Upcoming changes to fatigue risk management
Topic: Fatigue risk management
Presenters: Steve Whitesmith, Mick Bishop, Desley Thompson
Date: Wednesday, 19 February 2025
Who attended: Vessel owners or operators, seafarers, maritime industry professionals, national and state industry associations, State and federal government agencies, industry advisory groups
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Thompson, Desley 4:42
Good afternoon, everyone, and welcome to today's webinar. My name is Desley Thomson, and I'm AMSA’s Safety Advisor Liaison Officer for Aboriginal and Torres Strait Islander people and communities. I'm based here in the Cairns Office in Far North Queensland.On behalf of the team and AMSA, we're excited to have you here as we dive into some of the upcoming changes to Marine Order 504. These changes will come into effect on 1 June 2025.
Today is the first in our series of three webinars about the changes to safety management system requirements, and our first topic today is fatigue risk management.
Before we go any further, I'd like to acknowledge the Traditional Custodians of Country throughout Australia and also acknowledge their connections to land, sea, and community. We pay our respects to their Elders, past and present, and also extend that respect to all Aboriginal and Torres Strait Islander peoples here today.
Just some housekeeping before the presentation:
- Today's webinar is being recorded, and you will receive a link to the webinar afterward.
- Please be aware that there is a 30-second delay.
- If you'd like to turn on live captioning, please do so by clicking the captions button, and it should automatically appear for you.
- If you have any questions, please post them in the Q&A chat. Our AMSA experts—Nathan, David, and Natalia—will answer these throughout the presentation.
- Questions can be posted anonymously too. If you see a question in the chat that you'd also like answered, give it a thumbs up to help prioritise it.
- We will make sure to respond to all questions either during the webinar or afterward.
- At the end of the presentation, we'll also ask you to complete a short survey. This will help us gauge whether our webinars are meeting your needs.
I'd now like to introduce the team helping me out today:
- Steve Whitesmith, AMSA’s Liaison Officer in the Fremantle Office, WA
- Mick Bishop, a Liaison Officer in the Townsville Office, QLD
Our presenter today is Steve. I'll now hand over to you to begin the presentation.
Whitesmith, Steve 7:25
Thank you, Desley, and thank you to everyone attending today. As you can see from the slide, there are seven areas that will be covered in this seminar, so let's begin.The fatigue management requirements under Marine Order 504 provide vessel owners with flexibility to chose how they manage the risk of fatigue for masters and crew. This could be through the use of a fatigue risk management plan. Whatever method is chosen, it must include a level of detail that matches the operation’s risk level, type, and complexity.
The requirement for fatigue management applies to all Class 1, 2, and 3 DCVs, including all operation types and voyage lengths. The level of detail required will be determined on the nature and complexity of the operation.
As mentioned earlier, these changes take effect from 1 June 2025. It is also important for vessel owners to continue managing risk of fatigue under state and territory work health and safety laws.
Why has AMSA made these changes? AMSA conducted a research survey in 2019 to understand awareness and perceptions of fatigue and its management for masters and crew working on DCVs.
Responses on sleep duration and quality at home indicated that one-third of seafarers commenced duty in a fatigued state. While at sea, 40% of respondents stated getting less than six hours of sleep in a 24-hour period.
Respondents were also less likely to recognise behavioural symptoms of fatigue, such as headaches, body aches, affected speech, and increased risk-taking.
Over 25% of respondents stated they experienced fatigue very often or most of the time, either immediately before or during their time at sea.
50% of respondents indicated they had either not received any fatigue management training or were unsure.
Fatigue is a hazard that can affect a seafarer's ability to perform their job safely and effectively. It also affects health and well-being. There is a common misconception that fatigue comes with the job, but the reality is that many maritime operations expose seafarers to conditions that lead to fatigue.
Fatigue has been identified as a contributing factor in several marine incidents. We will touch on a few of these later in the presentation.
Accident investigations and research reveal the serious impact of fatigue on safety, health, and welfare. While fatigue cannot be eliminated, it must be properly managed.
Aspects that elevate the risk of fatigue include:
- Inadequate sleep (both in quantity and quality). For example, sleep disorders such as sleep apnoea can affect the quality of sleep
- Shift work, which disrupts the body clock
- Duration of continuous work without adequate breaks
- Intense mental and/or physical workloads
- Stress, isolation, and separation from family
- Environmental aspects such as ship motion, vibration, temperature variation, light, and noise.
- In recent years, family and work demands, including increased use of electronic devices such as phones and time spent on social media have also affected sleeping habits.
Fatigue can have a profound impact on an individual’s ability to work safely. It has been shown to not only have an impact on their physical and cognitive abilities but also impact individual behaviour.
To give you some examples, we would like to get an idea of how many of you have experienced fatigue in your job.
It might be firsthand or you may have witnessed a colleague suffering from the risks of fatigue while working.
If you can add a thumbs up to the question in the Q&A chat, and then we'll go through the next few slides which might help you in considering this question.
Common physical signs of fatigue include inability to stay awake, head nodding, or falling asleep involuntarily. Difficulty with hand eye coordination, speech difficulties, slurred, slow or garbled speech, increased frequency of dropping objects like tools or parts, digestion problems, and insomnia.
And cognitive science of fatigue includes being preoccupied, lapses in concentration, misjudging distance and speed, and slower reaction times.
Common behavioural signs of fatigue include decreased tolerance and or displaying antisocial behaviour, irregular mood changes, irritability, depression, failure to anticipate danger and low motivation.
In fatigued, this can impact safety, performance, health and well-being, and in some cases, this has led to marine incidents with consequences similar to that shown in the photograph.
We'll discuss a couple of marine incidents later in the presentation.
Most dangerous aspect when fatigue is that we are poor judges of our own level of fatigue and performance because of what we know about fatigue and its consequences it's important that we manage the risks. This can be done through having a fatigue risk management plan.
Generally, the single most important factor to consider in managing the risk of fatigue is sleep.
People generally need 7 to 9 hours of good quality sleep to perform effectively. Anything less is a compromise. For example, if an individual only obtains 5 hours sleep, they have accumulated a sleep debt. Unless this sleep dead is recovered, it will lead to performance impairment. Sleep debt only goes away with good quality sleep.
Excessive nights of inadequate sleep add to this sleep debt. This leads to further reduction in performance and can lead to more severe fatigue symptoms such as micro sleeps, long term sleep debt has been shown to have a significant impact on health and well-being.
Another factor is time awake. The longer a seafarer remains awake, the stronger the drive for sleep, and the higher the levels of fatigue.
Long work hours are associated with poor performance and poorer safety and health outcomes.
How far you have to commute to work is also important to consider.
Seafarers may have to travel or drive long distances to the vessel and then have to work again, affecting their quantity of sleep. This is similar for crews who work part time or are volunteers with other employment. They can also be affected by quantity of sleep.
Everybody has a body clock, and this clock regulates the body's circadian rhythm.
Body Clock makes a person sleep or alert on a regular schedule, regardless of whether they are working or not.
Body clock programmes us to be active during the day and to sleep at night.
In normal conditions the sleep-wake cycle follows a 24-hour rhythm. However, the cycle is not the same for everyone.
Typically, we are most alert during the day and sleepy at night. The circadian through typically occurs between 2:00 and 6:00 AM and is referred to as the window of circadian low.
This is when we're at the lowest of our alertness and working during these times means we are more at risk of making mistakes and this has been scientifically proven.
Consequently, the time of day in which work takes place increases the risk of fatigue. Seafarer is working through the night can be expected to be sleepy, and when you look at the circadian rhythm diagram in the slide, you can see that the period that is dark red in colour between 2:00 and 6:00 AM, where they have to make additional effort to maintain alertness and performance.
Many seafarers working patents conflict with their body clock.
If you have to be awake and work at night or in the early morning, or working for extended periods, it can disrupt your body clock, resulting in increased risk of fatigue.
We will now take a short break to go through some questions in the Q&A chat and answer some commonly asked questions. I’ll now pass over to Desley and Mick.
Thompson, Desley 17:13
Thanks, Steve. Just in terms of the webinar poll.There's been a quite a few thumbs up and I can see a few that have had experience around fatigue at work, so it's a really important discussion that we're having today and thank you for those that have put their thumbs up and have noted that the poll as well too.
Also, thank you to those that that are posting some questions on the Q&A chat. I might read a couple of them and.
Get you Steve or Mick to answer them for me, if that's OK. So the first one is.
Whitesmith, Steve 17:49
That's fine.Thompson, Desley 17:53
Can I use an SMS app to develop my fatigue plan? How about this Steve, did you want to answer that one? Thanks.Whitesmith, Steve 17:58
Yep, I'll take this one. That’s a great question! As we know, SMS apps are becoming increasingly common, popular in the industry. If an app has the ability to include a fatigue risk management plan, it can certainly be used.However, under Marine Order 504, a vessel's SMS must be kept on board and be reasonably practical based on the vessel’s size and use. A copy must also be kept onshore. The requirement won’t be met if the SMS cannot be accessed while on board—for example, if it relies on internet access and hasn’t been downloaded. I’d recommend having a chat with your SMS provider and they will be able to provide information in terms of access to the SMS.
Thompson, Desley 18:45
Thanks for that response. That’s great to know because, as you said, there are quite a few apps available now.This next question is for you, Mick: Why doesn’t AMSA align the minimum rest hours in the domestic maritime industry with international standards—specifically, the 10-hour minimum break in each 24-hour period?
Bishop, Mick 19:24
Great question on fatigue risk management. Our approach considers a broader range of risks beyond just work and rest hours, including environmental factors, night work, and the suitability of the sleeping environment. This flexible approach better suits the diverse range of domestic commercial vessel operations, which vary from large vessels to small ones and from long trips to short ones, rather than applying a one-size-fits-all model.Thompson, Desley 19:55
You’re absolutely right—it’s a diverse industry, and having that flexible approach makes sense. Thanks for that, Mick.Next question for you, Steve: I already have a fatigue plan. Do I need to redo it?
Whitesmith, Steve 20:13
No, you don’t need to redo it, but you do need to review it. It’s important to ensure your plan complies with the requirements of Marine Order 504. You can review it anytime between now and 1 June to meet the upcoming changes. If you already have a plan, I’d encourage you to review it, compare it against the information we have online and what you’ve learned from today’s presentation, and ensure it meets all the necessary requirements—not just those of Marine Order 504, but all relevant standards.Thompson, Desley 20:15
OK.Thompson, Desley 20:47
That’s good to know. Thank you.OK, Mick, here’s a question for you: How are emergency service volunteers supposed to manage their work/rest hours, given that they often respond to emergencies after their day jobs, particularly in the evenings?
Bishop, Mick 21:07
That’s another great question. Volunteer organisations need to factor this into their risk management plans. When reporting for duty, volunteers should assess and communicate their current fatigue levels.For example:
- How well did they sleep the night before?
- How long have they been awake?
- What type of work have they been doing—manual or mental? (There’s obviously a big difference.)
- How long have they been working?
- What is their general health and well-being status?
Organisations should then use a fatigue management plan to determine a volunteer’s suitability for a given task. For example, should they be deployed on a rescue boat, or would it be safer for them to assist from the base during the operation?
Thompson, Desley 21:50
Those are really good things to think about—thanks for that, Mick.I’ll now hand back over to you, Steve, to continue the presentation.
Whitesmith, Steve 22:00
OK, thanks, Desley. Mick. So, yes, we'll continue, and we're now into the nuts and bolts of it in terms of the approach you take to developing your plan.As mentioned earlier, 50% of crew who undertook the fatigue survey indicated they had either not received any fatigue management training or guidance, or they were unsure. Educating yourself and the crew about the causes and consequences of fatigue is a good start. It is important to understand what causes fatigue and what can happen when a person is fatigued. Having a shared awareness of the causes and consequences will ensure that you and your crew are better placed to deal with fatigue and lessen its effects.
This should also include factors that increase the risk of fatigue at sea, identifiable signs and symptoms of fatigue, so that crew are educated to identify fatigue not only in themselves but in others. We discussed this earlier when we looked at the physical, cognitive, and behavioural signs of fatigue.
Effective fatigue coping measures can be adopted at sea, and fatigue risk management approaches assist in managing fatigue risks. It is important to document how you provide education and training to your masters and crew on fatigue in your plan.
Once the crew are educated, they can contribute to your fatigue risk management process. Open communication about managing fatigue is critical. You and your crew should feel comfortable having these types of conversations.
The risk of fatigue needs to be considered as part of the owner's risk assessment and appropriate crew determination within the vessel safety management system. The owner must develop the plan with assistance from the master and crew, drawing on the experience and expertise of all people involved in the operation.
Once educated on fatigue, the master and crew can then contribute to the development of the plan. It is important to make it clear that managing fatigue and its associated risks is a shared responsibility between the owner, the master, and the crew.
The master and crew not getting enough quality sleep is the main contributor to fatigue. This must be the primary consideration when putting together a fatigue risk management plan, so it is essential that seafarers are provided with adequate sleep opportunity. There may be instances when seafarers do not obtain adequate sleep, even when provided with the opportunity. Regardless of what circumstances are causing insufficient or poor-quality sleep, it is important to recognise these as potential shipboard hazards.
Developing good sleeping habits is key. There are simple strategies you can adopt to improve sleep, and more information on this is being added to the Q&A chat.
Maintaining fitness for duty is crucial. Seafarers must be fit for duty and able to maintain safe levels of alertness and performance. It can be helpful to monitor and assess seafarers' levels of fatigue before commencing work to ensure they can perform tasks safely. A fatigue assessment tool can assist with this.
Work with your master, crew, and anyone else who may be able to help identify factors contributing to fatigue risk in your operation. Consider the types of operations you undertake and think about what could go wrong if a person is fatigued, how it could endanger lives, and impact the environment.
A checklist and fatigue risk management tool are useful guides and are available on the AMSA website.
Working at night presents a high risk that crew may fall asleep because they are working against their circadian clock.
In these circumstances, you need to ensure you have the right control measures in place to manage the identified risks, with particular attention to working between midnight and 6:00 AM.
As shown on the slide, AMSA has highlighted two marine incidents through our Safety Lessons page where fatigue was a contributing factor to vessel groundings. Investigation findings included:
- For the lone crayfish vessel, the master acknowledged they fell asleep due to fatigue.
- For the 3B fishing vessel, no formal watchkeeping procedure was in place or documented. Extended wakefulness and intermittent rest periods resulted in the crew being fatigued, leading to a watchkeeping mix-up during the circadian low between 2:00 and 6:00 AM.
Having considered the risk of fatigue with input from the master and crew, record the risks identified in your risk assessment. In the example shown, key risk factors have been identified:
- Ensure crew have adequate fatigue training and awareness so they understand the risks.
- Limit the number of hours crew are required to work at night.
- Plan for a minimum of two crew members together on deck or on navigational watch.
- Ensure crew are fit for duty by providing adequate time for sleep before commencing duty and, where possible, allowing for short rest breaks.
Once identified, controls are added to the controls column in the risk assessment. Fatigue training awareness would be recorded under training risk control. Again, this is an example only and may not be applicable to your operations.
Identify the risks and the controls you intend to implement. You then need to consider who will be responsible for implementing and monitoring the controls. In making this decision, consider the knowledge and training of the person and their ability to undertake the role as part of or in addition to their normal duties. Each control measure requires someone to ensure it is implemented and followed. Depending on the control, this could be the owner, master, or a crew member. In this example, the owner has shared responsibilities with a breakdown of the areas of responsibility.
After going through the education and planning steps, it is time to implement your plan. This requires updates to existing procedures or the development of new procedures regarding fatigue. Once ready, undertake training for your master and crew, and when satisfied, put it into practice.
It is important to trial your plan to ensure it is working as intended. The trial should run for a reasonable period, typically one to two months, to identify and address any problems. Ask key questions and encourage honest feedback from the master and crew to ensure the plan functions as intended.
As you can see in this example, the owner has undertaken a review of the trial in consultation with the master and crew. For this particular risk, they have recorded three observations and will update the training manual.
Having completed the fatigue risk management plan, including a trial period and being satisfied that it is fit for purpose, the plan becomes part of normal vessel operations. The plan must be reviewed following any incident where fatigue may have been a contributing factor, if the master or crew raise any fatigue concerns, and at a minimum during your annual SMS review.
AMSA has a number of resources available on our website that you may find useful. The link is now being added to the chat. You can also find these resources by using the search function at the top of the AMSA homepage by entering the word "fatigue."
We will also ensure links are included with the uploaded copy of this presentation and provided to webinar participants.
We will now go through some more questions, and I will ask Mick and Desley to rejoin the chat.
Thompson, Desley 31:24
Thanks Steve. There's been a lot of questions that have come through and thanks to Nathan and David and Natalia, for looking after the Q&A section.I am going to read out some questions for you both, so this one's for you, Steve.
So will AMSA be inspecting our plans?
Whitesmith, Steve 31:43
Yes. So the fatigue risk management plan forms part of the SMS. The risk assessment component is part of your safety management system and you may well be asked by an inspector to produce a plan during an inspection or following an incident. So yes, certainly your plan can and will be inspected at some point in the future.
Thompson, Desley 32:04
OK. Thanks for that.Mick, so I run a small vessel and I only work when the sun is up and for a short period of time. Does my plan need to be that big?
Bishop, Mick 32:18
No, It doesn't. Operator has got the flexibility to develop a fatigue risk management plan that works best for them and their operation. So the scale of the plan will depend on the size and complexity of your operation as well as the length of the voyage.In fact, AMSA will be discussing shorter versions of the fatigue risk management plans in more detail in our simplified SMS webinar on the 9th of April, and we encourage small vessel operators to register at that time.
Thompson, Desley 32:50
Thanks for that Mick. So the next question is, actually it's more of a statement. I'm out at sea for a week at a time. It's not easy to get a good amount of sleep. Mick, what do you suggest I could do?Bishop, Mick 33:04
Good question. And there's a number of things they could look at to do with the environment as part of their plan. So, for example,- blackout curtains for darkness
- suitable temperatures very important and
- reducing noise levels if that's possible
- The other thing is calm anchoring areas if they're available.
There's also, apart from that, you can also look to provide risk breaks throughout the work period such as naps and meal breaks. All of those will contribute to helping address fatigue.
Thompson, Desley 33:41
That's great. Great suggestions there. Thanks, Mick.Whitesmith, Steve 33:48
All right. Thanks, Desley. Thanks, Mick. So, prior to closing out, we, we'd like to remind everyone that there are two more webinars on the upcoming changes to Marine Order 504, if you haven't already done so, you can register for these on the AMSA website or through the link in the chat.Thompson, Desley 34:08
Thanks everyone for attending today.I hope you enjoyed it as much as we did. So to help the team make sure that future webinars are valuable use of your time we'd like some feedback from you. So you'll see that in the chat now there's a link to conduct a short survey for us, please.
And like Steve said, if you haven’t already registered for the next webinar, please do so and please encourage others to attend as well too. So, we hope to see you in March for the next one.
Thanks everyone.Whitesmith, Steve 34:50
Thank you. Cheers.