mine safety code of practiveThe employer of a mine has the responsibility to prepare a risk based code of practice (COP) on Fatigue Management (Section 9(2) of the MHSA). Fatigue is more than simply feeling tired or drowsy. It can be caused by prolonged physical or mental exertion without enough time to rest. Or by spending long periods of time awake with inadequate sleep. It undoubtedly affects an individual’s capacity to function. This leads to decreased performance and productivity, and the increased potential for injuries to occur.

Aspects to be addressed in the COP

Section 11 of the MHSA requires the employer to identify hazards and assess the health and safety risks to which employees may be exposed while they are at work. The COP must set out how these risks will be addressed.

Factors to be considered when addressing fatigue at mines

Fatigue is most appropriately conceptualized as either work related or non-work related.

Work related factors that contribute to fatigue includes work time arrangements, high physical workloads, temperature extremes, excessive noise, work stress, and poor ergonomic design of workstations and equipment.

Non-work related fatigue could be triggered by undiagnosed diseases and disorders, living conditions, alcohol and substance abuse, and lack of exercise. The fatigue experienced by an individual is usually an accumulation of several of the above factors.

Development of a fatigue management plan

The goal of a fatigue management plan is to maintain and, where possible, enhance safety, performance and productivity in operational settings, and manage the risk of fatigue in the workplace. In order for a Fatigue Management Programme (FMP) to be effective, senior management must provide visible support, endorsement, and allocate sufficient resources to establish, sustain, monitor and optimize the FMP.

STEP 1: Hazard identification

There are many ways of identifying workplace factors that contribute to fatigue:

  1. Inspecting workplace rosters;
  2. Consulting with workers;
  3. Consulting with workplace health and safety representatives and committees;
  4. Conducting a health and safety audit;
  5. Analysing injury and incident reports (particularly within periods of high fatigue).

The Guideline for the Compilation of a Mandatory Code of Practice for Risk-Based Fatigue Management at Mines (Government Gazette 19 December 2014) provides annexures that offer guideline-templates to assist in identifying hazards of fatigue in the following areas.

  1. Shift systems and rostering;
  2. Ergonomics, environmental and work factors;
  3. Personal factors;
  4. Fatigue risk worksheets;
  5. Review accident or incident reports;

STEP 2: Risk assessment

Managing fatigue involves assessing and rating the risks associated with the workplace factors that contribute to fatigue. Site-specific information and evidence of fatigue-related incidents could be used to assist in the risk assessment process.

For each of the risks, bearing in mind the existing control measures:

  1. Determine the likelihood of an incident occurring at the workplace;
  2. Determine the consequences of an incident occurring at the work place;
  3. Combine the estimates of the likelihood and consequences to rate the risk.

STEP 3: Risk Control

Control mechanisms should be put in place to manage the identified factors that contribute to fatigue. The controls should address the sources of fatigue in the workplace and take into account the factors identified in the personal environment. Control measures should be introduced using the hierarchy of controls. According to the hierarchy of controls, the ideal solution when managing fatigue is to completely eliminate factors that contribute to fatigue.

STEP 4: Evaluation

The FMP should be reviewed at regular intervals to ensure that all relevant hazards are included and to assess the effectiveness of the controls.

  1. Have the control measures been implemented as planned?
  2. Are there any new operational processes that have been introduced?
  3. Review available fitness, health, EAP and absenteeism data;
  4. Review incident data.

STEP 5: Documentation

The final step in the fatigue management process is to develop and document a plan detailing how control measures will be implemented. The FMP should be integrated as part of an overall occupational health and safety programme.

Communicating the FMP

An appropriate information, education and awareness programme should be put in place to create awareness and educate all employees on the impact of fatigue in the workplace, their role in managing the risks, and the controls in the workplace. Careful, but vigorous, communication is critical when ‘rolling out’ the FMP. It has to be communicated to the entire workforce with open lines of communication between all stakeholders. Ideally the communication framework should also provide and encourage opportunities for family members to be included in the information exchange as this could stimulate the employees’ willingness to focus attention on the important issue of fatigue.

Monitoring, reviewing and modifying

Finally, the FMP should be subject to periodic assessments (minimum at least every two years) to ensure that it remains appropriate and effective, and can address existing and emerging or changed fatigue risks.

Underground Mine Safety