Risk management approach to fatigue

This guidance can help employers to eliminate or reduce the risk of fatigue at a workplace.

Definition of work-related fatigue

Fatigue is an acute and/or ongoing state that leads to physical, mental or emotional exhaustion and prevents people from functioning safely. Working long hours, with intense mental or physical effort, or during some or all of the natural time for sleep, can cause fatigue. All of these have obvious implications for workplace and public safety. Fatigue can also have long-term effects on health.

How to manage the risks of work-related fatigue

A risk management approach ensures fatigue risks are identified, understood, monitored and controlled. It recognises that each situation has its own characteristics, which should be assessed to decide the best way of improving health and safety.

An effective risk management system should methodically and comprehensively ensure your employees' health and safety by addressing three key areas:

  • preventing harm by identifying physical and psychosocial hazards for fatigue, predicting and implementing measures to prevent fatigue and associated issues
  • monitoring and early intervention by monitoring fatigue risks and signs of employee fatigue across work hours, and intervening to prevent issues or restore capacity until employees have an opportunity to recover
  • supporting recovery by providing opportunities to recover and overcome exhaustion

Employers must:

  • provide training, information, instruction and supervision for all affected employees
  • provide a system for monitoring the health of employees and conditions at the workplace
  • have a system for employee consultation

In addition, an effective fatigue risk management system should include:

  • policies that prioritise safety and accountability
  • approaches for holding leaders and managers accountable for upholding safety policies and procedures, including the support and resources for implementation and monitoring of fatigue prevention
  • a non-punitive system for reporting and managing employee fatigue
  • an approach to monitoring employee fatigue and procedures for intervening when employees are identified as being at risk of fatigue-related incidents or injuries an incident reporting and investigation procedure
  • a process for deciding and initiating action and change following an incident and investigation
  • a system for reviewing the effectiveness of risk controls and elements of the fatigue risk management system

  1. Identify fatigue-related hazards

    Identify all the fatigue-related hazards that could cause harm.

  2. Assess the risks

    Assess the nature of the harm that could be caused by the hazards identified in step 1, including how serious the harm could be and the likelihood of it happening.

  3. Control the risks

    Select risk control measures on the basis of highest protection and most reliability (refer to the hierarchy of control). Determine and implement the most effective control measure/s that are reasonably practicable in the circumstances.

  4. Monitor and review hazards and control measures

    Ensure controls are working as planned and, when necessary, improved.

The importance of consultation

A successful risk management process involves consultation between employers and employees and/or their Health and Safety Representatives. Consultation is a requirement under the OHS Act. The points at which consultation must, so far as is reasonably practicable, occur are:

  • when the organisation identifies fatigue is a hazard in the workplace
  • when the organisation reviews how fatigue is currently managed
  • when changes are proposed to work schedules and working procedures
  • prior to new work schedules and working procedures being introduced
  • at each step of the risk management process

In addition, consultation:

  • must take place after an incident or near miss occurs where required by the Victorian
  • Occupational Health and Safety regulations and should take place in all other circumstances
  • should take place where there are indications of fatigue affecting the health and safety of employees
  • should be undertaken to help identify training needs for fatigue management

Consulting employees at each step of the risk management process encourages everyone to work together to identify fatigue-related hazards and risks and implement effective control measures. Consultation also helps to raise awareness about the risks and consequences associated with fatigue as a workplace hazard and buy-in for any proposed actions.

Step 1: Identify fatigue-related hazards

The first step in the risk management process is to identify the factors associated with physical, mental and emotional fatigue risk. It is essential to consider all the factors that might contribute directly and indirectly to fatigue risk across the workplace, the work and employees. It is often not enough to only consider the most obvious cause (e.g. scheduling or work duration).

Organisations should use a number of sources to fully understand the extent and severity of fatigue-related risks, such as:

  • consultation, communication and co-operation with employees and their HSRs
  • workplace walk-through inspections to identify issues relating to environment, equipment, materials, substances, and tasks
  • a review of organisational records, reviews and data analyses – such as hours of work records, driving logs and durations, rosters and incident data
  • employee survey or sick leave data that might indicate mental or emotional fatigue

You should also consider the organisation and management of work, as well as your culture, leadership practices, current policies and procedures. Considering current best practice and research on fatigue and consulting industry or employee associations that may be able to assist with risk identification and assessment can also be helpful.

Workplace inspection

A workplace 'walk-through' inspection is a useful way of identifying hazards. It is a systematic way of gathering and recording information quickly to ensure hazards are not overlooked. Appendix 2 in the full PDF document may help identify issues to be considered during the walk-through inspection and risk assessment process. This can be done with an HSR or an employee who works in the area to capture useful insights.

Review of organisational records and data analyses

Workplace data can provide valuable information to help inform the decision-making process in the assessment of risks. A review of relevant records and other workplace data can help determine potential fatigue risks including the likelihood of employee health and safety being affected, potential severity of the consequences of fatigue, and to decide upon control measures so far as reasonably practicable.

The data should be analysed to establish a baseline for monitoring changes in reporting, measuring improvement, and to monitor and analyse trends. The data can be used to support decision-making and setting priorities for further investigation, assessment, action or review.

A holistic approach should be undertaken to inform and verify any conclusions drawn from workplace data, considering factors such as:

  • reviewing data across an adequate period of time to ascertain common themes and trends (an adequate period of observation to draw conclusions)
  • ensuring multiple relevant data sources are used and conclusions are not drawn from the data in isolation (for example, consult with employees and review other trends)
  • ensuring data selected is reflective of all relevant employee experiences, not just a select few
  • using both lead (a measure preceding or indicating a future event) and lag (a measure for previous events) indicators

Sources of data can vary depending on the size of your workplace. Appendix 1 in the full PDF document (link at the bottom of this page) provides a detailed overview of examples of the type of data that may be available to help an organisation to understanding the level of risk associated with fatigue.

Interaction with other hazards

When taking a risk management approach to fatigue, it is very important to consider how fatigue might interact with other workplace hazards. The level of risk associated with some hazards, such as manual tasks and exposure to hazardous chemicals, dust, and noise, may increase when working extended hours.

Manual tasks

The risk of a musculoskeletal injury increases during an extended shift due to the cumulative effects of muscle fatigue, strains and sprains, that is, the risk of injury is significantly higher during a 12-hour shift than during an eight-hour shift. Employees who perform repetitive manual tasks should have regular rest breaks. Injuries usually occur towards the end of a shift.

Exposure levels

Exposure to hazards, such as noise, heat and chemicals, may also increase during extended working hours. Exposure should be carefully monitored, and exposure levels adjusted. National and international exposure standards are usually based on five eight-hour working days per week.

Seek expert advice when adjusting exposure levels.

Exposure during a 10-hour work day, for example, may not equate to 1.25 times the exposure experienced during an eight-hour shift. The reduced recovery time after being exposed to a hazard during an extended shift also needs to be accounted for. Aim for best practice, keep all exposures significantly below the specified standards and allow for daily variations in exposure levels.

Step 2: Assessing fatigue risks

Risk assessment is a way of deciding which hazards need to be addressed and in what order. Risk assessment should indicate the likelihood of the risks causing harm, the anticipated severity of any harm caused, and the actions required to control the risks.

Depending on the risk and information available, a risk assessment may be as simple as a discussion with your employees, or it may be more complex and involve specific risk analysis tools and techniques recommended by safety professionals.

The following questions, in conjunction with Appendix 2 in the full PDF document, will support you to assess fatigue risks in your workplace:

  • How likely is fatigue to occur?
    • How severe are the possible consequences – i.e. could the hazard cause death, serious injuries, illness or minor injuries to employees and/or in turn expose others to risks to their health or safety?
      • Where, which and how many employees are likely to be at risk of becoming impaired by fatigue?
        • How many employees are likely to be harmed at the workplace, or external to the workplace – i.e. driving home or work-related driving?
          • Is there a domino or cumulative effect of failed control measures?
            • Could a small error escalate to a much larger error with more serious consequences?
              • Is there any information regarding previous workplace incidents, or near-misses, as a consequence of fatigue?
                • Has anything changed recently that might impact existing risks or controls?
                  • Changes might include new employees or leaders, new schedules, increased sick leave, downsizing, or conflict.
                • Do control measures exist and are they adequate?
                  • What other control measures need to be put in place?
                    • How urgently does this action need to be taken?

                      The risk assessment should place the fatigue risk factors in order of priority and those with the highest level of risk should be addressed first. It is also important to recognise factors can be interrelated and therefore should not be considered in isolation.

                      Step 3: Controlling fatigue risks

                      Hierarchy of control

                      If your assessment has identified actual or potential harm from exposure to physical and/or psychosocial hazards, the next step is to control fatigue risks assessed as requiring risk controls. Under OHS laws, work-related hazards that present a risk to physical and/or psychological health and safety must be eliminated so far as is reasonably practicable or, if not reasonably practicable, the risks must be minimised so far as is reasonably practicable.

                      Some control measures are more effective than others. The ranking of controls from the highest level of protection and reliability to the lowest, is known as the hierarchy of control. It is important to work through the hierarchy of control to help you eliminate or minimise risks. Control measures should be matched to the hazards identified and assessed in steps 1 and 2 of the risk management process. When deciding on risk controls, you should also check whether any measures currently being used to address the problem are effective and that new or additional control measures do not introduce additional hazards.

                      Work design is often the best way to directly address fatigue risk. This might include planning and scheduling to manage work duration and the effects of shift work on employees' body clocks. Control measures relevant to several aspects of work design are described later in this section.

                      However, remember to consider both direct and indirect contributing factors when deciding on controls, and how they might interact to impact the effectiveness of these controls. For example, if a new scheduling process is the most appropriate control, consider if your leaders will support compliance with this new process and whether managers and employees have the skills and knowledge to comply.

                      While preventing harm is your first priority, an effective fatigue risk management system also supports intervening early to manage issues and promote recovery. You should consider these aims when deciding on your broader risk management activities.

                      The risk control measures outlined in the next sections show where they are most effective for preventing harm, intervening early to manage issues as they occur, and supporting recovery.

                      Physical, mental and emotional demands of work

                      Table 3 in the full PDF document provides an overview of measures that can be used to address the risks associated with the physical, mental and emotional demands of work. These are listed in the order of the hierarchy of control, with controls to eliminate risks at the top. These controls should be considered first, before considering other options.

                      Work duration

                      Table 4 in the full PDF document provides an overview of measures that can be used to address the risks associated with work duration. These are listed in the order of the hierarchy of control, with controls to eliminate risks at the top. These controls should be considered first, before considering other options.

                      Work scheduling and planning

                      Shift scheduling and planning is an important fatigue risk management approach that can be supported by scheduling software, such as technology leveraging bio-mathematical models. Such software can enhance the quality of data used to develop appropriate schedules and help manage irregular operations. Software can also be used to monitor fatigue risk during shifts, and support analysis of fatigue impact in accidents. However, like all technology, the use of this software requires appropriate human interpretation.

                      Tables 5, 6 and 7 in the full PDF document provide an overview of measures that can be used to address the risks associated with scheduling and planning, including:

                      • adequate staffing
                      • managing shift work
                      • managing night shift

                      Environmental conditions

                      Table 8 in the full PDF document provides an overview of measures that can be used to address the risks associated with environmental conditions.

                      Training

                      As an employer you must provide information, instruction, training and supervision to employees, as is necessary, to enable them to work in a way that is safe and without risks to health.

                      Training can support employees to manage the requirements and demands of their role, understand and identify fatigue and associated risks, understand and comply with OHS responsibilities and policies.

                      Training is an important part of a risk management approach to fatigue but is not effective on its own and must be used in conjunction with other controls. Necessary training and information should be available to employees on all shifts, covering:

                      • any specific knowledge and skills a person needs to fulfil their role effectively, or to manage new and/or temporary responsibilities
                      • OHS responsibilities of everyone in the workplace
                      • body clock and sleep processes (including sleep hygiene and sleep disorders)
                      • risk factors for each types of fatigue (physical, mental and emotional)
                      • signs and symptoms of each type of fatigue in self and others
                      • self-assessment tools and risk management strategies
                      • procedures for preventing fatigue, such as incident reporting
                      • health and lifestyle factors that may contribute to fatigue or impede good quality sleep, and
                      • balancing work and life demands

                      Additional training for officers, managers or other employees with responsibilities for managing fatigue risk and/or rostering should be provided, covering:

                      • how to identify the causes of fatigue and potential consequences
                      • understanding and applying relevant legislation
                      • obligations and responsibilities for various roles
                      • development and implementation of risk management strategies, such as work scheduling, to eliminate or minimise fatigue-related risk so far as reasonably practicable
                      • effective control measures for fatigue, such as work scheduling
                      • the importance of a workplace culture that supports fatigue management, and
                      • other positive leadership practices relevant to the context and cultural aspirations, such as effective communication, conflict management, change management, leading teams, and so on

                      Step 4: Monitoring and review of control measures

                      Not all control measures will work as effectively as intended, and they may not remain effective over time as things change.

                      It is therefore essential to engage in ongoing monitoring and review of control measures, learn from experiences and make changes as necessary. High-risk hazards will require more frequent review. This process may require steps 1 and 2 (identify and assess risks) to be repeated to ensure all risks have been controlled for so far as reasonably practicable.

                      Remember, consultation with employees is an important part of this process, which will likely involve trialling and refining control measures and considering employee feedback, new technology and changes in knowledge.

                      Having a monitoring and review process and plan in place will help you clarify your review objectives and the actions you need to take to make sure your review is successful.