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  • ACOEM Comments on CSB Evaluation of Fatigue Risk Management Systems

    April 9, 2013

    Chemical Safety and Hazard Investigation Board
    Office of Congressional, Public, and Board Affairs
    2175 K Street, NW, Suite 650
    Washington, DC 20037
    Attn: D.Horowitz

    To Whom It May Concern:

    The American College of Occupational and Environmental Medicine welcomes the opportunity to comment on the Chemical Safety Board’s draft evaluation of the American Petroleum Institute (API) and the United Steelworkers International Union (USW) jointly lead development of an ANSI consensus standard with guidelines for fatigue prevention.

    ACOEM, an organization of more than 4,000 occupational physicians and other health care professionals, provides leadership to promote optimal health and safety of workers, workplaces, and environments.

    ACOEM recognizes the important role of fatigue management in maintaining a safe and healthy workforce. For this reason, in February of 2012, ACOEM published a guidance statement entitled Fatigue Risk Management in the Workplace. This Guidance Statement notes that “Employee alertness depends not only on how many hours worked but also on a variety of other factors including: 

    • what one does at work;
    • when one is at work (relative to the individual’s circadian rhythm);
    • whether the work environment promotes alertness or fatigue;whether there are mechanisms in place to detect excess fatigue;
    • whether one obtains adequate sleep during time off or uses that time for other purposes;
    • whether one has a sleep environment that promotes high-quality restorative sleep; and
    • whether one has emotional, physical, or medical issues that interfere with high quality restorative sleep.”

    Because of the multifactorial nature of fatigue risk, no one solution, including Hours of Service (HOS) Guidelines, is sufficient to adequately mitigate that risk. For this reason, ACOEM advocates the use of a Fatigue Risk Management System (FRMS).

    “Although several of these factors are under the control of an employer, others are not. Thus, it is critical to enlist the entire workforce as active partners in managing risk associated with fatigue. Increasingly, industry and regulators are moving away from pure hours-of-service standards toward comprehensive FRMSs designed to promote alertness, minimize fatigue, identify evidence of excess fatigue, and mitigate either the fatigue itself or its potential consequences.”(ACOEM Guidance Statement, Fatigue Risk Management in the
    Workplace).

    ACOEM advocates that employers take direct steps to address those factors under their control such as the work environment and HOS. For other matters, the employer should work to motivate and educate the workforce to take steps to maximize their alertness on the job. They should also strive to foster a culture in which employees feel empowered to raise fatigue-related issues.

    The ANSI standard, RP-755, utilizes the FRMS approach outlined and advocated in ACOEM’s guidance statement, Fatigue Risk Management in the Workplace. We do not agree with CSB staff that: “The document places undue emphasis on “soft” or “personal” components of fatigue control, such as self-evaluation by employees, evaluation by supervisors, and training and education, without supporting scientific evidence of their efficacy.”

    Rather, ACOEM finds RP-755 to be a noteworthy standard that incorporates the components of an FRMS. Those components that CSB staff refer to as “soft” or “personal” are no more or less critical to the success of the FRMS than any others.

    Thank you for your consideration of our comments. Please do not hesitate to contact me or Pat O’Connor, ACOEM’s Director of Government Affairs at 202-223-6222, should you have any questions regarding the concerns outlined above or this matter in general.

    Sincerely,

    Karl Auerbach, MD, MS, MBA, FACOEM
    President