Regulation 3 of the Management of Health and Safety at Work Regulations 1999 (MHSWR) states every employer shall make a suitable and sufficient assessment of the risks to the health and safety of his employees to which they are exposed whilst they are at work. 

Fatigue is all too often forgotten about as a significant risk and this needs to change.  PFEW is asking all forces to consider how they could implement Generic Fatigue Risk Assessments and will work with them to ensure our members are protected.   We will also be pushing them to be dynamic and utilise these Generic Assessment to support officers by opening conversations around fatigue and creating Personal Risk Assessment where appropriate. 

When considering how to implement these Risk Assessment we would remind forces the MHSWR states where an employer implements any preventive and protective measures they shall do so on the basis of the principles of prevention:

(a) avoiding risks;

(b) evaluating the risks which cannot be avoided;

(c) combating the risks at source;

(d) adapting the work to the individual, especially as regards the design of workplaces, the choice of work equipment and the choice of working and production methods, with a view, in particular, to alleviating monotonous work and work at a predetermined work-rate and to reducing their effect on health;

(e) adapting to technical progress;

(f) replacing the dangerous by the non-dangerous or the less dangerous;

(g) developing a coherent overall prevention policy which covers technology, organisation of work, working conditions, social relationships and the influence of factors relating to the working environment;

(h) giving collective protective measures priority over individual protective measures; and

giving appropriate instructions to employees.

HSE 5 Step Risk Assessment

Police officers and managers are well practised at considering risk and ensuring the appropriate control measures are in place to reduce it to an acceptable level. 

As fatigue presents a significant risk to the health, safety and welfare of officers it is suggested the guidance provided by the HSE is followed when considering how to approach this particular problem.  The HSE adhere to a five step process for Risk Assessment which is detailed in the following link, Managing risks and risk assessment at work – Overview –HSE, and shown below:

Hazards 

Knowing the signs and symptoms of fatigue is essential if we are to support officers and reduce risk.  However, there are some particular indicators which if identified early can allow for effective control measures before fatigue becomes an issue. 

The following is not an exhaustive list:

When considering hazard there is no getting away from the biggest of all, that being the human factor.  The following HSE guidance raises awareness of this issue:  hsg48.pdf (hse.gov.uk)

Evaluating Risk 

After identifying any hazards and who might be affected, it is important to evaluate the severity the risk may present (should it occur) and establish suitable and effective controls to reduce this level of risk as far as is ‘reasonably practicable’.  This means that everything possible is done to ensure health and safety considering all relevant factors including:

• Likelihood that harm may occur
• Severity of harm that may occur
• Knowledge about eliminating, reducing or controlling hazards and risks
• Availability of control measures designed to eliminate, reduce or suitably control or the risk
• Costs associated with available control measures designed to eliminate, reduce or suitably control or the risk

Assessing the severity of a risk requires an evaluation of the likelihood of an occurrence and how substantial the consequences that it may cause. Some factors affecting this evaluation include the duration and frequency of exposure, number of persons affected, competence of those exposed, the type of equipment and its condition, and availability of first-aid provision and/or emergency support.

Control Measures 

A certain amount of fatigue may be acceptable provided the risks are adequately managed. Adopting a hierarchy of risk control measures allows organisations to effectively manage the level of risk associated with fatigue, so far as is reasonably practicable.  Some control measures which could be considered are shown in the table below:

Symptom Checklist 

If a symptom of fatigue is observed in another person, it should be brought to that person’s attention.

As a guideline, if an officer experiences more than three of the specified symptoms in a 15-minute period they are likely to be fatigued and should be considered to be at an elevated level of fatigue-related risk. Appropriate fatigue control measures need to be considered.

Officers that repeatedly exhibit fatigue-related symptoms may require additional support via force Occupational Health Services.  

Implement changes and record your findings 

In general when considering a Risk Assessment you consider all who will be affected by the action or activity.  If a workplace has five or more individuals, significate findings of the risk assessments are required to be kept either electronically or in writing.

Recording your findings on a risk assessment form is an easy way to keep track of the risks and control measures put in place to reduce the identified risk. The form includes:

• What hazards were found
• Person(s) or groups affected
• The controls put in place to manage risks and who is monitoring them
• Who carried out the assessment
• On what date the assessment was done.

Ongoing review and improvement

Nothing stays the same for ever. By talking to officers and monitoring incident rates and control measures, you will be able to judge whether your control measures are effective. Managers in partnership with officers must be given responsibility to oversee the process and develop reporting procedures, discussing and helping to implement solutions, as well as monitoring the solutions for effectiveness.

A risk assessment should be reviewed regularly to ensure that the risk of being harmed by fatigue has not changed and that no further control measures are needed.  There is no legal time frame for when a review should take place. It is at the discretion of the manager to decide when a review is deemed necessary, but the risk assessment is a working document and, as experiences change, this information should be recorded and updated. As a guide, it is recommended that risk assessments be reviewed on an annual basis.

Look at your risk assessment again:

• Have there been any changes?
• Are there improvements you still need to make?
• Have your workers spotted a problem?
• Have you learnt anything from accidents or near misses? 

Helpful examples of how fatigue is managed:

• Fatigue Risk Management for First Responders
• Emergency_services_guideline_for_risk_managing_fatigue.pdf (safework.sa.gov.au)
• Fatigue Risk Management Systems: A Review of the Literature (clockworkresearch.com)
• Fatigue Risk Management System for the Canadian Aviation Industry
• Managing Fatigue Using a Fatigue Risk Management Plan (FRMP)