is monotonous
- Commuting
Commuting can contribute to employee fatigue in two ways.
A long commute, especially if it's daily, can erode the time employees can spend with family and friends. This can result in employees not getting enough sleep as they try to meet their personal commitments.
The commute itself can also contribute to fatigue. It sometimes involves a long drive to and from the mine, or travelling to the airport and catching a long flight.
Legal duties
Both employers and employees are responsible for protecting their health and safety and that of others. Under the Occupational Health and Safety Act 2004, an employee also includes:
- independent contractors and their employees
- labour hire workers
Employer responsibilities
As a mine operator, it's your legal duty to identify all mining hazards, including fatigue. There is also a duty to assess the risks associated with these hazards and put control measures in place.
You must, so far as is reasonably practicable, eliminate any mining risks. This includes the risk of fatigue. If it's not reasonably practicable to eliminate a risk, you must reduce it.
You also have a broader duty to provide and maintain a safe working environment.
The following measures can help you fulfil your duties:
- Ensuring employees know about fatigue risks and how to control them.
- Ensuring systems of work (like rosters and breaks) are designed to reduce the risk of fatigue.
- Creating an environment where employees can tell their supervisor that they or someone else may be fatigued.
- Ensuring workplace hazards (like noise and vibration), are controlled so they stay within acceptable limits.
- Ensuring psychosocial hazards (like aggression or high job demands) are eliminated or controlled.
- Providing employees in mining accommodation with a balanced diet and a comfortable place to sleep.
Employee responsibilities
Employees must cooperate with measures an employer has in place to control fatigue. Employees can take reasonable care for their own fatigue by:
- following instructions given to control fatigue risks
- telling their supervisor if they're feeling fatigued
- telling their supervisor if they think another employee is experiencing fatigue
- not entering or staying in a mine if they're affected by alcohol or drugs
- getting enough sleep so they're not fatigued before starting a shift
The following document includes tools to help employees assess their own levels of alertness and fatigue.
Duty to consult
The OHS Regulations state that as an operator of a mine, you must consult with employees and any health and safety representatives (HSRs) about ways to control risks related to fatigue.
It's useful to consult:
- when fatigue is identified as a hazard or there are signs it’s affecting the health and safety of workers
- when carrying out risk assessments and taking steps to control risks
- when introducing educational programs about the risk of fatigue
- when there are changes to work schedules and tasks
- before new work procedures
- after an incident or near-miss
Risk management approach to fatigue
The following four steps can help you manage the risk of fatigue. The accompanying document, Fatigue risk management tools, helps you complete each step. It includes questions, checklists and examples.
You should use multiple approaches to identify fatigue-related hazards, including:
- consulting with employees about their experiences, concerns and observations
- creating an employee survey asking specifically about fatigue related hazards
- workplace walk-through inspections, ideally with an employee or HSR who works in that area
- reviewing organisational documents, records and data to determine potential fatigue-related hazards and to set a baseline for monitoring changes
You can find examples of common fatigue hazards in the fatigue risk management tools document.
You then need to assess all the identified fatigue-related hazards to find out which ones should be addressed and in which order. The order should go from hazards that pose the highest risk to the lowest. High-risk hazards should be addressed as a priority. Mining is a high-risk industry, so if you're not sure how severe a hazard is, treat it as high risk.
The fatigue risk management tools document sets out a list of questions to consider when assessing fatigue risks.
The next step is deciding on the appropriate controls for the fatigue risks you've prioritised.
The best and most effective risk controls are those that eliminate fatigue risks altogether. The next best option is putting controls in place that reduce the risk so far as is reasonably practicable.
The fatigue risk management tools document lists some example risk controls.
The last step requires mine operators to review and, if necessary, revise:
- the identification of mining hazards
- the assessment of risks associated with mining hazards
- the risk controls implemented.
Reviews must be conducted every three years, as well as:
- before any mine modification is made
- after any incident involving a mining hazard occurs at the mine
- if the operator of a mine has removed a person from their work or assigned the person to alternative work
- after receiving a request from an HSR.
It's essential to constantly review controls, learn from experiences and make changes if needed. A formal review includes a repeat of steps 1, 2 and 3 to ensure all risks have been identified, assessed and controlled so far as is reasonably practicable.
The fatigue risk management tools document has questions and tips to help you with this step.