Chapter 9: Internal FRMS Audit

Learning Outcomes

On completing this chapter, you will be able to:

  • Detail the fatigue-risk management factors that are assessed during internal audits.

Internal FRMS Audit

The components that make up a fatigue risk management system will evolve over time as additional information is collected and assessed through normal operations or through investigations into incidents or events. This chapter outlines the kinds of information that can be useful for conducting an internal audit of the company’s fatigue risk management system. Sample questions have been provided that make it possible for individuals or groups who are not necessarily fatigue risk experts to perform the audit. While other stakeholders such as regulators may require additional data for their own purposes, the questions provided below can act as a useful starting point.

Ideally, an internal FRMS audit should be conducted one year after the initial implementation, and every two years after that. Internal audits are generally conducted by the safety manager or by an external consultant. However, it is essential that employees be involved in the audit process to obtain their perceptions of how the FRMS is working. After the review, senior management and the FRMS committee should meet to review and discuss the findings and plan any potential changes to the FRMS.


Used to define fatigue and to outline responsibilities of the employer as well as employees.

  • Has a fatigue policy been developed?

  • Does the policy clearly detail individual responsibilities of the employer and employee (may also include clients and contractors) in managing fatigue?

  • Does the policy specifically help employees, supervisors and managers understand (1) the significance of fatigue management, and (2) their role in keeping levels of fatigue within acceptable levels in the workplace? Has the policy manual been shared with all relevant stakeholders for comment and final approval?

  • Has the policy implementation date been chosen or has the policy actually been implemented?

  • Has the policy also been applied to contractors who work on-site?

FRMS Committee (or person responsible for the FRMS)

Tasked with the review and guidance of company matters relating to fatigue.

  • Has an FRMS committee been established? Or has it been incorporated into a more general safety committee? Or has a person been designated as responsible for the FRMS?

  • Does the committee represent all the key stakeholders – for example, operators, supervisors, managers, maintenance and safety personnel, union representatives, as well as trainers?

  • Has the FRMS committee (or person responsible for the FRMS) been provided with the resources, information, and technical support to perform its required role?

  • Has the FRMS committee (or person responsible for the FRMS) identified major fatigue-related issues, problems, and strengths related to fatigue management in the organization and subsequently developed a fatigue management plan?

  • Does this plan deal specifically with training and education, scheduling guidelines, risk management, workforce planning, as well as management training and activities?

Communication and Consultation

To keep all stakeholders informed of the fatigue management process and its progress (may be developed by the FRMS committee or a pre-existing group).

  • Have all reasonable methods for communicating to stakeholders been assessed for effectiveness and cost benefit (for example, face-to-face training, e-mail, safety newsletters, posters in the workplace)?

  • Have stakeholders been provided with the policy, hours of work guidelines, information about training and education, as well as sources of additional information?

  • Have stakeholders been consulted about the implementation of the FRMS? What did the consultation process involve? How did the organization consider each group’s point of view in establishing the final FRMS?

Implementation Process

The step-by-step process and schedule for implementation.

  • Have supervisors, managers, and those who supervise or manage onsite contractors been trained in the implementation and use of the fatigue management system? Do company management, supervisors, and employee representatives have the skills to implement and manage the FRMS?

  • Have all parties received information and procedures for managing fatigue according to the policies and guidelines?

  • Have training sessions or workshops been conducted to address any questions and to discuss possible scenarios?

  • Has resource material been provided to support these employees after the session?

Schedules and Actual Hours of Work

Where “acceptable” balances safety, operational, and general risk concerns with social requirements.

  • Has a scheduling guideline been developed that meets both organizational requirements and fatigue risk management principles?

  • Were stakeholders consulted and asked to provide feedback regarding the FRMS scheduling guidelines?

  • Were stakeholders provided with adequate information about the specific fatigue implications of various shift structures?

  • Has a date been set to implement the scheduling guidelines or have they already been implemented?

  • Have specific criteria been developed to manage the effect of overtime, leave and vacation, start and finish times of shifts, and commuting to and from work?

  • Has a fatigue assessment tool been used to predict fatigue levels associated with the hours of work? Have the scheduling guidelines been applied to contractors work on site?

Assessment of Actual Sleep Obtained

To ensure that there is a process to be followed if an employee does not feel safe to start or continue work. Ideally, this should be non-punitive.

  • Has fatigue been formally recognized as a legitimate reason for employees to stop work and/or request a break?

  • Has a system been developed to manage reports of fatigue? What is the system?

  • Was the workforce able to participate in the planning and development of the self-disclosure system?

  • Has the fatigue self-disclosure system been used? How many reports have been processed over the last week/month/six months/year? (No reports of fatigue over a number of months may indicate that the organizational culture does not yet support the system.)

Development of Training Program

To determine whether appropriate training materials are developed.

  • Who is responsible for developing/ presenting training materials to employees?

  • What are the key components of the training?

  • If training materials were developed in-house, was the person or group provided with adequate reference material, financial resources, and support to complete the job to an acceptable standard?

  • Have adult learning principles and competency-based training methods been used?

  • Were the people who developed the training adequately qualified and/or experienced to develop a fatigue-related program?

    • Have the materials been tested and reviewed by groups of employees?

    • Has any employee reported fatigue on so many occasions that it is considered excessive? (It is important that such cases be managed carefully and appropriately and that a clear definition of excessive be in place.)

    • Has the FRMS committee or other relevant pre-existing group developed procedures to help supervisors deal with employees who report that they are fatigued?

Delivery of Training

To ensure that specific and targeted training occurs using suitably qualified and experienced trainers.

  • Are trainers appropriately qualified and experienced? (Experience with shiftwork is a significant advantage)

  • Have trainers been involved, or at least fully briefed, in the development of learning outcomes, lesson plans, and other aspects of the training requirements? (For material developed in-house)

  • Have trainers been supplied with, or provided access to, reference materials to help answer a wide range of related questions?

  • Have trainers been supplied with evaluation forms so that training can be improved?

  • Is a training register kept as a record that employees have completed their training?

Incident and Accident Investigation

To update procedures to ensure that fatigue is included as a potential factor to be investigated.

  • Has the existing incident and accident investigation process been fully reviewed to determine whether it adequately identifies potential fatiguerelated issues?

  • Does the process collect data relating to work and non-work related factors that may contribute to fatigue?

  • Have incident/accident investigation and training procedures been updated?

Internal Audits

To keep accurate records of implementation for reporting purposes and audits by any outside parties such as regulators.

  • Does the internal audit system assess all relevant components of the fatigue management system? (At a minimum, this should include policy, training, hazard control, and audit.)

  • Are there additional assessments that might provide valuable information for the organization? If yes, provide details.

  • Has a survey or other consultation been conducted within the organization and with any relevant contractors to consider the adequacy of the process and level of impact of the fatigue management system?

  • Are follow-up assessments made of training delivery, compliance with scheduling guidelines, implementation schedules, and other parts of the fatigue management implementation?

While the list above suggests that an audit consists of a number of distinct and independent reviews, it should not be forgotten that each component is part of an overall, interactive system.

- Discuss the benefits of conducting fatigue management internal audits.
- List six aspects of an FRMS that should be assessed during an audit.
- Provide at least three key questions for three of these aspects that should be asked during a thorough internal audit assessment.
- List the departments and/or individuals or groups that need to be involved in the review and update of the incident and accident investigation system as well as the internal audit system.

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