DEVELOPING A FATIGUE MANAGEMENT PLAN FOR COMMERCIAL VEHICLE DRIVERS AND OPERATORS - PDF

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DEVELOPING A FATIGUE MANAGEMENT PLAN FOR COMMERCIAL VEHICLE DRIVERS AND OPERATORS Developing a Fatigue Management Plan for Commercial Vehicle Drivers and Operators 2 / 20 INTRODUCTION... 4 COMMERCIAL VEHICLE
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DEVELOPING A FATIGUE MANAGEMENT PLAN FOR COMMERCIAL VEHICLE DRIVERS AND OPERATORS Developing a Fatigue Management Plan for Commercial Vehicle Drivers and Operators 2 / 20 INTRODUCTION... 4 COMMERCIAL VEHICLE DRIVER FATIGUE IS A MAJOR SAFETY PROBLEM... 4 A DRIVER FATIGUE MANAGEMENT PLAN WILL HELP EMPLOYERS MEET THEIR DUTY OF CARE... 4 OPERATING STANDARDS FOR WORK AND REST... 5 THE OPERATING STANDARDS IN THE REGULATIONS ARE USED TO ESTABLISH A SAFE SYSTEM OF WORK... 5 OPERATING STANDARDS FOR WORK AND REST IN ROAD TRANSPORT... 5 DRIVING WITHOUT A RELIEF DRIVER... 5 DRIVING WITH A RELIEF DRIVER... 5 A DRIVER FATIGUE MANAGEMENT PLAN... 6 MANAGING COMMERCIAL VEHICLE DRIVER FATIGUE REQUIRES EFFECTIVE POLICIES & PROCEDURES... 6 BASIC PRINCIPLES TO INCLUDE IN A DRIVER FATIGUE MANAGEMENT PLAN... 6 DEVELOPING A DRIVER FATIGUE MANAGEMENT PLAN... 8 STEPS TO DEVELOP A DFMP... 8 IT IS IMPORTANT THAT YOU HAVE A WRITTEN DFMP... 8 SCHEDULING... 8 ROSTERING OF COMMERCIAL VEHICLE DRIVERS... 9 FACTORS TO BE TAKEN INTO ACCOUNT... 9 CONTROL MEASURES WHAT IF MY OPERATIONS DO NOT CONFORM TO THE REGULATIONS? COMMERCIAL VEHICLE DRIVER WELL-BEING READINESS FOR DUTY COMMERCIAL VEHICLE DRIVER HEALTH AND FITNESS WORKPLACE CONDITIONS TRAINING TRAINING IS CRITICAL INDUCTION, REFRESHER AND FURTHER TRAINING ARE ALL NECESSARY FORM & CONTENT OF TRAINING OPERATOR SUED FOR PUSHING COMMERCIAL VEHICLE DRIVER ADMINISTRATION RESPONSIBILITIES DOCUMENTATION MANAGING INCIDENTS REVIEWING THE DRIVER FATIGUE MANAGEMENT PLAN AUDIT & REVIEW THE DFMP TO ENSURE IT IS ADEQUATE... 17 Developing a Fatigue Management Plan for Commercial Vehicle Drivers and Operators 3 / 20 Developing a driver fatigue management plan for commercial vehicle drivers and operators in Western Australia A transport industry training resource originally developed by Lance Poore (Department for Planning and Infrastructure) and Laurence Hartley (Institute for Research in Safety & Transport, Murdoch University). After reading this training information and completing the accompanying self-assessment questions on the SafetyLine website, you should be able to: explain the basic principles of managing fatigue contained in division 10 of the Occupational Safety and Health Regulations and the draft Code of Practice for Fatigue Management for Commercial Vehicle Drivers; state the principles used in planning a company Driver Fatigue Management Plan (DFMP); explain the importance that commercial vehicle driver well-being has on work performance and fatigue; and explain the importance of knowing the correct procedures and the importance of training and dealing with critical incidents. Developing a Fatigue Management Plan for Commercial Vehicle Drivers and Operators 4 / 20 Introduction Commercial vehicle driver fatigue is a major safety problem The concept of Due Diligence has meant that operators must take every precaution reasonable in the circumstances to protect the safety and health of their workers, customers and the general public. In turn the need for better standards of safety and health has been matched by an increasing requirement for documentation of commercial vehicle driver operations and activities. Commercial vehicle driver fatigue has long been recognised as a major safety problem in all forms of transport. In other states of Australia, restrictions on hours of work and on-road enforcement using logbooks have traditionally been used to address this issue. In Western Australia we have not gone down this path to control fatigue. Instead Western Australia uses the Occupational Safety and Health Act 1984 and the Occupational Safety and Health Regulations 1996 to require employers and employees to work together to achieve a safer road transport industry. A driver fatigue management plan will help employers meet their duty of care The WorkSafe division of the Department of Consumer and Employment Protection, the Department for Planning and Infrastructure, and employer and employee representatives from the transport industry have collaborated to produce amendments to the Occupational Safety and Health Regulations and have developed a draft Code of Practice for Fatigue Management for Commercial Vehicle Drivers which sets standards for safe operations in road transport. Those standards are summarized in this training resource which explains the background to the development of a Driver Fatigue Management Plan (DFMP), and aims to provide some help and advice for operators who wish to develop a DFMP or who may wish to revise or update their existing system. So we ll look at the following issues: the basic principles for fatigue management contained in the OSH regulations and the draft code of practice; the steps in producing a company Driver Fatigue Management Plan; commercial vehicle driver well-being an important consideration; administrative tasks necessary to ensure that policies, procedures and contingency actions are performed as required by the regulations; and policies necessary for dealing with critical incidents and for the provision of training. Developing a Fatigue Management Plan for Commercial Vehicle Drivers and Operators 5 / 20 Operating standards for work and rest The operating standards in the regulations are used to establish a safe system of work The operating standards included in the regulations provide a guide to industry on how to plan trip schedules and rosters for commercial vehicle drivers that best manage fatigue. The standards emphasise the importance of sleep and the timing of work and rest. The operating standards offer flexibility in hours of work to reflect the geography of WA and the distances between towns. The operating standards, as set out in the regulations, provide guidance to the authorities and the courts as well as providing guidance to operators. The WorkSafe division of the Department of Consumer and Employment Protection and the Department of Planning and Infrastructure use those standards when investigating an incident involving commercial vehicle driver fatigue or checking whether a safe system of work is in place. Operating standards for work and rest in road transport Transport operations must, as far as practicable, be conducted within the operating standards described below. The 24-hour cycle starts at the commencement of work following a long break of 7 hours or more. Operating standards for hours of work and rest Driving without a relief driver (Solo commercial vehicle driver) Minimum continuous non work time in any 24 hours Minimum non work time in any 72 hour period Maximum time between major rest breaks (7 hours or longer) Minimum 24 hour continuous periods of time not working in any 14 days Minimum 24 hours continuous periods of time not working in any 28 days Driving with a relief driver (two-up driving) for each driver Minimum non work time in a 24 hour period Minimum continuous non work time in any 48 hours (must be in a stationary vehicle or away from the vehicle) OR Minimum continuous non-work time in any 7 day period (must be in a stationary vehicle or away from the vehicle) All commercial vehicle drivers Maximum continuous work time (driving and non-driving work time) Minimum break from driving for each 5 hours of work Minimum break from driving to be taken after 5 hours work Maximum work time in any 14 days (unless working to 28 day roster, then it is reduced to 144 hours) 7 hours 27 hours 17 hours 2 periods 4 periods 7 hours 7 hours 48 hours 5 hours 20 minutes 10 minutes 168 hours Developing a Fatigue Management Plan for Commercial Vehicle Drivers and Operators 6 / 20 A driver fatigue management plan Managing commercial vehicle driver fatigue requires effective policies & procedures A Driver Fatigue Management Plan (DFMP), as described in the regulations, is a written document that sets out the requirements and procedures relating to how a company will schedule trips; roster drivers; establish a driver s fitness to work; educate drivers in fatigue management; manage incidents on or relating to commercial vehicles; and establish and maintain appropriate workplace conditions. This is not as difficult as you might think. Every company that operates commercial vehicles needs a DFMP, and it should be part of your company s risk management systems. Every company has some risk management systems, even if they are not written down. Preventative truck maintenance is a risk management system, as are commercial vehicle driver rosters. The most effective way to reduce the risks associated with driver fatigue is by planned long-term measures. Rostering and scheduling practices are essential long-term measures, which are supported by short-term practices such as power naps and short breaks. Managing commercial vehicle driver fatigue requires effective management practices and office procedures including: maintaining open lines of communication between management and commercial vehicle drivers; encouraging feedback from commercial vehicle drivers; ensuring that the DFMP is included in commercial vehicle driver induction programs and in other Human Resource procedures and practices; and appropriate documentation and record keeping practices. Documentation of policies and procedures associated with the driver fatigue management plan provides practical evidence that a system is in place and is actively working to manage commercial vehicle driver fatigue. It also allows the effectiveness of the system to be measured. Documentation should be well managed and include numbered and dated systems in place for updating information. Record keeping is also important. Records provide the detail that the program is working and standards are being met. Records are an essential part of an overall risk management program as they provide a history of a particular commercial vehicle driver or management activity. This information may be of vital importance in any legal action. Records must be kept for a minimum of three years. You will need a written driver fatigue management plan. The Occupational Health and Safety Act 1984 requires employers to provide their employees with a safe system of work. A driver fatigue management plan is evidence that you have a safe system of work in place, and WorkSafe inspectors may ask to see it when visiting your workplace or when conducting an investigation into a serious accident or incident. Basic principles to include in a driver fatigue management plan A number of basic principles apply when developing a Driver Fatigue Management Plan. The following are detailed in the draft code of practice and should be considered as the basis for most systems. Give a commercial vehicle driver at least 24 hours notice to prepare for working time of 14 hours or more. A schedule must permit a solo commercial vehicle driver to have the opportunity for at least 7 continuous hours of rest in any 24-hour period, preferably between 10pm and 8am. Minimise irregular or unfamiliar work rosters. Developing a Fatigue Management Plan for Commercial Vehicle Drivers and Operators 7 / 20 Operate flexible schedules to allow for sufficient breaks from driving or discretionary sleep. Minimise very early departures to give commercial vehicle drivers the maximum opportunity to sleep in preparation for the trip. When commercial vehicle drivers return from leave, minimize night-time schedules and rosters to give drivers time to adapt to working long hours especially at night. Require a commercial vehicle driver to present and remain in a fit state for duty including not being impaired by alcohol or drug use. Develop a written policy on fitness for duty in consultation with employees and unions. Provide an appropriate truck sleeper berth if commercial vehicle drivers will be required to sleep in the vehicle. Require regular assessment of a commercial vehicle driver s health by a suitably qualified medical practitioner (to the National Road Transport Commission or Federal office of Road Safety standard). Ensure that the medical assessment includes consideration of sleep disorders and other fatigue related conditions. Identify health problems that affect the ability to work safely, e.g. diabetes, heart disease, sleep apnoea. Provide appropriate employee assistance programs where necessary and practicable. Provide commercial vehicle drivers with information and assistance to promote management of their health. Provide a working environment that meets appropriate Australian standards for seating and sleeping accommodation. When commercial vehicle drivers work a continuous rotating shift system of 5 days or more there must be 24 hours of non-working time between shift changes. Developing a Fatigue Management Plan for Commercial Vehicle Drivers and Operators 8 / 20 Developing a driver fatigue management plan Steps to develop a DFMP You might like to consider the following ten-step approach to establishing a driver fatigue management plan in your business. 1. Obtain commitment from management. 2. Obtain management and employee agreement to cooperate. 3. Provide fatigue awareness training throughout the company. 4. Involve employees' families. 5. Incorporate the program in the overall safety and health culture of the company. 6. Establish non-punitive medical screening for health fitness and sleep disorders. 7. Devote attention to commercial vehicle driver scheduling; including provision for adequate rest. 8. Inform clients and enlist their cooperation. 9. Establish a trial period 10. Establish and collect measures of effectiveness; evaluate. It is important that you have a written DFMP At the end of this paper there is a checklist you can use to ensure that your driver fatigue management plan is adequate. You can use this for preparing your driver fatigue management plan documentation. All you need do is check the boxes in the list to show you comply with the Standards laid out there. Of course you must be honest! You may be asked by WorkSafe, to produce your driver fatigue management plan one-day, especially if you have a commercial vehicle that is involved in a serious incident or accident. During their investigation, WorkSafe may need to examine supporting documents that show that your commercial vehicle drivers have had at least 27 hours of rest in any 72 hours, and have worked no more than 168 hours in a fortnight, if they are working to a 14 day roster, and no more than 144 hours in any 14 day period if they are working to a 28 day roster. It is mandatory for the commercial vehicle operator (the Company) to retain trip records for your commercial vehicle drivers for 3 years. Scheduling A key factor in managing commercial vehicle driver fatigue is how a company schedules or plans individual trips to meet a freight task. Where practicable and reasonable, scheduling practices should include appropriate pre-trip or forward planning to minimise fatigue. A commercial vehicle driver should not be required to drive unreasonable distances in insufficient time and without sufficient notice and provision for adequate rest. Scheduling practices should not put the delivery of a load before a commercial vehicle driver s safety or health. If your scheduling practices are inadequate the rest of your system is meaningless. The main risk factor for fatigue crashes is inadequate sleep for one or more nights. Company procedures should recognize that at least 6 hours of sleep is required each night to minimize fatigue. A minimum of 7 continuous hours break must be planned for, to ensure a commercial vehicle driver has the opportunity for at least 6 hours of actual sleep. This is an absolute minimum and may still lead to increased levels of fatigue over a number of days. Schedules should be developed that provide this or greater opportunities for sleep. Developing a Fatigue Management Plan for Commercial Vehicle Drivers and Operators 9 / 20 The second main risk factor for fatigue crashes is working when the commercial vehicle driver would normally be asleep. People who work at night have trouble adjusting their body clocks. No matter how much sleep a person has beforehand, they will still feel sleepy between 1.00am and 6.00am. Company procedures should recognize that driving during this period puts employees and other road users at risk. There should be written procedures that demonstrate that schedules are developed with this risk in mind, and that where possible there is the opportunity to sleep during this period. Simply being on the road at 3 am does not mean there will be a crash, but it does mean a greater awareness of the risks is required. Rostering of commercial vehicle drivers Rosters are the commercial vehicle drivers planned pattern of work and rest for a week or more. A commercial vehicle drivers roster and workload should be arranged to maximize the opportunity for them to recover from the effects or onset of fatigue. Rostering practices must as far as practicable, be in accordance with the OSH regulations. Night shift work and rotating or irregular shift patterns are risk factors for fatigue crashes. Company procedures should document how these risk factors are addressed. They should outline how night work is minimised and if it cannot be eliminated, how the company manages fatigue related to night work and documents its approach. Factors to be taken into account To comply with the operating standards, scheduling and rostering must ensure that: A commercial vehicle driver is given at least 24 hours notice to prepare for working time of 14 hours or more. A commercial vehicle driver is not permitted to exceed 168 hours of working time in any 14 day period,. Total non-working time in any 72 hours is at least 27 hours. A solo commercial vehicle driver has least one continuous 7-hour period of non-work time in any 24-hour period and preferably between 10pm and 8am. Continuous periods of work time do not exceed 5 hours before a break of at least 10 minutes is taken. A schedule must allow for an average of 20 minutes breaks from driving for each 5 hours of work time for a commercial vehicle driver, and a minimum break from driving of at least 10 consecutive minutes at the end of 5 hours work time. Maximise the opportunity for sleep and to prepare for a trip by minimizing very early departures. A commercial vehicle driver has at least two continuous period of 24 hours non-work time in 14 days. Minimise irregular or unfamiliar work rosters. Minimise schedules and rosters that depart from daytime operations when commercial vehicle drivers return from leave: commercial vehicle drivers returning from leave require time to adapt to working long hours especially at night. Ensure 24 continuous hours of non-work time between shift changes when commercial vehicle drivers work a continuous rotating shift system of 5 days or more. Time doing work that is incidental to the driving, such as servicing and maintaining the vehicle Developing a Fatigue Management Plan for Commercial Vehicle Drivers and Operators 10 / 20 or operating mobile plant is counted as work time and needs to be taken into account when planning trips. Control measures To ensure compliance with the operating standards the following practices should be adopted when a commercial vehicle driver is likely to work more than 14 hours in consecutive 24-hour periods. Replace commercial vehicle driver with a fresh relief driver, where practicable. Reduce the period of work time in the next 24-hour period to ensure that at least 27 hours of non work time is available in any 72 hour period, to recover from the effects of any accumulated sleep debt. Set schedule so commercial vehicle driver can rest when and where most appropriate. Use shared driving, driving with a relief driver (two-up driving). Split trip into shorter continuous driving periods. Schedule rest to precede or coincide with high fatigue risk times, e.g. night and dawn. Change customer pick-up or delivery times where possible. Allow for a day of non-work time after a trip. Re
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