Fatigue significantly increases the risk of incident when not effectively controlled. Karl Simons, chief health, safety and security officer at Thames Water, explains why organisations need to take fatigue management seriously.
Q: What prompted Thames Water to look at the risks posed by fatigue?
We were always looking at the psychological impact mental health and state of mind can have on concentration levels, which can lead to slips and lapses in concentration and judgement, and ultimately end up in incidents and injuries. Errors often arise because someone is not focused on the task at hand, because of worry, tiredness or exhaustion.
Q: What is the industry picture?
Businesses have changed their practices governing the control of working hours to prevent excessive fatigue. The Working Time Directive 2003 tells us that companies must have shift patterns in place to keep working hours to an average of 48 hours per week over a 17-week period and ensure more stringent controls for night shift and vulnerable workers.
As working hours are generally implemented with a great deal of thought and approval, businesses
keep within the rules.
However, there are hidden risks and the key to understanding this is first to ask the right questions. For example, when did you last run a check on overtime hours from a health and safety perspective, not a cost control measure?
There are a number of routes a company can take – including vehicle telematics, reviewing work scheduling devices and sifting through clock-on/clock-off cards – to understand its exposure to fatigue risk, however some of these can provide an inaccurate picture, for example someone might forget to clock off a device and this leads to a false sense of risk control.
Arguably the best mechanism for understanding exposure to fatigue risk is setting robust working hours or shift pattern control and then analysing the overtime hours worked in a department or a company.
Q: What is the position of the UK Health and Safety Executive (HSE) on fatigue?
The HSE has undertaken extensive fatigue management research; this tells us that the risk of incident can escalate as fatigue levels increase, which may have devastating consequences.
Controls need to be implemented because of the risk escalating in such an extraordinary manner, the HSE insists.
Shift patterns are a simple starting point for asking the right question: for example “How many of our people are working in excess of 12 hours in a 24-hour period?” When you start to ask that question, you can start to put in controls.
From what I’ve seen, the water industry collectively has been very good at asking this question, understanding the fatigue risk and implementing controls.
Q: Are there any warning signs employers should be looking out for of employees potentially putting themselves at risk?
There are two ends of the scale. Some employees will speak up and say, ‘I’ve been working hard all week, I am really tired’ and then at the other end of the scale some will say, ‘I worked 16 hours yesterday and 80 hours this week.’ This sort of bravado conversation does happen and are the ones you’ve got to look out for.
As much as someone may feel proud and boast that they have worked 60, 70, 80 hours in a week, that can be very dangerous. It’s about listening out for those conversations and setting the tone within your organisation that says: ‘You’ve got to speak up, call that out and say “That’s not all right, that shouldn’t be happening.”’
This is going to be tough because there may be some organisations where many of the staff live off the money they get from their overtime hours. But it doesn’t detract from the fact that they will be at risk when they are working those long hours and then perhaps operating heavy industrial machinery or driving home at the end of a long shift. That adds to the danger, so factoring in commuting into your fatigue management programme is really important.
Key fatigue takeaways
- Carefully manage and monitor the following areas where the incidence of accidents and injuries is highest: workers on night shifts, those who do successive shifts – especially night shifts – those who do shifts over eight hours, those who do not have enough breaks.
- Manage fatigue risks, regardless of an individual’s willingness to work extra hours or preference for certain shift patterns.
- Risk assess changes to working hours, using the HSE’s ‘fatigue risk index’ tool (see Resources).
- Consult employees on working hours and shift patterns, but remember that they may prefer certain shifts that are unhealthy and likely to lead to fatigue.
- Develop a policy that sets limits on working hours, overtime and shift-swapping to guard against fatigue.
- Implement the policy, monitor it and also ensure it is enforced. This could include developing a robust system of recording working hours, overtime, shift swapping and on-call monitoring.
Q: What subsequent key controls should organisations be putting in place?
Prevention is always better than cure. From a very complex perspective, I have seen and worked in companies that applied a fatigue risk management index type of system. I have also seen those that have applied a more simple and easier-to-manage control: for example, stop, engage and assess at certain trigger points, such as after 12 hours. Finally, there are firms that have management intervention at the point of overtime approval before work proceeds.
Whichever model is implemented by a company, the important thing is that it has been thought through and can then be applied consistently, protecting the individual and company alike.
For example, if an individual hits a trigger point for intervention or feels that if they continue working they may begin to feel tired and makes a call to their manager, this enables mitigation measures to be put in place. It could be: ‘We’re going to down tools and get a new team out.’ Alternatively, it could be: ‘You’ve half an hour’s work left’, in which case continue working but with restrictions in place on the type of work they can do.
If a task must be finished, a risk assessment could include continuing work but with mitigation measures applied, such as an additional person sent out to keep an eye on the technical specialist who must complete the work.
But there needs to be a conversation and a risk assessment before the individual continues working because
the risk of incident is now increasing.
Due to the complexities of managing fatigue and perhaps the sheer volume of extended hours worked in major 24/7 businesses, many organisations have now begun applying a cap on maximum working hours. This is an effective way of forcing steps to be taken at an earlier stage to ensure an individual gets home safe and well.
A key consideration often missed is to factor in workers’ commuting time. Research tells us that, following long working hours, the drive home can become the most dangerous part of the working day.
"As much as someone may feel proud and boast that they have worked 60, 70, 80 hours in a week, that can be very dangerous"
Counting the cost: How big a problem is fatigue?
The HSE estimates that more than 3.5 million people in the UK do shift work across sectors including the emergency services, healthcare, the utilities, transport, entertainment and retail.
Caused by excessive working hours or poorly designed shift patterns (as well as sleep loss and/or disruption to the body clock), fatigue leads to a decline in mental and physical performance and results in slower reactions, a reduced ability to process information, lapses in memory, decreased awareness and
an underestimation of risk.
The HSE says fatigue has been implicated in 20% of UK accidents on major roads. It estimates that fatigue
costs the economy between £115m and £240m in workplace accidents.
Q: In effect, these systems are there to allow the individual to make that call?
In the water industry, there is good consultation and debate, and an alignment towards implementation of controls. For example, in addition to the working hours, shift patterns and trigger points to management intervention controls, the majority of water companies have capped working hours to a maximum of 16 hours in a 24-hour period, with some going so far as to set that cap at 14 hours. There will always be minuscule differences in the specifics of policies for areas such as commuting and breaks, but generally I see an industry working together to effectively control risk and protect people.
Q: How do you manage this in smaller organisations that may not have the resources to enforce these controls?
The challenge is that you are balancing cost and value and that you must also factor in risk. Yes, you can make money – but at what expense in terms of escalating risk, the potential incident to the individual and potential risk of prosecution to the organisation. Companies have to take this on board because it should be a factor in any investigation.
All organisations are responsible for putting in safety measures that prevent individuals from failing. Why would staff want to work excessive hours? It may be because they have financial difficulties or because they are trying to please their boss. Whatever it may be, the company needs to implement the controls, which help staff not to place themselves in a position of risk, in turn placing the organisation in a position of risk.
"There will always be minuscule differences in the specifics of policies for areas such as commuting and breaks"
Q: How do you create the conditions with the worker to have that conversation? It can be a sensitive issue both because of the pressure to work long hours and to earn more money.
The internal culture may be one of open dialogue and the manager may be supportive if the worker says they are tired, but not all organisations are like that. In an organisation where it’s all about working excessive hours, that can lead to a detrimental impact on individuals. Fatigue not only happens within the 24-hour period, it also creeps up on you over time when an employee works repeatedly for a long period over many days.
HSE research tells us that fatigue adds up. That’s why we always feel more tired on a Friday than we do a Monday or Tuesday when we are getting on with work. You naturally, progressively become more tired.
It is important the leadership tone is clear. The starting point for this is the moral message from the top, which then echoes throughout the business, that the priority is to keep everyone safe at work and send them home safe and well at the end of every day.
Q: Should companies apply the same principles throughout the supply chain?
Yes. At Thames Water, we have for many years worked collaboratively with supply chain partners so we have the same level of robust controls for anybody who works on behalf of the organisation. You have got to have a healthy and open debate with your contracting partners around health and safety risk management and this includes fatigue.