GM1 ORGH.MGM.200(b)(4) General requirements for the management system

CONSIDERATION OF FATIGUE IN PLANNING GH ACTIVITIES

(a) The GH organisation is already subject to compliance with the provisions of Directive 2003/88/EC of the European Parliament and of the Council of 4 November 2003 concerning certain aspects of the organisation of working time. This is considered the most relevant document enabling the GH organisation to manage fatigue among its GH operational personnel.

(b) Fatigue is one of the factors that may contribute to errors when it is not properly considered as part of planning activities.

(c) Fatigue may be induced by:

(1) the environment and conditions in which work is carried out (e.g. noise, rain, high or low temperature), working in enclosed spaces, lifting/moving heavy items or working in uncomfortable positions (e.g. in a bent position or on knees);

(2) excessive hours of duty and shift working, particularly with changing shift periods or patterns, work intensification due to, for example, flight delays or short turnaround times, personnel shortage, additional overtime or night work.

(d) The way and the extent to which the GH organisation should consider the threat of fatigue in the planning of GH tasks and organisation of shifts may vary from one organisation to another, depending on the type of GH activity and the operational context in which it is performed (where, when and by whom).

(e) Fatigue is one example of a human factor that should be considered by the management system, particularly in the planning of activities. In this respect, where the personnel involved in an activity are prone to experiencing fatigue, it is recommended that the GH organisation:

(1) ensure that the safety reporting system required by point ORGH.GEN.165 enables the collection of data on fatigue issues;

(2) ensure that the threat of fatigue is adequately considered by the management system’s key processes (e.g. assessment, management, monitoring);

(3) provide safety‑related promotional material and adapt safety training accordingly.

(f) When organising shifts, the GH organisation should consider good practices in the GH domain and applicable rules. Below are a few examples of how the GH organisation can set up activities and shifts in a way that enables GH personnel to remain sufficiently free from fatigue to perform the planned activities safely:

(1) include regular breaks in the working schedule, adjusted to the type of activity;

(2) provide rest periods of sufficient time to enable workers to overcome the effects of the previous shift and to be rested by the start of the following shift;

(3) avoid shift patterns that cause a serious disruption of an established sleep/work pattern, such as alternating day/night duties;

(4) inform the personnel of the shift schedule and changes to it sufficiently in advance to enable them to plan adequate rest;

(5) plan recurrent extended rest periods and notify the personnel of these sufficiently in advance.

(g) It is recommended that the GH organisation have a procedure, including mitigation measures, to address cases where working hours are going to be significantly increased or where shift patterns will be significantly modified, such as for urgent operational reasons. In cases not covered by that procedure, the organisation is expected to perform a specific risk assessment and define additional mitigation actions, as applicable. Basic mitigation measures may include:

(1) provision of additional supervision;

(2) use of additional rest breaks.