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How to Develop a Fatigue Management Policy

Ever wondered how a simple policy could save billions?

Studies reveal that fatigue-related incidents cost businesses billions annually, with fatigue being a leading factor in workplace accidents and errors. 

Developing a robust fatigue management policy can mitigate many risks by systematically assessing and addressing fatigue factors. This policy can save your workplace by establishing controls and standards, providing training and education, implementing reporting processes, and regularly reviewing effectiveness. 

This guide will help managers learn and go through the step-by-step process of developing an effective fatigue management policy. It covers critical areas, including:

  • Legal and Regulatory Considerations for Policy Making
  • Assessing Fatigue Risks for Developing Policy
  • Developing a Fatigue Risk Management Policy (Step-by-Step)
  • Disciplinary Measures of Fatigue Management Policy
  • Role of SafetyIQ in Managing Fatigue

By following this guide, managers can ensure a safer and healthier work environment while optimizing organizational performance.

Legal and Regulatory Considerations for Fatigue Management Policy 

When developing a fatigue management policy, it's important to consider relevant laws and regulations. Key regulations related to fatigue management include:

1. OSHA Regulations

The Occupational Safety and Health Administration (OSHA) regulates workplace fatigue through the General Duty Clause of the OSH Act (1970). This states that employers must provide a workplace free from recognized hazards likely to cause death or severe harm. Failure to address fatigue risks may violate the General Duty Clause.

Some OSHA regulations related to fatigue risks include:

  • Illumination standards requiring adequate workplace lighting
  • Walking-Working Surfaces standards on slip, trip and fall hazards
  • Personal Protective Equipment standards on the proper use of PPE while fatigued

2. DOT Hours of Service Rules

The Department of Transportation (DOT) regulates driver fatigue for commercial motor vehicles. 

Key regulations include:

  • Limits on driving time per day and week
  • Mandatory breaks and rest periods
  • Requirements for time off between shifts

Carriers and drivers must comply with DOT hours of service rules to manage fatigue.

3. State and Local Laws

Many states and localities have additional rules related to fatigue management. These may cover meal and rest breaks, shift scheduling, mandatory overtime, etc. Employers should review and comply with any applicable state or local laws related to workplace fatigue in their jurisdiction.

Employers (including operations and HR managers) must develop fatigue policies aligned with relevant regulations. Failure to comply can result in OSHA citations, DOT violations, lawsuits, and an increased risk of fatigue-related incidents. Also, staying current on regulatory changes allows for the improvement of fatigue programs over time.

FOR A COMPREHENSIVE ANALYSIS OF RISK FACTORS DUE TO FATIGUE, DOWNLOAD OUR FREE FATIGUE MANAGEMENT GUIDE HERE.

Assessing Fatigue Risks for Developing Fatigue Management Policy

Some things to consider when assessing fatigue risk include:

Identifying High-Risk Jobs and Tasks

Some positions are at higher risk of fatigue due to the hours worked, type of work, and work environment. Jobs that require long hours, night/shift work, repetitive tasks, or work in extreme environments tend to have higher fatigue risks. 

Examples include:

  • Drivers (especially long-haul trucking)
  • Healthcare workers
  • Manufacturing and warehouse workers
  • Mining, oil/gas, and other remote site workers
  • Aviation and transportation workers

Factors That Contribute to Fatigue

There are a number of factors that can increase the risk of fatigue for workers:

  • Hours worked

Consistently working over 8 hours a day or 40 hours a week can lead to cumulative fatigue. Shift work and night shifts also disrupt sleep cycles.

  • Task type

Repetitive, tedious tasks require sustained mental focus and can cause fatigue quicker than engaging tasks. Physically demanding labor also leads to fatigue.

  • Work environment 

Hot, cold, noisy, or otherwise harsh environments make workers tire faster.

  • Inadequate breaks

Frequent short breaks are needed to rest, stretch, and re-energize.

  • Sleep loss 

Not getting 7-9 hours of quality sleep negatively impacts alertness and performance.

  • Health factors

Medical conditions, medication side effects, and poor nutrition can increase fatigue.

Developing a Fatigue Risk Management Policy (Step-by-Step)

Developing an effective fatigue risk management policy requires a systematic approach to assess risk factors, establish controls, and implement training and reporting processes. Here are the key steps:

Step 1: Assess Fatigue Risk Factors

Conduct a fatigue risk assessment to identify factors that contribute to fatigue in your workplace, such as shift lengths, break times, commute distances, and workload. Review incident reports, absenteeism rates, and employee feedback surveys to gather data. Identify high-risk roles, tasks, or operational situations.

Let’s understand this step more clearly:

You're the HR manager at a manufacturing plant. Recently, occupational accident and absence rates have increased. You decide to conduct a fatigue risk assessment because you think fatigue may be a contributing factor.

You schedule observations, employee feedback questionnaires, and incident reports as sources of information to collect data. You discover that workers on the night shift have complained about feeling sleepy in the early morning hours. Fatigue is worsened by the lengthy duties that some employees have to face.

Step 2: Consult Stakeholders

Involve employees, supervisors, health and safety representatives, and management in the policy development process. Get their input on fatigue risks and control measures. Ongoing consultation will aid implementation.

For instance, as an HR manager, you set up a meeting with the department head [health and safety representatives and employee representatives] with the information you've gathered. You give the information at the meeting and let participants inquire about it.

Supervisors can raise concerns about the long hours some workers work because of higher demand. Representatives from health and safety stress the importance of taking breaks and rest times. Employee representatives talk about the difficulties of balancing work with long journeys.

Step 3: Establish Controls and Standards

Determine appropriate controls to mitigate identified fatigue risks, such as limits on hours worked, minimum break requirements, call-out policies, and minimum rest periods between shifts. Refer to scientific guidance and industry standards when setting limits and thresholds.

In this step, what do you do?

A fatigue risk management policy is written after getting feedback from key parties. The policy prevents working more than eight hours in a row, requires breaks, and allows workers with long commutes to switch shifts.

You review the scientific literature and industry standards to ensure the suggested controls align with best practices. After it has been reviewed and approved by management, the policy becomes accessible to all workers.

Step 4: Training and Education

Provide training to employees and supervisors on fatigue causes and effects, managing fatigue, reporting procedures, and their role in supporting the policy. Promote awareness of healthy sleep habits and fatigue countermeasures. 

Here’s how it works.

To ensure the policy is followed correctly, you set up training sessions for both workers and supervisors. During the meetings, you discuss how fatigue affects safety and performance, how to deal with fatigue, and how important it is to report problems.

Supervisors are instructed on telling when their employees are tired and how to change their work plans to accommodate this. Employees are also advised on how to get enough sleep and deal with fatigue.

Step 5: Reporting Processes

Implement procedures for employees to report fatigue concerns confidentially. Establish processes for supervisors to report non-compliance, incidents, and fatigue-related hazards.

For instance, as part of the policy rollout, you establish a confidential way for workers to report concerns about fatigue. Managers are instructed to report any violations of the policy or safety incidents that might be connected to fatigue.

Employees' reports will be kept secret, encouraging them to speak out without worrying about getting in trouble. Supervisors must be instructed to respond carefully to reports and quickly deal with all issues.

Step 6: Policy Review Procedures

Schedule regular reviews of the policy's effectiveness and relevance. Use data from reporting, audits, and feedback to identify gaps and opportunities for improvement. Update the policy as needed.

For example, tweak break schedules to better align with peak fatigue periods or introduce additional training modules based on identified gaps.

Example of a Fatigue Management Policy

Disciplinary Measures of Fatigue Management Policy

When it comes to disciplining those who violate the fatigue management policy, the focus should be on education and prevention rather than punishment. However, progressive discipline may be necessary in some cases.

ViolationDisciplinary ActionAction
First ViolationCoaching and RetrainingEmployee receives coaching and retraining on fatigue risks and the importance of following the policy. Goal is to correct behavior through education.
Continued ViolationVerbal WarningEmphasizes that further issues will lead to more serious discipline.
Continued ViolationWritten WarningAdded to the employee's record, making clear the behavior is unacceptable. Puts the employee on notice that additional issues could lead to suspension or termination.
Ongoing/SevereSuspension Without PayRemoves the employee from the workplace while underscoring the seriousness of disregarding fatigue policies.
Last ResortTerminationNeeded for workers who consistently break the rules about fatigue, don't change their behavior after being warned several times, or engage in a serious violation that shows they were intentionally careless.

REMEMBER: The focus should always be on correcting issues through training and incentives for compliance, rather than punishment. However, disciplinary procedures must exist to address serious or repeated violations. 

Role of SafetyIQ in Managing Fatigue Across Organizations & Policy Making

SafetyIQ’s Fatigue Management Module is designed to combat workplace fatigue, a significant safety concern for many industries. As a manager, ensuring your staff's alertness is crucial to prevent accidents and injuries. The software tackles this challenge through a unique game-like quiz that assesses workers' alertness.

The software goes beyond basic tests by learning individual behavior patterns and establishing a rolling baseline. This allows SafetyIQ to detect minor changes in alertness that might indicate fatigue. If a worker's score deviates from their usual range, you'll be notified, enabling you to intervene before issues arise.

SafetyIQ's versatility extends to various industries, including manufacturing, construction, and transportation. While the software itself doesn't set policies, it empowers you to enforce existing ones or create new fatigue management protocols. For instance, a policy could mandate removing workers scoring outside their normal range from safety-sensitive tasks.

In conclusion, SafetyIQ equips you with the tools to manage fatigue proactively across your workforce. By identifying workers at risk and enabling early intervention, SafetyIQ fosters a safer and more productive work environment.

Blog

We cover a range of topics in our articles - view all blogs.

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From planning the journey, completing a risk assessment to gaining approval, the entire process is automated and seamless with SafetyIQ.

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