Chapter 3: Policies and Procedures
- 1. Overview of Fatigue Risk Management
- 2. Responsibility for Managing Fatigue under an FRMS
- 3. Policies and Procedures
- 4. Training and Education
- 5. Level 1 Controls: Providing Sufficient Sleep Opportunity
- 6. Level 2 Controls: Assessing Actual Sleep
- 7. Level 3 Controls: Assessing Symptoms of Fatigue
- 8. Level 4 and 5 Controls: Fatigue Proofing and Reporting Incidents and Accidents
- 9. Internal FRMS Audit
On completing this chapter, you will be able to:
Describe the importance of developing an FRMS policies and procedures manual.
Write a mission statement, outlining the scope, objectives and purpose of the FRMS and design subsections of an operationally specific policies and procedures manual.
Policies and Procedures
As discussed in Chapter 1, it is the responsibility of company management, or a fatigue risk management working group, to produce a policies and procedures manual. This includes ensuring that employees are consulted and have the opportunity to provide feedback throughout the policy development process. The goals, objectives, implementation, and day-to-day operation of the FRMS should be clearly documented and communicated to all stakeholders.
The policies and procedures manual defines fatigue and its associated risks and creates a common understanding within the organization about the principles and standards for dealing with fatigue-related risks. The FRMS policy helps align all organizational efforts toward the ultimate goal of improved safety. If employees are consulted throughout the development of the policy and are supportive of the process, it is more likely they will take a positive, proactive approach to fatigue risk management at the individual as well as organizational levels.
FRMS policies and procedures should:
meet existing legal/regulatory/industrial requirements for fatigue risk management
suit specific operational needs
allow intra-organizational flexibility (i.e., the rules for one work group may not necessarily be the same as another within the same company)
not place unnecessary economic burdens on organizations
Studies have found that many organizations need guidance in designing FRMS policies that are both specifically suited to their operational needs and that meet regulatory approval. Transport Canada has published a companion document to this guide that offers guidelines for the development of policies and procedures (see Policies and Procedures Development Guidelines, TP 14576E).
FRMS policies are often developed over a period of several months. Many organizations begin by releasing an over-arching mission statement to set the framework and to underscore the backing of senior management of the organization (e.g., CEO, general manager, board members). The mission statement should also be incorporated as a single paragraph into the organization's existing SMS policy (for more information on developing the policy and mission statement, see Section 3.2 of Policies and Procedures Development Guidelines). In addition to stating management support, the mission statement should outline the scope, purpose, and objectives of the FRMS. The document need not be any longer than a page. An example is provided below.
Fatigue Risk Management Mission Statement
ABC Company is committed to protecting all employees, clients, and visitors from fatigue-related risk.
ABC's fatigue risk management system aims to continually improve the safety of its flight operations by managing fatigue-related risk and by ensuring that staff consider at all times the safety implications of their own fatigue, and that of their colleagues.
ABC Company's fatigue risk management policy is backed by the strongest commitment at the highest level.
(signed by managing director)
Sample FRMS Mission Statement
After announcing the support of senior management through the mission statement, the detailed design of the FRMS policies and procedures manual can begin. The responsibility for developing, implementing, and maintaining the FRMS manual should ultimately rest with the individual responsible for safety or with a more formal fatigue working group (also known as the FRMS committee). However, there should be opportunities for employees to provide input. It is important that employees understand the purpose as well as the required elements of the FRMS policy. The consultation should be undertaken by the person or committee responsible for the development, implementation, and operation of the FRMS policy.
Studies have underscored the benefits of ensuring that employees are involved in all new and ongoing policy initiatives. This not only ensures buy-in from employees, but also improves the likelihood that the goals and action plans set out in the policies are based on the true capability of the organization and its employees.
The detailed FRMS policies and procedures manual should describe the various levels of fatigue hazard controls to be put in place at the company and the related procedures for each. Usually the manual covers:
responsibilities of employees under the FRMS
communication and consultation processes
hours of service and scheduling
verification of actual sleep
monitoring of fatigue-related symptoms
training and education
review and improvement process
- Describe the importance of developing an FRMS policies and procedures manual.
- Write the scope, purpose, objectives and definitions for your organization's FRMS.
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