Chapter 5 - Review and Improvement Process (Mandatory)
- How to Use this Guide
- 1. Introduction
- 2. Manual Control and Organization
- 3. Fatigue Risk Management System
- 4. Training and Education (Mandatory)
- 5. Review and Improvement Process (Mandatory)
- 6. Appendices
- 7. Further Reading
Fatigue-related impairment is likely to change with operational demands, organizational culture, and employee turnover. It is important that the FRMS be continually reviewed and improved to ensure that it is operating effectively. All the major components of the FRMS and levels of control should be reviewed, including:
- FRMS Committee
- Communication and consultation
- Implementation process
- Schedule and actual hours of work
- Assessment of actual sleep obtained
- Training and education
- Delivery of training and education
- Incident and accident investigation
- Internal audits
Among other aspects, the review process should consider the following:
- Is the FRMS manual clear and up to date?
- Has everyone been provided with fatigue-related information and received the appropriate training?
- Is the FRMS able to identify and deal with fatigue-related hazards before they result in an error or incident?
- Is the FRMS able to adapt to changing operational demands, scheduling changes, and contingency situations?
- Is the reporting system adequate for identifying fatigue-related hazards?
- Is there an internal investigation and auditing system in place, and is it working?
- What feedback has been obtained from safety audits and from error and incident reports?
- What feedback has been provided by employees, contractors, and clients about the system?
As part of the FRMS review, it is also useful to look at annual expenditures on the FRMS. In calculating the cost of FRMS, include factors such as person-hours devoted to implementing and maintaining the FRMS and absenteeism due to fatigue.
Major design and implementation expenses normally occur in the first year. It is possible that absenteeism due to fatigue will increase slightly at the beginning as employees become more aware of fatigue as a potential hazard. However, it is likely that employees who feel impaired by fatigue already call in sick under normal sick leave conditions – the FRMS will probably help highlight existing causes of absenteeism.
The review may find that employees need to be encourage to participate more actively in the FRMS. Employees who hold key leadership roles within the organization could be approached to promote the FRMS. Similarly, employees who have been proactive throughout the review period in FRMS (e.g., reporting events, involvement in the FRMS committee, promoting fatigue countermeasures) could be formally acknowledged in corporate newsletters.
Points to Consider
- How often will the FRMS be reviewed?
- Who will be responsible for collecting data and overseeing the review process?
- How will the FRMS be reviewed?
- What will be done with information obtained through the review process?
- How will results of the review be communicated to employees?
The FRMS will be reviewed and updated after the first year of implementation. Following the post implementation review, the FRMS will be reviewed and updated every two years.
The Accountable Executive will appoint an independent person to be responsible for providing oversight for the FRMS review process. The review should include all aspects of the fatigue risk management system including (where applicable) the following components and operational responsibilities:
- Schedulers are required to maintain accurate records of planned and actual work hours for assessment with the FAID program.
- Payroll personnel are required to record reasons for absenteeism to assess any trends due to fatigue.
- Employees are required to complete a two-week sleep diary twice a year (which will be kept confidential from company management) to assess current sleep habits (see form in Section 7). This will be coordinated by the person responsible for the FRMS.
- Supervisors are required to report any instances where employees may be at risk of making a fatigue-related error due to insufficient sleep opportunity, insufficient sleep, or fatigue-related symptoms using the fatigue occurrence database (see Section 3.7). This data will be analysed for any trends and used for further improvement of the FRMS.
- Employees and supervisors are required to report any errors or incidents that may have been fatigue related using the reporting system outlined in the SMS policy. This data will be analysed for any trends and used for further improvement of the FRMS.
- Employees and supervisors are required to participate in incident investigation procedures, and provide data to investigators regarding work schedules, sleep obtained, and symptoms prior to the event. This data will be analysed for any trends and used for further improvement of the FRMS.
- The person responsible for the FRMS will conduct focus groups with a representative sample of employees to obtain feedback about the effectiveness of the FRMS.
- The person responsible for the FRMS will keep a record of all costs and benefits that result from the FRMS. This may include but is not limited to financial gains/losses, employee morale, and frequency of errors, lost time injuries, and fatalities.
After the review process, the Accountable Executive will review the findings and the FRMS Committee will meet to discuss the results and any potential changes to be made to the FRMS. The results of all FRMS reviews, together with any actions taken to improve the FRMS, will be kept on file for Transport Canada to review in the auditing process. Any changes made to the FMRS policies and procedures document will be recorded using the manual amendment process, outlined in Section 1.2.
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