Managing Worker Fatigue Regulatory Document Helen McRobbie CSSE October 31, 2019 e-doc 5992081
Outline • Background information • Frameworks • Hours of work limits and recovery periods • Fatigue management elements • Next steps 2
Background Information
CNSC’s Mandate • Regulate use of nuclear energy and materials to protect the health , safety and security of persons and the environment • Implement Canada’s international commitments on the peaceful use of nuclear energy • Disseminate objective scientific, technical and regulatory information 4
CNSC’s Scope 5
REGDOC – Fitness for Duty: Managing Worker Fatigue 6
Inputs to REGDOC • Research – CNSC and licensees’ research reports – Peer-reviewed scientific literature • Benchmarking – International nuclear regulators – Non-nuclear sectors • Public consultation 7 7
Symptoms of Fatigue Transport Canada, TP 14573 •“Cognitive slowing” (Bratzke et al., 2007) 8
Context for Regulatory Document • Workers are a key contributor to nuclear safety – Must be able to effectively perform their duties • Fatigue can affect fitness for duty Workers are fit for duty – Fatigue degrades performance (concentration, memory, etc.) Risks related to – Identified as causal factor in several Risks related to other FFD high-profile events fatigue are factors are managed managed • Risks related to fatigue must be effectively managed • Certain aspects of work increase the likelihood of fatigue (night shifts, rotating shifts, extended shifts) 9
Basic Facts About Fatigue • Sleep fulfils a physiological need, like food and water • Sleep deprivation is a loss of sleep that can occur ‒ Acutely (extended wakefulness) or ‒ Cumulatively (some sleep loss each night over consecutive nights) • Night work poses a greater risk for fatigue due to circadian rhythms • If the body does not get enough sleep, it will take it involuntarily ‒ Involuntary drive for sleep can overcome motivation to remain awake Multiple risk factors Greatest fatigue levels 10
Frameworks
Framework for managing fatigue Captured in management system Defense 4 Defense 5 Defense 1 Defense 2 Defense 3 Fatigue is managed Fatigue-related problems are Goals Sufficient Sufficient Sufficient Sufficient Sufficient Staffing Sleep Sleep Alertness Workplace Levels Opportunity Obtained Environment Behaviour identified Control Measures -Supervisory -Sufficient -Shift -Management -Workplace & peer staffing scheduling of workers design monitoring levels for -Hours of with higher -Break -Practices volume of work limits risk of policies when risk work and and fatigue of fatigue is 24/7 recovery -Self- high coverage periods reporting Assessment and Continual Improvement Based on Lerman, S., Eskin, E., Flower, D., George, E., Gerson, B., Hartenbaum, N., Hursh S. & Moore-Ede, M. (2012). 12 Fatigue risk management in the workplace. Journal of Occupational and Environmental Medicine , 54 ( 2 ), 231-258.
Framework Supporting Limits on Hours of Work & Recovery Periods Fatigue is managed Sufficient Sufficient Sufficient Sufficient Sufficient Alertness Staffing Sleep Sleep Workplace Behaviour Levels Opportunity Obtained Environment Acute Cumulative Provide Limit average Restrict Provide sufficient weekly hours consecutive time off to time for as safeguard shifts to allow for sleep against limit build- recovery daily cumulative up of sleep from sleep fatigue debt debt 13
Conceptual Framework Supporting Hours of Work Limits and Recovery Periods in REGDOC-2.2.1 Sufficient sleep opportunity Limit average weekly Restrict consecutive Provide time off to Provide sufficient hours to allow for shifts to limit build- allow for recovery time for daily sleep recovery from residual up of sleep debt from sleep debt sleep debt 1. People sleep less on 1. After ~17 hrs awake, 1. Free days allow for 1. Longer term limits work days than on performance recovery from provide a safeguard days off declines rapidly sleep debt and against cumulative Supporting Facts fatigue-related fatigue while allowing 2. When people get 8 2. Sleep debt builds up performance short-term scheduling hrs in bed / day, when people get decrements flexibility performance less sleep than they 2. Insufficient 2. Increasing weekly remains stable require recovery time hours are related to 3 At least 11 hour free 3. Performance can result in shorter sleep durations from work is decrements performance and increased rates of required to give accumulate across decrements errors, car accidents people 8 hr sleep consecutive days of when a new shift and injuries opportunity / day restricted sleep sequence begins
Population – graded approach Do not have potential through work activities to pose risk to nuclear Excluded Workers – safety or security perform work referred to in a Analysis Potential through licence (NOTE: Applies based on work activities to Broad to workers work pose risk to directly activities nuclear safety or employed by a security licensees and to contractors and subcontractors) Safety-sensitive positions Role in the operation, where impaired performance could result in a significant incident 15
Limits on Hours of Work & Recovery Periods Fatigue Performance- Prescriptive Management based criteria HoW limits Provisions addressing HoW Broad Population Safety- sensitive positions
Relative fatigue levels of various shift sequences High Outside limits Within limits of REGDOC Low 12-hour shifts NOTE: Except for first point showing 8-hour day worker, all shifts are 12 hours 17 17
Sleep Debt • People need sleep every day Work Days • People sleep less on work days than on free days Free Days • Although sleep needs are Average individual, most sleep >7 hours/day 18
Cumulative Fatigue: Sleep Obtained by Smelter Workers (2 days, 2 nights, 4 off) (Baulk et al., 2009) 19
Sleep Debt & Restrictions on Consecutive Shifts If 12-hr shift workers get ~6 hours TIB on average (Paech et al., 2010; • Geiger-Brown et al., 2012), then expect performance declines over consecutive days (Van Dongen et al., 2003) Total sleep deprivation 4 hr TIB 24 hours of sleep 6 hr TIB deprivation 8 hr TIB 20 NOTE: Sleep obtained during the night
Daily Limits Requirements Guidance 12 hr work shift/24 hrs (normal) 16 hours work/24 hours 8 consecutive hours free 11 consecutive hrs free /24 hrs (regular) between shifts -Anything less should be rare 28 hrs work/48 hrs 21
Daily Limits Konowal et al., 1999 2008 Sleep in America Poll 22
Weekly Limits • Longer work weeks (50-60+ hours) are associated with increased risk of – Errors (Rogers et al., 2004; Cappuccio et al., 2009) – Vehicle accidents (Stutts et al., 2003) – Injuries (Dembe et al., 2005; Dong, 2005; Vegso et al., 2007) • Working at weekly limit of 60 hours is not sustainable long-term – US NRC - security personnel “ questioned their readiness and ability to perform … because of the adverse effects of cumulative fatigue ” following September 11, 2001. – “ individuals had been working up to 60 hours per week for extended periods ” (Federal Register, Vol 73, No. 62, p. 17135) – Fatigue experts cautioned European Aviation Safety Agency against allowing 3 consecutive 60-hour weeks (Moebus, 2008) 23
Programmatic Fatigue Management Elements Fatigue Performance- Prescriptive Management based criteria HoW limits Provisions addressing HoW Broad Population Safety- sensitive positions
Fatigue management elements • Establish limits on hours of work and minimum recovery periods – provide sufficient time for sleep daily – restrict consecutive shifts to limit the build-up of sleep debt – provide sufficient time off to allow for recovery from sleep debt – limit average weekly hours as a safeguard against cumulative fatigue 25
Fatigue management elements • Identify and manage worker fatigue Sufficient – temporary or ongoing circumstance(s) or Sleep condition(s) that increase risk of fatigue at Obtained work – expectations related to rest periods that include an opportunity to sleep, if permitted – self-reporting – actions for supervisors • Train and educate People are not good at evaluating how fatigue degrades their performance 26
Fatigue management elements • Identify and manage worker fatigue – Additional supervisory oversight and independent verification when the risk of fatigue is highest (e.g., during the night shift, near the end of a shift, working Sufficient Alertness beyond 12 hours) Behaviour – Scheduling safety-critical tasks outside of peak times for fatigue (especially between 2 and 6 a.m.) when possible 27
Fatigue management elements • Problem identification and resolution – Record the work schedule of workers directly involved for at least one week prior to the incident – Asking “were you tired” is not enough – Assess data periodically to determine the effectiveness of limits – Record fatigue-related factors of the workers directly involved – work schedule – sleep obtained prior to the incident compared to sleep normally obtained – consecutive hours awake at the time of the incident 28
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