HSE welcomes the development of the American Petroleum Industry’s fatigue standard: API RP 755 Fatigue Risk Management Systems For Personnel in the Refining and Petrochemical Industries and its accompanying guidance. Establishment and implementation of a Fatigue Risk Management System (FRMS) by employers is considered a positive step towards reducing and managing the risks of fatigue.
However, HSE wishes to emphasise that companies, which intend implementing the standard in the UK, should be aware that they will be also expected to comply with UK regulations on working time (including the Health and Safety at Work etc Act 1974, the Management of Health and Safety at Work regulations 1999, the Working Time Regulations 1998 and all other relevant regulations), as well as following good practice as outlined in HSE’s guidance on managing shift work (Managing Shift work: Health and Safety Guidance HSG 256). This includes paying appropriate attention to major accident safety issues eg under the COMAH Regulations, which may arise from poor control of fatigue and shift work.
Employers should also note that the ‘hours of service guidelines’ as outlined in API RP 755, have been developed in the context of the existence of a comprehensive FRMS, where the limits are intended to act as triggers for further risk assessment and not as working time limits. Consistently working to the limits is not sustainable and may lead to chronic sleep debt and would be considered unacceptable in the UK where rapid rotation of shifts and shorter weekly hours are considered good practice.