Back to Basics, Personnel Safety

Back to Basics: Creating a Fatigue Risk Management System

Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine how to create a fatigue risk management system.

fatigue risk management system

Worker fatigue is a serious problem that can lead to dangerous work conditions, lower productivity, injuries, and even death.

According to OSHA, employers can reduce the risk of worker fatigue in the workplace by:

  • Examining staffing issues such as workload, work hours, understaffing and worker absences
  • Arranging schedules to allow frequent opportunities for rest breaks and nighttime sleep
  • Adjusting lighting, temperature, and physical surroundings of the work environment to increase alertness
  • Providing worker training and education on the hazards and symptoms of worker fatigue, the need for adequate sleep, and the importance of diet, exercise, and stress management
  • Consider implementing a fatigue risk management system (FRMS) to help you manage fatigue

The American College of Occupational and Environmental Medicine (ACOEM) in 2012 published a guidance statement detailing the importance of managing fatigue risk in the workplace. The statement discussed how to establish an FRMS, which may include:

  • A fatigue management policy
  • Fatigue risk management, including collecting information about fatigue as a hazard, analyzing its risk, and putting controls in place to mitigate the risk
  • A fatigue reporting system for employees
  • Fatigue incident investigation
  • Fatigue management training and education for employees, management, and families
  • Sleep disorder management
  • A process for internal and external auditing of the FRMS that delivers corrective actions through a continuous improvement process

Setting up an FRMS

The size of the FRMS will vary depending on the size and complexity of the business. At a small company, it could be one person in the safety department with these responsibilities; at larger companies, there could be a steering committee with representatives of various groups including personnel, work scheduling, manpower, safety, union or employee representatives, training, or any other group involved with work scheduling and fatigue.

According to the ACOEM guidance, there are five levels of defense against errors from fatigue:

  1. Workload-staffing balance
  2. Shift scheduling
  3. Employee fatigue training and sleep disorder management
  4. Workplace environment design
  5. Fatigue monitoring and alertness for duty

A major root cause of worker fatigue is an imbalance between workload and staffing levels. Staffing levels play the largest role in determining the average amount of overtime per employee, average time between shifts, average time off between consecutive blocks of shifts, average shift length, average work hours per week, average number of consecutive days worked, and discrepancy between the published shift schedule and the actual schedule worked.

If the staffing level is lower than it should be, the employees have to work additional hours or extra shifts. Understaffing can impact both acute and chronic fatigue levels, but employees may volunteer for overtime to make more money. Some employees may become over-fatigued and over-stressed and miss work, which puts more pressure on the remaining employees to work overtime.

The FRMS would then analyze workload-staffing imbalances to determine the necessary staffing level and how to address it. This may involve reexamining and reengineering processes to reduce the number of employee positions; cross-training employees to fill positions to increase the available staff; and examining the fluctuations in workload and how to properly staff for them. And of course, if necessary, the decision may be made to hire more employees.

Recognizing fatigue

Fatigue risk management training can help employees make lifestyle changes and avoid some of these problems. Among the principles to explain are the hazards of working while fatigued, how to get adequate sleep, how to recognize sleep disorders, how to recognize fatigue, and alertness strategies.

Supervisors should be trained on how to recognize signs of excessive fatigue, which include:

  • Physical signs (e.g., yawning, drooping eyelids, rubbing of eyes, head dropping, microsleeps, digestive problems)
  • Mental signs (e.g., difficulty concentrating on tasks, lapses in attention, difficulty remembering tasks being performed, failing to communicate important information, failing to anticipate events or actions, accidentally doing the wrong thing)
  • Emotional signs (e.g., quieter or withdrawn than usual, lack of energy, lack of motivation to perform tasks well)

Strategies to mitigate fatigue include:

  • Taking a break
  • Shifting safety-sensitive activities to others who are more alert or to another time
  • Using a buddy approach to increase social interaction and help monitor alertness
  • Moderate use of caffeine
  • Enhancing environmental factors such as lighting and music


The FRMS should demonstrate its effectiveness by collecting supporting data such as attendance, safety, and health metrics. These can include the following:

  • Time and attendance data including absenteeism, hours worked, and overtime
  • Validated survey instruments such as the Work Limitations Questionnaire to assess productivity
  • The OSHA recordable work-related injury and illness data collection
  • Workers’ compensation injury and illness incidence, severity, and costs
  • Root cause analysis during incident investigation of an accident or injury to identify whether fatigue was a contributing factor
  • Employee health status may be tracked through health risk assessments, healthcare insurance utilization data, healthcare cost data, and employee surveys or questionnaires
  • Employee fatigue or sleepiness at work may be measured by assessment tools such as the Health and Safety Executive’s Fatigue and Risk Index Tool or the Epworth Sleepiness Scale

Leave a Reply

Your email address will not be published.

This site uses Akismet to reduce spam. Learn how your comment data is processed.