Staying Alert: Australia’s New Code of Practice on Managing Fatigue is on the Horizon

In Australia, several high-risk, safety-critical industries, including mining, oil and gas, rail, transportation, utilities, and emergency services, operate on rotating schedules with 24/7 cycles to meet customer demand. These industries frequently face challenges related to fatigue ^{(1, 2)}. Since 2024, Safe Work Australia (SWA) has conducted a review of the existing guide. It is preparing a draft code of practice, with the intention of releasing a review on fatigue and working hours. The Model Code of Practice: Managing Fatigue Risks at Work (the Code) promises a significant upgrade on the current 2013 guide with a sharper, risk-based approach ⁽³⁾.

The Current Guide on Fatigue and Working Hours

The Guide for Managing the Risk of Fatigue at Work, released by Safe Work Australia in 2013, provided practical steps for identifying fatigue hazards, assessing risks, implementing and regularly reviewing the controls. It also provided tools, checklists, case studies, and general advice, making it a valuable resource across various industries. But for safety-critical sectors, where risks escalate under complex shift patterns and isolated working conditions, a more dynamic framework was needed ⁽⁴⁾.

Enter the Model Code – Risk-Based and Practical

Expected to be finalised by the end of 2025, the Draft Model Code of Practice on Managing Fatigue Risks at Work builds on the 2013 foundation guide. Importantly, it takes things further, introducing a risk-based approach tailored to the realities of high-risk sectors. Rather than relying on a one-size-fits-all checklist, the Code places responsibility on businesses to assess their unique risks of fatigue. That means accounting for factors like:

• Lengthy shifts, rosters and extended commutes
• Long or irregular shifts that disrupt natural sleep cycles
• Critical tasks performed during circadian low points (3–6 am, 2–4 pm)

Summary feedback received by SWA on the draft code suggests stakeholders want a code that reflects real-world operational constraints, provides clear guidance for balancing risk with compliance, and allows cross-sector flexibility.

Controls may include restructured rosters, fatigue monitoring technology, limiting high-risk tasks during periods of reduced alertness (e.g. 03:00-06:00), the use of biomathematical modelling, education and health promotion. Importantly, the Code and current research encourage the continuous review and evaluation of controls, ensuring that strategies adapt as operations evolve ^(4,5,6,7).

For industries across the board, from mining, oil, and gas, to transport, healthcare, construction and beyond operations, the risk-based approach is a transformative step forward, as it provides ⁽⁸⁾:

• Risk management flexibility
• Businesses can tailor fatigue controls to their operational demands
• Safer, more innovative scheduling – with proactive measures to prevent fatigue-related errors before they occur
• Legal clarity – the Code sets a benchmark for compliance and due diligence

While designed with safety-critical sectors in mind, the Code remains flexible for use in various industries, including agriculture, healthcare, emergency services, transportation, and more. Its four core pillars —identify, assess, control, and review—still apply across industries, but its risk-based design makes it far more potent for safety-critical operations ⁽³⁾.

From Adherence to Culture

The upcoming Code signals a shift from merely following guidelines and rules to fostering a proactive health and safety culture, where fatigue isn’t just managed but is strategically and proactively controlled. For all industries, this translates to fewer fatigue-related incidents, a sharper focus, and healthier, more alert, and capable teams ⁽⁹⁾.

At Melius Consulting, we specialise in helping businesses navigate evolving health and safety challenges such as sleep health and fatigue management. Our fatigue risk management solutions are proactive and tailored to ensure your teams are work-ready, alert, and aligned with the upcoming Model Code of Practice. From risk assessments and roster design to fatigue technology reviews and advice, biomathematical modelling, and compliance and best practice reviews and training, we provide the expertise to keep your operations healthy, safe, efficient, and future-proof.

Contact Martha.Cavanagh@melius.com.au or info@meliusconsulting.com.au to learn more.

References

1. Paterson, J., Ferguson, S., & Dawson, D. Fatigue. In The Core Body of Knowledge for Generalist OHS Professionals. 2020. 2nd Ed. Tullamarine, VIC: Australian Institute of Health and Safety.
2. Banks S, Landon LB, Dorrian J, Waggoner LB, Centofanti SA, Roma PG, Van Dongen HPA. Effects of Fatigue on Teams and Their Role in 24/7 Operations. Sleep Med Rev. 2019 Dec;48:101216. https://doi.org/10.1016/j.smrv.2019.101216
3. Safe Work Australia (SWA). Rapid Review on Evidence of Managing the Risks Associated with Fatigue. 2024. Safe Work Australia (SWA).
4. Honn KA, Van Dongen HPA, Dawson D. Working Time Society consensus statements: Prescriptive rule sets and risk management-based approaches for the management of fatigue-related risk in working time arrangements. Ind Health. 2019 Apr;57(2):264-280. https://doi.org/10.2486/indhealth.SW-8
5. Horberry TJ, Harris J, Way K, Hill A, Lim N, Dodshon P, Lee J, Cliff D. Fatigue Management in the Queensland Mining Industry and its relationship with Mental Health. 2023. Queensland Government Publication.
6. Bauerle TJ, Sammarco JJ, Dugdale ZJ, Dawson D. The human factors of mineworker fatigue: An overview on prevalence, mitigation, and what’s next. Am J Ind Med. 2022 Nov;65(11):832-839. https://doi.org/10.1002/ajim.23301
7. Wong IS, Popkin S, Folkard S. Working Time Society consensus statements: A multi-level approach to managing occupational sleep-related fatigue. Ind Health. 2019 Apr;57(2):228-244. https://doi.org/10.2486/indhealth.SW-6
8. Gurubhagavatula I, Barger LK, Barnes CM, Basner M, Boivin DB, Dawson D, Drake CL, Flynn-Evans EE, Mysliwiec V, Patterson DP, Reid KJ, Samuels C, Shattuck NL, Kazmi U,  Carandang G, Heald JL, Van Dongen HPA. Guiding principles for determining work shift duration and addressing the effects of work shift duration on performance, safety, and health: Guidance from the American Academy of Sleep Medicine and the Sleep Research Society, Sleep. 2021 Nov;44(11):zsab161. https://doi.org/10.1093/sleep/zsab161
9. Sprajcer M, Thomas MJW, Sargent C, Crowther ME, Boivin DB, Wong IS, Smiley A, Dawson D. How effective are Fatigue Risk Management Systems (FRMS)? A Review. Accid Anal Prev. 2022 Feb;165:106398. https://doi.org/10.1016/j.aap.2021.106398