PROMOTING SAFETY, HEALTH & WELLBEING USING

FATIGUE RISK MANAGEMENT SYSTEMS (FRMS)

STEVE LERMAN, MD, MPH

NIOSH WORKING HOURS, SLEEP AND FATIGUE CONFERENCE

SEPTEMBER, 2019

OVERVIEW

• Why use FRMS to manage fatigue risk?

• What are the key components of an FRMS?

• Selected topics in FRMS

• What has changed in the second edition of RP-755?

• Fatigue Risk Management Systems for Personnel in the Refining & Petrochemical Industries

JOEM Volume 54, Number 2, February 2012

• FRMS Developed using concepts of Safety Management Systems

• Pioneered in Australia by Dawson & McCulloch

• ACOEM Guidance Statement is a readily accessible overview & not industry-specific

Key Concepts• Restricting Hours of Service insufficient to manage fatigue related risk• Some factors controlled primarily by management, others by employees• Approach relevant broadly but must specifics of operations

Nuclear power plants Off-shore rigs EMTs

FRMS IS NOT EASY! BUT IT IS WORTH ITBenefits

Enhanced Process Safety

Enhanced Personnel Safety

Enhanced Health, e.g.:CardiacMetabolic

Enhanced Productivity

Enhanced Mood

Enhanced overall sense of Wellbeing

Costs

Employees need to change behavior at home, not just at work

Employees may lose OT pay or be forced to work unwanted OT

Employees may find fatigue monitoring intrusive

Employees may not like environmental changes (e.g., lighting)

Management may need to add staff (partially offset by lower OT costs)

Management may need to invest in tools, equipment and processes

Management has to address labor relations issues

FRMS must be sold

… and sold… and then, after that… sold again

5 DEFENSES IN AN FRMS

SELECTED ISSUES IN FRMS:

• Fatigue Risk Modeling

• Multiple tools exist (e.g., FAST, CAS, Fatigue Index)

• Utilize similar data

• Provide similar guidance

• Business models differ

• Differ in how data is presented but all appear to be quantitative

Assumptions about sleep & individual sensitivity make data semi-quantitative

• Most useful for comparing one work schedule to another

• Can also be used for incident investigations

SELECTED ISSUES IN FRMS: • Training

Most training is primarily knowledge transfer

This training must be motivational as well

Worker behavior on and off the job must be modified

CBT not optimal for motivation… in person training preferable

• Rest policy

Brief scheduled naps temporarily enhance alertness during long work shifts

Prolonged napping can result in sleep inertia

Work cultures often not compatible with napping

SELECTED ISSUES IN FRMS: Fitness for duty

• Many technologies available for real-time alertness assessment

Performance monitoring (e.g., lane tracking, hard braking)

Eye closure

EEG

Heart rate variability

Reaction Time

• Must know what to do with the data

• Piloted use of the PVT in clinics

Identify only chronic issues related to lack of alertness

Sleep disorders, medication/drugs, chronic illness

3 of 95 subjects identified with remediable causes of fatigue

None of them identified by standard history & physical

INCIDENT INVESTIGATIONS

• Assessing fatigue in incidents & near-misses

Can be used to determine the need for an FRMS

Critical to continuous improvement

• Role of fatigue in individual incidents may not be clear

Need to ask the right questions

Need to have fatigue as a potential contributor in mind

Should look at aggregate data

RP-755 UPDATE

Fatigue Risk Management Systems for Personnel in the Refining & Petrochemical Industries

• First edition issued in 2010 by API as an ANSI Standard

First US standard calling for use of FRMS

• Second edition issued in 2019 – Retains all components of FRMS

• Several updates to:

Enhance clarity

Simplify

Provide additional guidance based on users experience

Provide additional guidance based on newer science

KEY CHANGES TO RP-755Shoulds vs. Shalls

Activities changed from “Should perform” to “Shall perform” to clarify that performing key

components of an FRMS is not optional while retaining flexibility re how to perform components

Example: All employees shall receive initial & recurring training that should include the following …

Hours of Service Limits: Simplified, with increased flexibility and clarity

Call Outs: Second edition provides much more guidance based on user experience

Exception Approval Process: Senior site management promptly informed of higher risk exceptions

Work Environment

Guidance regarding use of lighting designed to minimize circadian disruption

• Reflects increased evidence regarding potential health effects of circadian disruption

• Recognizes that commercially available tools to address this are just now beginning to emerge

Individual Risk Assessment and Mitigation: Guidance on use of tools for fitness for duty assessment

CONCLUSIONS

• FRMS is the state of the art approach to managing fatigue risk

• It can be customized to apply to all work settings

• Effort & need for culture change on the part of management and workers is high

Don’t skimp on time/effort in selling the benefits

• Overview of FRMS structure available from multiple sources including JOEM 2012

• RP-755 2nd edition now available

Consistent with 1st edition; significant clarifications, simplifications & updated guidance