Fatigue Management Programs, Systems and Plans:  Is there a difference? Part III

Part III: Fatigue Management Plans

In Parts I and II of this article series, we compared fatigue management programs to fatigue risk management systems (FRMS).  Fatigue Management Plan (FMP) requirements fall somewhere in the middle of fatigue management programs and fatigue risk management systems.  They can include outlining the purpose of the FMP, definitions of roles and responsibilities, stating policies as well as listing the strategies that will be used to manage fatigue.  Scheduling practices, training and awareness programs and processes to ensure that workers are not too fatigued to be able to work safely may also be included in FMP requirements. However, and similar to FRMS, they may also be referred to externally from the FMP document.

confused by rules and regs

FMP documents are generally process oriented like FRMS documents and they are becoming increasingly under regulatory control.  Currently, and in contrast to FRMS, most regulators governing FMP’s do not allow operating outside the limits and requirements prescribed by scheduling practices and this is reflected in the FMP documentation. This means that FMP’s do not allow for a flexible and tailored use of strategies to manage fatigue according to the situation.  For example, if a situation necessitated a duty period that was only 30 minutes longer than the scheduling practices would allow, fatigue management strategies could not be invoked to allow the extra 30 minutes even if an in-depth analysis demonstrated that the longer duty period could be completed safely. In contrast to FRMS and FMP’s, fatigue management programs differ significantly due to their lack of regulatory control and may or may not include flexible approaches to managing fatigue. 

Also in contrast to FRMS, FMP requirements generally do not include any need to continuously improve safety by setting increasingly challenging key performance goals.  Although FMP requirements do generally stipulate the need to demonstrate that the FMP is functioning as designed and is maintaining fatigue risk at acceptable levels.  Fatigue management programs may or may not include continuous improvement requirements and the need to demonstrate their effectiveness. 

Fatigue Management Plan documents usually include two main sections.  One section describes the workforce’s roles and responsibilities in managing fatigue and a second section that describes all the processes that are used to manage fatigue.  The processes reduce the risks to safety that result from fatigue by:

  1. being easy to understand and follow immediately after their reading, 
  2. preventing fatigue as much as possible by reducing the risk (i.e., probability) that fatigue will manifest,
  3. preventing manifested (extant) fatigue from increasing risks to safety, and
  4. ensuring that the FMP is functioning as intended.

For an example of regulations governing FMP’s, have a look Part D of Transport Canada’s Duty and Rest Period Rules for Railway Operating Employees

Although programs, systems and plans are different in their approaches, they do demonstrate one important similarity.  Their ultimate goal is the same. It is to reduce fatigue to prevent negative safety outcomes. This is their present goal. In the future, organizations will likely expand the goal to capitalize on an ever-growing body of research demonstrating that when sleep and fatigue are better managed, organizations and workers can experience an abundance of non-safety benefits such as improved productivity and physical and mental health.