Deciphering Fatigue Risk Management Systems
A Holistic Approach to Mitigating Work-Related Fatigue
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Approximately 40 million workers in the United States (nearly 30 percent of the workforce) are employed in nonstandard work schedules such as shiftwork and extended work hours. These types of schedules are common and often required in industries such as transport, healthcare, mining, oil and gas, utilities, public safety, and information technology. Fatigue can reduce attention and concentration, impair communication skills, and limit decision-making ability, increasing the risk for safety-critical incidents such as injuries and motor vehicle crashes. For example, studies have shown that the risk of fatigue and safety-critical incidents not only increases over the course of a night shift, but it also increases dramatically over successive night shifts. Therefore, organizations that use shiftwork schedules need to manage the risk associated with fatigue to keep their workers safe and productive.
Limiting hours worked has been the traditional way of managing fatigue in some industries. This often means creating rules based on the number of consecutive shifts, break minima, shift length, or the maximum number of hours worked in a week or month. However, fatigue can stem from a number of sources such as extended time on task, heavy physical or mental workloads, monotony, exposure to hot or noisy environments, night work, and impaired sleep. For these reasons, managing fatigue in the workplace requires a holistic approach that recognizes its many sources and creates a framework to mitigate the risks. Fatigue Risk Management Systems A fatigue risk management system (FRMS) is a set of management practices for identifying and controlling fatigue-related risks. The use of this approach has been widely adopted internationally in the last two decades. More recently, in the U.S., FRMSs have been effectively incorporated by the Federal Aviation Administration and the Federal Railroad Administration.
To effectively manage work-related fatigue, we need to recognize not only the likelihood of fatigue, but also its related consequences. A unique aspect of an FRMS is that it recognizes that fatigue should be considered on a continuum, not a cut-point, and the risk for a safety-critical event relates the level of fatigue with the level of effort needed for the occupational task. Acknowledging that fatigue is impossible to eliminate entirely is a critical first step in identifying and controlling fatigue-related risk. This approach has been successfully adopted across a number of international jurisdictions and within key U.S. transport industries. Fatigue-proofing the workplace by reducing the likelihood or consequence of a fatigue-related error has clearly been shown as a method to reduce the risk associated with a fatigue-related error.
This risk-based approach to fatigue management generally allows a greater degree of operational flexibility. It is usually more accepted by workers because it doesn’t mean a complete stoppage of work and resulting loss in pay, as would happen with work hour limitations. This is not to say that work can or should continue indefinitely without breaks within the context of an FRMS, but rather that decisions about working time arrangements should be made based on an assessment of risk, not on arbitrary limitations to work hours.
Key components of an FRMS Components that should be included in an organization’s FRMS are policies and procedures that identify roles and responsibilities in the organization; risk assessment tools to quantify and assess fatigue risk; control plans and actions to provide ideas and decision trees for a graduated approach to manage fatigue; non-punitive reporting systems to create a trusted and strong safety culture; education and training to help workers and managers identify fatigue risk and strategies for minimizing those risks; and methods for regular monitoring and evaluating of the system for effectiveness (that is, a continual improvement process).
Policies and Procedures While some industries are bound by work hour regulations—one example is commercial truck transport, which is regulated by the Federal Motor Carrier Safety Administration—most organizations have formal and informal practices to manage workplace fatigue. Formal approaches include traditional work hour limitations. Informal approaches may include a “buddy system” where workers look out for each other to keep each other safe. An example of the buddy system is having another person double-check an employee’s work. Additional considerations may need to be made for compliance with any local legislations.
Incorporating elements of an FRMS doesn’t have to be complicated or costly, and it doesn’t necessarily mean overhauling your safety management system.
Roles and Responsibilities
Roles and responsibilities regarding the management of fatigue should be identified, as managing fatigue is a shared responsibility among workers, managers, and organizational leaders. While workers are responsible for ensuring they arrive well rested and fit for work, the most effective practice is to manage fatigue at the organizational or leadership level through work schedules or job design.
Fatigue-Related Risk Assessment Organizational risk assessment generally involves the identification, measurement, and control of factors that influence the likelihood and consequence of an adverse health and safety outcome. Using the ISO 31000 standard for risk assessment, fatigue-related risk is determined based on the likelihood and consequence of a fatigue-related error (see Figure 1). In this context, fatigue likelihood is generally based on a combination of analysis of work schedule structure, prior sleep/wake behavior, and self-assessment. Consequence severity depends on the tasks undertaken by workers when they are fatigued. For example, tasks where consequences would result in major or catastrophic outcomes would be at the more severe end of the rating scale.
Figure 1. Risk matrix for evaluating fatigue-related risk based on likelihood and consequences of a fatigue-related error. Adapted from ISO 31000, Risk Management.

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Control Plans and Actions Control plans and actions are road maps that identify pre-set actions to deploy when fatigue risk may compromise worker safety. One such road map is a decision tree, which helps quickly identify the appropriate actions to take. Control plans and actions may include a graduated approach where the responding fatigue mitigation action is proportionate to the level of fatigue risk. For example, in low- or moderate-risk situations, minor controls (for example, caffeine use) may be appropriate. In higher-risk situations, more extensive controls may be needed. This could entail replacing work with less safety-critical activities such as administrative duties. Only the most extreme circumstances would require a work stoppage. This flexible process provides options for workers to continue working safely while fatigued. In many jurisdictions, this process allows for work to continue at higher fatigue levels, as long as proportional control measures are implemented to ensure the safety of workers.
Non-Punitive Reporting Non-punitive reporting (sometimes referred to as a “just culture framework”) is fundamental to developing a strong and trusted safety culture and the successful operation of any fatigue management system. Non-punitive reporting allows managers and workers to report if they, or their co-workers, are too fatigued to work safely. This may include anonymous reporting; a sufficiently mature safety culture—one that is supported by the executive level—will ensure workers will not be punished for reporting fatigue. This allows the organization to discuss and recognize fatigue as similar to other workplace hazards without stigma or fear of backlash from management or workers. If punitive measures are taken or authority gradients are too steep, the result can be a culture of silence and mistrust that enables unsafe work practices.
Education and Training Education and training programs help organizations to meet their legal responsibility to inform employees about risk factors within the workplace. These programs not only provide information about fatigue risks and mitigation strategies, but also include opportunities where information is developed, learned, and used to encourage healthful behavioral change for workers and managers. Such training can be provided as short lessons or safety discussions that can be easily and gradually incorporated into regular work activities to allow for long-term, meaningful changes. Lessons would generally include practical training on the day-to-day functionality of the FRMS (for example, what to do if they are fatigued at work and how to manage any fatigue detection technology they have in place).
Monitoring and Evaluation Monitoring and evaluation of the FRMS is integral to continual assessment of its effectiveness as needs or situations change. Data gathered from various sources such as work scheduling, safety incident reports, overtime costs, absenteeism, and sick leave can be used to indicate if the FRMS is still effective over time. For example, data can be used to assess any positive or negative effects of work schedule changes on work injuries. It can also be used to determine the impacts of organizational or governmental policies on overtime costs, sick leave, or absenteeism. Ideally, these data sources should be monitored regularly to determine if any changes to the FRMS are needed to remain relevant. However, system evaluation is only as good as the data on which it is based. Considerations for good data sources include ease of collection and assessment, operational practicality, and data quality. These considerations apply not only to system components such as incident investigations or work schedules, but also to any technologies that may be used, such as fatigue detection sensors and modelling software. It is critical that operational needs and technological effectiveness are also considered when fatigue-detection technology is selected.
Viewing Fatigue As a Hazard Fatigue risk management is not just about providing people with hints for how to get a good night’s sleep. If fatigue is viewed as a hazard, in the same way as drugs, alcohol, or hazardous materials, it can—like those hazards—be embedded and mitigated within occupational safety and health management systems.
Many organizations are now combining work hour rules with an FRMS for a hybrid or transitional approach, which presents the opportunity for increased flexibility to accommodate different working conditions while increasing safety. The hybrid or transitional approach typically includes both risk-based and prescriptive components. This novel approach may include reducing the standard hours of work limits (where work can be undertaken without risk assessment or the implementation of controls). This reduced prescriptive envelope of permitted work time would then be supplemented with a risk-based approach. Work could be undertaken outside of this envelope, but only if the operator can demonstrate that it can be undertaken safely—that is, they can demonstrate that the fatigue-related risk has been assessed and controlled appropriately.
Incorporating elements of an FRMS doesn’t have to be complicated or costly, and it doesn’t necessarily mean overhauling your safety management system. Many organizations already have elements of an FRMS in place that can simply be updated, formalized, and enhanced. Similarly, FRMS components such as fatigue training during toolbox talks and risk assessment procedures can be added to your existing safety management system (but make sure you have clear policies and procedures for any new additions). These “quick wins” can be the first steps toward improving worker safety and well-being—or to developing a comprehensive FRMS.
MADELINE SPRAJCER is an academic at CQUniversity’s Appleton Institute with a research focus on sleep, fatigue, and safety.
IMELDA WONG is the program coordinator for the NIOSH Center for Work and Fatigue Research.
DREW DAWSON is a research psychologist specializing in fatigue.
The findings and conclusions in this report are those of the authors and do not necessarily represent the official position of the National Institute for Occupational Safety and Health, Centers for Disease Control and Prevention.
Accident Analysis and Prevention: “Fatigue Risk Management by Volunteer Fire-Fighters: Use of Informal Strategies to Augment Formal Policy” (November 2015).
Accident Analysis and Prevention: “How Effective Are Fatigue Risk Management Systems (FRMS)? A Review” (February 2021).
Accident Analysis and Prevention: “The Link Between Fatigue and Safety” (March 2011).
American Journal of Industrial Medicine: “The Human Factors of Mineworker Fatigue: An Overview on Prevalence, Mitigation, and What’s Next” (October 2021).
American Journal of Industrial Medicine: “Research Gaps and Needs for Preventing Worker Fatigue in the Transportation and Utilities Industries” (March 2022).
American Journal of Industrial Medicine: “US Research Needs Related to Fatigue, Sleep, and Working Hours Among Oil and Gas Extraction Workers” (November 2021).
CDC: National Health Interview Survey, Occupational Health Supplement (2015).
Ergonomics: “Educational Programmes for Shiftworkers, Their Families, and Prospective Shiftworkers” (1993).
Fatigue: Biomedicine, Health & Behavior: “Fatigue in the Workplace: Causes and Countermeasures” (January 2013).
Federal Aviation Administration: “AC 120-103A - Fatigue Risk Management Systems for Aviation Safety” (2013).
Federal Register: “Fatigue Risk Management Programs for Certain Passenger and Freight Railroads” (June 2022).
Industrial Health: “Working Time Society Consensus Statements: A Multi-Level Approach to Managing Occupational Sleep-Related Fatigue” (March 2019).
Industrial Health: “Working Time Society Consensus Statements: Prescriptive Rule Sets and Risk Management-Based Approaches for the Management of Fatigue-Related Risk in Working Time Arrangements” (March 2019).
Industrial Health: “Working Time Society Consensus Statements: Regulatory Approaches to Reduce Risks Associated with Shift Work—A Global Comparison” (April 2019).
International Journal of Environmental Research and Public Health: “Sleep Quality Among Police Officers: Implications and Insights from a Systematic Review and Meta-Analysis of the Literature” (March 2019).
International Journal of Modern Agriculture: “Demographic Profile and Occupational Health of Information Technology Professionals” (2021).
International Journal of Public Health Science: “Effects of the Occupational Physical Environmental Conditions and the Individual Characteristics of the Workers on Occupational Stress and Fatigue” (August 2012).
Journal of Cleaner Production: “A Comparative Outline for Quantifying Risk Ratings in Occupational Health and Safety Risk Assessment” (September 2018).
Journal of Occupational Health Psychology: “An Examination of the Relationship Between Workload and Fatigue Within and Across Consecutive Days of Work: Is the Relationship Static or Dynamic?” (July 2009).
Neuropsychiatric Disease and Treatment: “Sleep Deprivation: Impact on Cognitive Performance” (October 2007).
Neuroscience and Biobehavioral Reviews: “The Neurocognitive Consequences of Sleep Restriction: A Meta-Analytic Review” (September 2017).
NIOSH Science Blog: “Choosing the ‘Right’ Fatigue Monitoring and Detection Technology” (January 2021).
NIOSH Science Blog: “The Who, What, How and When of Implementing Fatigue Monitoring and Detection Technologies” (May 2021).
Occupational Medicine: “Shift Work, Safety and Productivity” (March 2003).
Occupational Medicine: “Systematic Review of Shift Work and Nurses’ Health” (June 2019).
Sleep Medicine Reviews: “Fatigue-Proofing: A New Approach to Reducing Fatigue-Related Risk Using the Principles of Error Management” (April 2012).
Sleep Medicine Reviews: “Look Before You (S)leep: Evaluating the Use of Fatigue Detection Technologies Within a Fatigue Risk Management System for the Road Transport Industry” (April 2014).
Sleep Medicine Reviews: “Managing Fatigue: It’s About Sleep” (October 2005).
Sleep Medicine Clinics: “Shift Work—Sleepiness and Sleep in Transport” (December 2019).
Transportation Research Part F: Traffic Psychology and Behaviour: “The Effect of Sleep-Need and Time-on-Task on Driver Fatigue” (October 2020).
U.S. Congress Office of Technology Assessment: “Legal and Regulatory Issues” in Biological Rhythms: Implications for the Worker, chapter 6 (September 1991).