WorkSafe’s Draft Fatigue in Mines: Toolkit June 2021

DR Elizabeth Gibson, General Manager of the CMPA

The following article provides extracts from WorkSafe’s draft Fatigue in Mines: Toolkit June 2021 together with requested, as per below, comments from CMPA. 

“While it is specifically for fatigue in mining and the obligations under their regulations I thought it would be appropriate to share with yourselves. We know that your members share some of these hazards, and while you aren’t subject to the same legislation I feel this may still assist with understanding and controlling these types of risk.”

The following are extracts from the draft Fatigue in mines: toolkit June 2021: the introduction together with the overview of fatigue. Note that the WorkSafe’s 2017 Fatigue in Mines was 23 pages and the proposed draft Fatigue in Mines: Toolkit June 2021 is now 37 pages long.

Introduction

Fatigue is a form of impairment that can result from physical or mental exhaustion, or inadequate or disturbed sleep.  It is a recognised health and safety risk in many industries, including the mining industry, and can limit people’s productivity at work.

By law, the operator of a mine must identify and implement control measures for all mining hazards, of which fatigue is one. This handbook contains risk management tools for identifying fatigue-related hazards, assessing and controlling for fatigue risks as well as monitoring and reviewing control measures. The risk management tools provided in this handbook build upon information provided in ‘A guide for employers, Work-related fatigue,’ (WorkSafe, 2020). 

This handbook is designed to assist mine operators and workers in the mining industry to comply with the Occupational Health and Safety Act 2004 (OHS Act) and Occupational Health and Safety Regulations 2017 (OHS Regulations). However, it is not an exhaustive guide or substitute for the detailed advice in the OHS Act or Regulations.

Whether a company has a well established risk management approach to fatigue, or is in the early stages of identifying risks, the evidence-based tools are designed to support employers and managers to consider the breadth of potential hazards along with effective strategies to reduce and prevent harm.

Overview of fatigue

Fatigue is a condition that can result following physical or mental exhaustion or inadequate or disturbed sleep. Physically and mentally demanding tasks combined with extended hours of work or work at night (particularly during the hours of 2am to 6am) can cause fatigue.

Fatigue is a form of impairment and can result in reduced performance as well as health and safety risks.

Detailed information about different types of fatigue and what causes it can be found in ‘A guide for employers, Work-related fatigue,’ (WorkSafe, 2020).

Why is fatigue a problem?

Fatigue poses both a health and safety risk to individual workers and those around them.

Health risks

Evidence suggests that shift work and fatigue can contribute to a number of health issues, including:

• Diabetes
• Digestive problems
• High blood pressure
• Heart disease
• Lowered fertility
• Drug and alcohol use
• Anxiety and depression

Recent research has found that disturbances to a natural sleep-wake cycle, known as a ‘circadian rhythm’, is associated with poor mental health and wellbeing. Increased activity during rest hours and/ or inactivity during the day, as seen in shift work, was found to be associated with a greater risk of mood disorders (such as depression and bipolar disorder; Lyall at el., 2018).

Safety risks

Fatigue is related to significant safety risks as it effects people’s ability to respond to changing circumstances and increases the likelihood of incidents due to human error.

Fatigue impairments include:

• Reduced alertness and concentration difficulties
• Reduced reaction time
• Reduced coordination
• Short term memory difficulties
• Impaired judgement and decision making
• Susceptibility to micro sleeps”

The following comments were submitted by CMPA:

General Comments

The Toolkit is not balanced:

• It does not provide any statistical information on fatigue related fatalities or serious injuries and if it were to do so it should clarify the causation of fatigue related to those incidents.  Fatigue includes so may contributing factors, so throwing them all under the one umbrella is misleading:
  – Diet and eating times/patterns;
  – Exercise and general level of fitness;
  – Drug and alcohol consumption;
  – Illness or chronic injury and the medications used;
  – Personal and family issues.

• It appears to target mines as one of the very few industries that work shifts over 24 hour cycles which is misleading and an easy way out of justifying the lack of statistical evidence.
• There is a significant emphasis on an extremely resource demanding risk management process and the related administration that quarries do not have the capacity to deal with. (Quarry Operators are likely to experience severe fatigue trying to implement this Toolkit.)
• There is a real lack of emphasis on what the employee can do to prevent or manage fatigue from a personal level.
• Once again WorkSafe is mandating a risk management process in this Toolkit where others state clearly that a formal risk assessment is unnecessary if knowledge and understanding about the risk and how to control it already exists.
  There is frequent mention of the moral obligation of the employer despite not being mentioned in the OHS Act.

Summary

• This Toolkit lacks information up front on the causes of fatigue and mostly mentions sleep issues and employers’ responsibilities.
• It does very little to address the many other causes of fatigue and employees’ responsibilities in managing such.
• The Risk Assessment process (Hazard ID section) appears to link fatigue as a potential hazard to nearly every activity in the mine.
• The Risk Assessment process (Assessment of Risk section) contains very subjective and open- ended questions. Using them to establish a risk score is often misleading and generally ends up scoring at the highest consequence level creating an over emphasis on unwarranted controls. It is incredibly difficult to assess consequence and that is why this model is flawed in these circumstances.
• The Risk Assessment process (Control of Risk section) lists many controls that simply would not be viable in a quarry environment with a small group of employees and generally working only one shift plus in some cases an afternoon shift.

Conclusion

This document is fully focused on workplace controls and does not include employee ‘moral and legal responsibility’. The employer can only manage what is within their control. They cannot manage what is not in their control such as the employee’s habits and lifestyle out of work.  

The Fatigue in mines: Toolkit is not supported for the extractive industry. 

Whilst it is acknowledged by the CMPA that fatigue is an important safety issue, any toolkit developed needs to be specific to the industry involved, practicable and proportionate to the risk.

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