How not to lose sleep over fatigue – The importance of implementing effective fatigue risk management systems

Monday, March 1, 2021

19 March marks World Sleep Day, an annual event designed to raise awareness of the “importance of sleep for achieving an optimal quality of life and improved global health”. The theme of World Sleep Day this year is ‘Regular Sleep, Healthy Future’. One of the central elements of healthy sleep is that sleep occurs regularly – that is going to bed and waking up at approximately the same time, every day. Of course, this is challenging for many – shift workers’ working patterns mean that they must sleep at different times throughout the day, while others lose sleep through the week and try to catch up with a lie-in at the weekend.

The Covid-19 pandemic has disrupted traditional work patterns, forcing some employees to work longer shifts, increasing the risk of fatigue, and impacting their sleep. Employers need to implement effective controls to manage fatigue in the workplace to improve safety, support employee health and wellbeing, and avoid business costs due to presenteeism and burnout.

Even in ‘normal’, non-Covid times fatigue is a hazard that must be managed in all industries that require ‘non-standard’ working hours, in other words, shift work, with night shifts and early shifts being particularly challenging from a fatigue perspective. In many industries, the only fatigue management requirement is around the management of hours of work, as set out in the EU Working Time Directive, or regulations around maximum working hours for drivers. Some industries, particularly aviation, but also other safety critical industries such as rail transport, oil & gas and mining, are required to manage hazards within their operations – one of which is fatigue.

We know that prescriptive limitations, which outline how many hours can be worked and the minimum number of hours for rest, are not effective for controlling fatigue risk, as they do not consider many important factors. This includes differences between types of operation within the same industry, differences in the ability for people to get enough sleep during time off at different times of day (it is much more difficult to get eight hours’ sleep during 12 hours  off between 0800-2000 than it is if the time off is between 2000-0800) to name just two.

Instead, operators are recommended to use data-driven fatigue risk management approaches, which enable the contributors to fatigue to be identified and managed. Such an approach can allow new and emerging fatigue hazards to be identified, such as, the disruption to sleep patterns and working hours during the pandemic highlighting that effective fatigue management has never been so crucial.

The pandemic has affected multiple industries, not least healthcare with professionals working round the clock in incredibly challenging environments, under huge pressure – a perfect storm for fatigue.

Aviation operators providing cargo, initially for moving PPE stocks around the globe, and latterly distributing vital vaccine stocks, and evacuation/repatriation flights were granted exemptions from local flight time limitations, in order to permit long haul return flights without crew staying over down route – in order to protect against infection. In order to permit this, the operators were required to demonstrate that their fatigue management arrangements were appropriate to ensure that such duties could be operated safely.

In many sectors some workers have been furloughed, while others have been working throughout the pandemic, often working more hours than they did prior to the pandemic and possibly having to combine work with home-schooling and childcare.

In industries such as the medical profession and aviation, it seems likely that not all annual leave may have been taken, with high workloads requiring people to cancel their holidays and continue working. One survey carried out by a personal finance comparison website ( revealed that 67% of full-time employees responding to the survey planned to roll over at least 1 day of annual leave from 2020 into 2021, with 37% of respondents wishing to roll over more than 5 days that they hadn’t been able to take during the 2020 holiday period.

How can employers implement effective Fatigue Risk Management?

There is no one-size fits all solution to managing fatigue. However, employers should consider taking a ‘system-wide’ approach, where both the company and individual employees share the responsibility for ensuring that fatigue is managed. Fatigue cannot be managed without both parties playing their part. Employers need to implement training that is tailored to the organisation and takes into account individual employees’ responsibilities, the environment and working hours. Training programmes must also be nimble and respond to change, and provide those responsible for managing fatigue (their own or others) with the competency to respond to change. This year, we have seen that the whole world can change incredibly rapidly. Through this change, we have seen that many of the methods that we use to identify fatigue levels and contributors may not have been agile enough to provide an up-to-date indicator of how fatigue has changed as we have been working in this new world. For FRM to be effective, it must be able to detect the effect of all changes, however large or small, as they emerge, so that risk management can be proactive, rather than lagging behind and potentially allowing brief periods of elevated fatigue going unrecognised.

Communication and transparency are also key to drive organisational engagement with a fatigue risk management programme. Communication need not be complicated and could include elements such as replying to all reports of fatigue and letting the reporter know what the outcome of their report has been, and regular sharing of articles from those running FRM training providing updates on recent activities and mitigations that have been implemented.

In aviation, commercial operators (primarily airlines and freight operators) in many parts of the world are legally required to manage the risk of fatigue using a ‘performance based approach’, which requires the use of FRM procedures alongside following prescriptive flight time limitations that are outlined by the local regulator. For most operators, this involves using their broader safety management system (SMS) to manage fatigue risks. For these operators, the most common procedures implemented include data collection to enable the identification of hazards (usually through reporting of fatigue risks by frontline personnel, but often also including an analysis of the rosters prior to publication using a fatigue model), and specific fatigue training added into the CRM training programme.

Whilst there is still a way to go with managing fatigue in aviation, there are lessons that other industries can learn from the experiences of the aviation sector. One of these is that improving fatigue risk management does not always mean that an organisation must increase the number of people that they employ. Whilst there are instances where the main reason for elevated fatigue is short-staffing, in other cases, the scheduling of current staff can be changed, allowing for the same coverage of work periods, with the same number of staff, whilst also lowering fatigue.

When creating the FRM programme, it is important to involve as many of the workforce as possible to gain their perspectives and feedback on individual employees’ situations. Front line personnel are the ‘operational experts’ and their knowledge of fatigue contributors and the functioning of the organisation can be invaluable when creating the FRM programme, and in identifying which mitigations are ‘doable’ and will be effective.

There is no ‘quick-win’ to implement an effective system for identifying and managing fatigue risk. It takes time and effort to make your processes and procedures effective, but at that point your organisation and the workforce are able to reap the benefits from being an organisation in which fatigue is effectively managed.

Data collection is essential – risk cannot be managed without being measured. Multiple sources of data are needed, because they all tell you slightly different things. For example, fatigue reports tend to tell us about unusual events or problems out of an individual’s control such as a poor hotel room on a business trip or crew layover, but they may not reveal day-to-day fatigue levels. A fatigue model gives us information about roster-related fatigue contributors for the average individual, but can tell us nothing about fatigue related to people’s home lives, their commute, or workload while on duty.

As part of the data collection process, FRMS requires proactive, predictive and reactive approaches to identifying fatigue risks, alongside mitigations to be implemented to control fatigue to acceptable levels, performance indicators to be used to track their use, and formal assurance processes to ensure that everything implemented is working as intended. In the aviation setting, a ‘formally approved FRMS’ is one that has been submitted to the local regulator, for example UK CAA for UK airline operators, by an operator who is using it to support a safety case, such as to demonstrate that they are able to operate in a specific way outside of the flight time limitations, for example to carry out Ultra Long Flights, that are longer than 16 hours.

Implementing a regulatory approved FRMS and undertaking a scientific study is a significant undertaking, and only a small number of operators world-wide have taken this approach. In all industries, an undertaking such as this must have a clear rationale – is the business case for operating this flight strong, or for an oil and gas operator, are there other reasons, such as difficulty travelling to remote sites, why a longer period of consecutive work days is preferable? With a well-thought out and focussed scientific study, and effective FRMS support, the business gets assurance that their critical patterns of work can be carried out safely from a fatigue perspective.

About Baines Simmons’ Fatigue Risk Management services
Baines Simmons are specialist in aviation regulations, compliance and safety management, partnering with the world’s leading civil and defence aviation organisations to improve safety performance. Fatigue Risk Management services including training and consulting, assisting safety-critical industries to measure and understand fatigue risk and to manage that risk through the implementation of fatigue risk management (FRM).