Safety and health management system elements and guidance for effective risk management of fatigue | Resources Safety & Health Queensland
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Mines safety bulletin no. 163 | 21 June 2017 | Version 1

Safety and health management system elements and guidance for effective risk management of fatigue

What happened?

Coal mines inspectorate investigations involving roster changes, contract arrangements and hours of work arrangements have highlighted some mine sites’ lack of consideration of key elements in managing fatigue risks to an acceptable level, and ineffective risk management relevant to complex health and psychosocial hazards.

Recommendations

It is strongly recommended sites review the above elements to ensure that the SHMS is managing fatigue risk to an acceptable level, and they are monitoring and reviewing the effectiveness of the systems in place. Coal mines will shortly be receiving a self-assessment survey on these elements to determine their capacity for dealing with the complex issue of fatigue risk management.

Introduction

Changes to rosters or working arrangements
When changing rosters or working arrangements, or reviewing effectiveness of current procedures, site policies and procedures (e.g. change management) within the safety and health management system (SHMS), mine sites need to identify if changes to rosters, contract arrangements, operational arrangements and hours of work arrangements will potentially change the level of fatigue risk. The benchmark here is the interaction of all fatigue risk factors and control measures identified in QGN 16 Guidance Note for Fatigue Risk Management. Some examples are shown in Table 1.

If changes to site arrangements could impact fatigue or fitness for work, the site is expected to trigger change management processes and undertake a fatigue risk assessment process complying with site senior executive obligations under the Coal Mining Safety and Health Act 1999 (CMSHA), and specific requirements under the Coal Mining Safety and Health Regulation 2001 (CMSHR), sections 10 (3) and 42. Section 10(3) requires that in developing the standard operating procedure, the site senior executive must:

  • a) use a risk assessment process recognised by the mining industry as an acceptable process for identifying and controlling hazards; and
  • b) have regard to the methods of controlling the hazard stated in the database kept by the chief executive under the CMSHA section 280(1)(a)(i).

A concern is that sites are not meeting their obligations under the CMSHA, section 30(2)(d). Section 30(2) stipulates that the systems must incorporate risk management elements and practices appropriate for each coal mine to:

a) identify, analyse, and assess risk

b) avoid or remove unacceptable risk

c) monitor levels of risk and the adverse consequences of retained residual risk

d) investigate and analyse the causes of serious accidents and high potential incidents with a view to preventing their recurrence

e) review the effectiveness of risk control measures, and take appropriate corrective and preventive action

f) mitigate the potential adverse effects arising from residual risk.

Many sites have no specific methods to identify fatigue contributing factors in investigations of serious accidents and high potential incidents.


Coroner’s inquiry into the deaths of Graham Brown, Malcolm Mackenzie and Robert Wilson
As part of fatigue risk management practices, coal mines need to consider relevant recommendations from the Coroner’s inquest into the deaths of Graham Brown, Malcolm Mackenzie and Robert Wilson, including the following:
Both the inquest findings and Queensland Guidance Note QGN16 Fatigue risk management are referenced in the Mining Hazards Database.

Recommendation 15

‘That the Mines Inspectorate investigate:

(a) the implementation of a fatigue management Recognised Standard incorporating a workable definition of fatigue including consideration of parameters for maximum number of hours in a day, a week and a shift cycle; and if so then

(b) enforcement powers be implemented either within a statutory framework or the employment contract or both to ensure compliance with the fatigue management standard on the shoulders of the employer and the employee.’

This recommendation highlights that fatigue is considered a joint responsibility, and procedures cannot only focus on worker (or contract/labour hire employee) ‘self-management’.

Recommendation 17

‘That mine operators fully explore control measures to reduce or eliminate the risks associated with workers commuting whilst fatigued.’

This highlights that Mine operators are expected to consider a range of control measures to reduce or eliminate the risks associated with workers commuting whilst fatigued, with cumulative fatigue from consecutive night shifts a particular area of concern for the commute home.

Recommendation 18

‘That the Mines Inspectorate sponsor, in conjunction with the Queensland Resources Council and the CFMEU, targeted research at both the industry and mine level into shiftwork fatigue risk management and commuting to ensure risk is at an acceptable level.’

This recommendation has resulted in published, peer reviewed research showing that fatigue risk on the roads can be affected by the distance of the journey after working night shifts, the number of consecutive night shifts worked, and hours of sleep prior to driving.

Many sites have introduced journey management plans into their commuting related fatigue risk management. Over-reliance on administrative procedures is of concern in managing the overall risk of driving more than 2 hours (or 150 km) after a series of night shifts. Sites must understand the profile or risks involved for workers driving after extended periods of night shifts, and incorporate this into the risk assessment. Recent Supreme Court decisions may be of relevance in determining the view of the courts in driving after a series of night shifts.

Fatigue risk assessments
Sites need to allow appropriate time and resources when undertaking fatigue risk assessments and reviews, and ensuring the risk assessment representation considers those operational areas most at risk of fatigue related incidents. For most sites, this will be those operational areas involving mobile equipment operation (particularly monotonous work) and rosters involving more than 4 consecutive night shifts. Many sites also miss that driving buses or transporting workers is a particular operational role that is of extremely high fatigue risk, as there is potential for multiple fatalities if the driver is affected by fatigue.

Labour hire and contractors
Based on concerns raised to the Mines Inspectorate, as well as analysis from HPI reporting, there will be a greater focus on working arrangements of labour hire and contractors with regards to fatigue. Sites should review their contract arrangements to determine there is sufficient emphasis on commute distance, breaks between and after rostered time of labour hire employees and the accommodation arrangements for contract and labour hire employees.

Authorised by Russell Albury - Chief Inspector of Coal Mines

Contact: Trudy Tilbury, Senior Principal Ergonomist , +61 7 4999 8508

Issued by Queensland Department of Natural Resources and Mines

Placement: Place this announcement on noticeboards and ensure all relevant people in your organisation receive a copy.

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Acknowledgement of Country

RSHQ respectfully acknowledges all Aboriginal peoples and Torres Strait Islander peoples and the Traditional Owners and Custodians of the country on which we live and work. We acknowledge their continuing connection to land, waters and culture and commit to ongoing reconciliation. We pay our respect to their Elders past and present.

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