Fatigue Management and the WHS Act

In recent times, we have seen many awareness campaigns from the regulators in relation to fatigue and long distance driving.  The campaigns were designed to optimise safety outcomes across the industry.

Fatigue does not only affect long distance truck drivers.  Are you aware of the potential for work related fatigue to become a workplace health and safety (WHS) issue in your workplace?

The Work Health and Safety (WHS) Act 2011 places a legal obligation on a person conducting a business or undertaking (PCBU) to consult and manage risks to health and safety by either eliminating risks so far as is reasonably practicable or if not reasonably practicable, minimise those risks. The same principles apply when managing the risk of fatigue in the workplace.

Managing Fatigue in the Workplace

Fatigue may be an acute state of tiredness or an accumulated chronic state of exhaustion that could lead to mental or physical exhaustion.  It can occur when a person’s psychological and physical capabilities are stretched to their very limits. Fatigue can also lead to long-term health problems. Its management is one of the components on an overall approach to fitness for work.

Fatigue is mental or physical exhaustion that prevents a person from functioning normally and can impair safe work performance.

Fatigue can be a caused by both work and non-work related factors:

• Non-work factors can include family and carer responsibilities, secondary employment, social and lifestyle activities, health issues (such as sleep disorders), study, sporting commitments etc.
• Work factors can include shift work – especially night shift, working extended hours, inadequate rest breaks, insufficient recovery time between shifts, driving long distances, among other reasons.

• Workers’ lifestyle and personal commitments outside of the workplace have potential to either mitigate or exacerbate how fatigue might be experienced in the workplace. Workers should be cognisant of this relationship and recognise their own role in managing lifestyle related fatigue.

• Workers have a legal duty to take ‘reasonable care’ to ensure that their acts are not harmful to the health and safety of themselves or others. i.e. a worker must present themselves to work in a fit state to conduct duties safely, and
• Workers must also comply with any reasonable instruction by the PCBU and cooperate with any reasonable policies and procedures of the PCBU – e.g. The PCBU’s Code of Conduct would cover how workers are expected to act i.e.  Act Professionally and Ethically.

Identifying if fatigue is a hazard

The following sources of information may assist in identifying whether work related fatigue has the potential to, or already has become a workplace issue:

• Observing for signs of fatigue, such as levels of alertness, reaction times and excessive yawning.
• Observing work practices and systems of work.
• Industrial issues, complaints or grievances citing fatigue.
• Staff and/or customer complaints.
• Some workers are at higher risk of fatigue because their work typically involves some or all of the factors that contribute to fatigue e.g., shift workers, night duty workers, on call workers, medical professionals etc.

Assessing fatigue risks

When assessing fatigue risk it is important to look at how fatigue can interact with other workplace hazards. Some hazards that can be increased when working extended hours are manual tasks and exposure to hazardous chemicals, dust and noise.

• Consulting workers on workloads and schedules – ask if they are edxperiencing or have experienced work related fatigue.
• Auditing of working hours. Where appropriate, related issues to consider may include work related travel and work completed outside of normal hours (e.g. when people take work home).
• Reviewing workplace incident data in regard to the fatigue hazard factors. Ask:
  • What is the likelihood that fatigue is contributing to the incidents?
  • What time of day do incidents occur?
  • When incidents occurred, how long had the workers involved been working?
  • When incidents occurred, was it when a worker’s body clock is low and concentration poor?
  • Reviewing work related motor vehicle incidents.
  • Enquiring if workers have had accidents travelling to and from work.

Eliminating or controlling the risks associated with work fatigue

 While actions taken will be specific to the individual circumstances and dependent on the issues identified suggested examples are provided below

• Shift and Rostering Design
  • Using a forward shift rotation e.g. starting times moving from morning to afternoon to night time.
  • Maximising breaks between shifts and before rotating workers to a new shift.
  • Minimising the number of consecutive night shifts.
  • Ensuring those periods of extended work hours are followed by an appropriate recovery time before resuming work.
  • Ensuring rosters reflect an appropriate skills mix.
  • Avoiding overtime allocation after afternoon or night shifts, especially after 10 or 12 hour night shifts.
  • Schedule low risk work during high fatigue periods. For example, at end of shifts and between 0200 – 0600 hours.

• Leave Management:
  • Ensuring a process is in place for reducing/minimising excessive accumulation of annual leave entitlements.
  • Ensuring the process for managing and monitoring rosters and leave are linked.
  • Ensuring service delivery needs and the impact on workers are considered and managed when planning rosters and approving leave.
  • Making alternative arrangements for workers to cover a roster as and when required.
  • Ensuring appropriate rest and nutrition breaks are provided in accordance with the relevant Award.
  • Managers may need to seek advice from their Human Resources Unit regarding relevant Awards.

• Work Environment:
  • If applicable provide rest accommodation or safe travel options after extra – long or extended shifts.
  • Ensure workers take regular rest breaks when driving long distances.
  • Sharing vehicles so driving duties can be shared if required.
  • Ensure adequate lighting since dim lighting strains the eyes and can create a tendency to sleep.
  • Provide adequate ventilation to ensure the work environment is not at temperature extremes.

• Staff Support:
  • Ensure that all workers are aware of policies, procedures and expectations regarding rostering and leave.
  • Provide information to workers on how they can manage both work and non – work related fatigue e.g. Nutrition, fitness and health issues relating to fatigue.

Safe Work Australia have produced two guides, one for the PCBU –  Guide for managing the risk of fatigue at work‘ and one for the Workers – ‘Fatigue management – a worker’s guide‘.  These guides provide further resources and checklists etc. to assist you in managing fatigue in your workplace.

You can find out more by visiting our page on Fatigue Management Training or by calling AlertForce on 1800 900 222.