Managing Worker Fatigue Regulatory Document
e-doc 5992081
CSSE October 31, 2019
Managing Worker Fatigue Regulatory Document Helen McRobbie CSSE - - PowerPoint PPT Presentation
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
e-doc 5992081
CSSE October 31, 2019
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– CNSC and licensees’ research reports – Peer-reviewed scientific literature
– International nuclear regulators – Non-nuclear sectors
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Transport Canada, TP 14573
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– Must be able to effectively perform their duties
– Fatigue degrades performance (concentration, memory, etc.) – Identified as causal factor in several high-profile events
effectively managed
fatigue (night shifts, rotating shifts, extended shifts)
Workers are fit for duty
Risks related to fatigue are managed Risks related to
factors are managed
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‒ Acutely (extended wakefulness) or ‒ Cumulatively (some sleep loss each night over consecutive nights)
circadian rhythms
involuntarily
‒ Involuntary drive for sleep can overcome motivation to remain awake
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Fatigue is managed
Sufficient Workplace Environment
Assessment and Continual Improvement
Sufficient Staffing Levels Sufficient Sleep Opportunity Sufficient Sleep Obtained Sufficient Alertness Behaviour
Goals
staffing levels for volume of work and 24/7 coverage
scheduling
work limits and recovery periods
with higher risk of fatigue
reporting
design
policies
& peer monitoring
when risk
high
Control Measures
Fatigue-related problems are identified
Defense 1 Defense 2 Defense 3 Defense 4 Defense 5
Captured in management system
Based on Lerman, S., Eskin, E., Flower, D., George, E., Gerson, B., Hartenbaum, N., Hursh S. & Moore-Ede, M. (2012). Fatigue risk management in the workplace. Journal of Occupational and Environmental Medicine, 54(2), 231-258.
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Fatigue is managed
Sufficient Workplace Environment Sufficient Staffing Levels Sufficient Sleep Opportunity Sufficient Sleep Obtained Sufficient Alertness Behaviour Provide sufficient time for sleep daily Restrict consecutive shifts to limit build- up of sleep debt Provide time off to allow for recovery from sleep debt Limit average weekly hours as safeguard against cumulative fatigue
Acute Cumulative
performance declines rapidly
work days than on days off
recovery from sleep debt and fatigue-related performance decrements
provide a safeguard against cumulative fatigue while allowing short-term scheduling flexibility Supporting Facts Sufficient sleep
Provide sufficient time for daily sleep Restrict consecutive shifts to limit build- up of sleep debt Provide time off to allow for recovery from sleep debt
Limit average weekly hours to allow for recovery from residual sleep debt
3 At least 11 hour free from work is required to give people 8 hr sleep
hrs in bed / day, performance remains stable
decrements accumulate across consecutive days of restricted sleep
when people get less sleep than they require
recovery time can result in performance decrements when a new shift sequence begins
hours are related to shorter sleep durations and increased rates of errors, car accidents and injuries
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perform work referred to in a licence
(NOTE: Applies to workers directly employed by a licensees and to contractors and subcontractors)
Analysis based on work activities Excluded Broad Safety-sensitive positions Potential through work activities to pose risk to nuclear safety or security Do not have potential through work activities to pose risk to nuclear safety or security Role in the operation, where impaired performance could result in a significant incident
Fatigue Management Provisions Performance- based criteria addressing HoW Prescriptive HoW limits
Broad Population Safety- sensitive positions
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17 Low
NOTE: Except for first point showing 8-hour day worker, all shifts are 12 hours
High
12-hour shifts Outside limits Within limits of REGDOC
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Work Days Free Days Average
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(Baulk et al., 2009)
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4 hr TIB 6 hr TIB 8 hr TIB Total sleep deprivation
24 hours of sleep deprivation NOTE: Sleep obtained during the night
Geiger-Brown et al., 2012), then expect performance declines over consecutive days (Van Dongen et al., 2003)
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Requirements Guidance 16 hours work/24 hours 12 hr work shift/24 hrs (normal) 8 consecutive hours free between shifts 11 consecutive hrs free /24 hrs (regular)
28 hrs work/48 hrs
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Konowal et al., 1999
2008 Sleep in America Poll
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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)
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)
Fatigue Management Provisions Performance- based criteria addressing HoW Prescriptive HoW limits
Broad Population Safety- sensitive positions
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– 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
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– temporary or ongoing circumstance(s) or condition(s) that increase risk of fatigue at work – expectations related to rest periods that include an opportunity to sleep, if permitted – self-reporting – actions for supervisors
Sufficient Sleep Obtained
People are not good at evaluating how fatigue degrades their performance
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– 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 beyond 12 hours) – Scheduling safety-critical tasks outside of peak times for fatigue (especially between 2 and 6 a.m.) when possible
Sufficient Alertness Behaviour
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– 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
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– Periodic assessments
– verify that staffing levels are sufficient for enabling adherence to limits on hours of work and recovery periods Sufficient Staffing Levels
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Consensus Conference Panel, Watson, N., Badr, M., Belenky, G., Bliwise, D., Buxton, O., Buysse, D. et al. (2015). Joint Consensus Statement of the American Academy of Sleep Medicine and Sleep Research Society on the Recommended Amount of Sleep for a Healthy Adult: Methodology and Discussion, Sleep, 38(8),1161-83.
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Type of Study Examples Meta- analyses
Folkard et al., 2006; Philibert, 2005; Pilcher et al., 1996; Pilcher et al., 2000; Lim et al., 2010; Driskell, 2005; Hutchins et al., 2013; Wickens et al., 2015
Systematic review
Saksvik et al., 2011; Parkes, 2012; Tucker, 2003; Wagstaff et al., 2011; Robb et al., 2008
Narrative review
Beswick et al., 2003; Durmer et al., 2005; Ficca et al., 2010; Goel, 2013; Harrison et al., 2000; Knauth, 2007; Folkard, 2008
Laboratory
Banks et al., 2010; Belenky et al., 2003; Bratzke et al., 2007; Cohen et al., 2010; Dijk et al., 1992; Doran et al., 2001; Drake et al., 2001; Ferguson et al., 2012; Johnson et al., 1992
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Type of Study Examples
Workplaces Dorrian et al., 2011; Baulk et al., 2009; Ferguson et al., 2010; Gohar et al., 2009; Heslegrave et al., 2000 (H-Q); Paech et al., 2010; Baker et al., 1995; Tucker et al., 1999 Population surveys Basner et al, 2007; Dembe et al., 2014; Escriba et al., 1992; Hale, 2005; Lombardi et al., 2010; Joint Consensus Statements & ACOEM Task Force American Academy of Sleep Medicine and Sleep Research Society, 2015 (recommended amount of sleep); National Sleep Foundation Drowsy Driving Working Group; American College of Occupational and Environmental Medicine (ACOEM) Guidance Statement
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Meta-analyses
variables
analytic examination
analysis
Systematic and narrative reviews
Laboratory
restriction and subsequent recovery: a sleep dose-response study
response effects of one night for recovery
effects on neurobehavioral functions and sleep physiology from chronic sleep restriction and total sleep deprivation
performance
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Workplace studies
safety after shifting from 9 to 12.5-hour shifts
residents
Population surveys
activities
illnesses: new evidence from the United States
national health interview survey (2004-2008)
Joint Consensus Statements and Task Forces
the American Academy of Sleep Medicine and Sleep Research Society
Environmental Medicine Task Force
consensus statement on drowsy driving