Identifying and Reducing Workforce Fatigue in Rapid Renewal Projects (2014)

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32 Fatigue Countermeasures A principal objective of the project was to identify promising fatigue countermeasures from the set of tools identified through literature review, for implementation in the rapid renewal environment through fatigue risk management plans and programs. Appendix C describes the detailed analysis of individual fatigue countermeasures identified and assessed in the review. This chapter integrates those findings in terms of the practical issues associated with deployment and implementation. The review of literature concerning fatigue counter­ measures identified 18 potential tools, which have been categorized as preventive or operational, as shown in Table 4.1. Preventive countermeasures are used to “maximize general alertness” and tend to be used in off­work settings. Operational countermeasures are employed in the actual work setting to mitigate the effects of acute fatigue. The counter­ measures were reviewed in terms of the evidence supporting the impact on worker fatigue and performance, and in terms of their potential applicability in the highway construction environments the team observed during field work. Factors considered included demonstrated impact on sleep and performance, the extent to which laboratory stud­ ies can be generalized and/or implemented in field settings, the existence of field studies, enhancement of worker knowl­ edge, and the overall preponderance of evidence and clinical experience. There have been relatively few “pure” field studies of fatigue countermeasures in the traditional experimental design model. Instead, much material is based on labora­ tory studies of controlled sleep duration, simulated perfor­ mance tests, and field studies of fatigue reports or error in shiftwork populations. Thus, countermeasure recommen­ dations are usually a result of synthesis of clinical experi­ ence, observation of trends, abstract experimental studies, and model­based sleep/wake regulation and circadian rhythm principles. The result is a list of fatigue counter­ measures categorized according to a general “effectiveness” metric, which combines the team’s assessment of the strength of evidence concerning impact on fatigue and performance, the duration of that impact, and the likelihood of application and adoption in the highway construction environment. This latest aspect is essentially a judgment based on applied research and engineering knowledge and is meant to reflect the practical aspects of countermeasure application. An additional classification for a number of counter­ measures is “limited evidence or implementation complex­ ities.” The team uses this category for countermeasures that should work, in principle, but involve considerable techni­ cal complexity for implementation, have not been shown to impact fatigue or performance empirically, or entail medi­ cal supervision such as hypnotics and stimulants. Among the 18 fatigue countermeasures identified, the team’s evaluation suggests that nine of them have potential near­term applicability in the rapid renewal environment, comprising those tools in the “generally effective category.” Additionally, the team believes two of the techniques in the “less effective” category warrant consideration for implemen­ tation: exercise and self­ and peer­monitoring. Although exercise does not lead to prolonged fatigue reduction, it may serve to remove severely fatigued workers from the opera­ tional task and thus function as a rest break. Self­ and peer­ monitoring may not be as reliable an indicator as desirable, but it is unlikely to cause problems, and may identify poten­ tially unsafe work practices. Issues of Responsibility in Fatigue Risk Management Fatigue risk management can be considered the responsibility of three levels or entities: (1) regulators, (2) industry/company, and (3) individual (Gander et al. 2011). Mature fatigue risk management programs rely on cooperative interaction between these levels, using appropriate communication, monitoring, and fatigue reduction tools. C h a p t e R 4

33 The Occupational Safety and Health Administration does not address work hours, with the exception of minors and overtime pay requirements. At the state level, companies operate under the requirements of state occupational safety and health agencies, which do not address issues related to working hours or fatigue. While a comprehensive review of state and federal requirements for fatigue management was not specifically required in this project, the team’s selective review suggests that fatigue training and incident reporting is not mandatory, and the incident reporting protocols for state safety agencies do not collect information that pertains to work schedule, prior sleep–wake assessment, or other factors related to fatigue. State DOT contracting offices do not con­ sider work scheduling in selection of proposals for award, and state­level inspection is focused on construction work qual­ ity; worker fatigue would need to be extremely egregious for inspectors to observe this and take corrective action. At the level of industry and company, the team has found no information to suggest that fatigue is addressed in a sys­ tematic way across the highway construction sector. Searches of trade journals and industry association websites did not reveal anything to suggest that worker fatigue is considered a fundamental safety problem. Similarly, the guiding docu­ ment for road construction zone safety practices, the Manual on Uniform Traffic Control Devices (FHWA 2009) does not con­ tain any material addressing worker fatigue. Further, the results of the team’s field data collection suggest that, at the company level, fatigue is considered as a general hazard of the job but not one addressed with systematic safety management processes. There is general concern about productivity of crews in rela­ tion to scheduling, but this appears to be more of an economic than a safety concern. SME interviews indicated that manage­ ment considers being well rested and able to perform as an individual responsibility, within the parameters of work scheduling. Individual responsibility for managing fatigue is an area that has not received much attention in the research litera­ ture. Review studies of demographics (Di Milia et al. 2011) have shown little in the way of systematic relationships between variables such as sex, age, job type, and so forth. Commuting distance has been shown to affect the amount of sleep people get. This may be an area of personal responsibil­ ity that could be addressed by contractors in assembling crews for specific jobs, by selecting people who live within a reasonable distance. More generally, the issue of personal responsibility for managing fatigue relies upon (1) knowledge of the worker about the factors contributing to fatigue and how to mitigate it, (2) the opportunity to obtain adequate sleep, and (3) taking advantage of the opportunity to obtain adequate sleep. Knowledge is an area that can be addressed through systematic education of workers; sleep opportunity can be addressed by schedule analysis and modifications as necessary. Actually taking advantage of the opportunity for adequate sleep is a complex lifestyle issue and depends upon workers being able to manage other aspects of their living patterns in order to prioritize the sleep opportunity and use it effectively. This would involve placing sleep at the top of the priority list among the many demands of the off­work period, such as family responsibilities, and the other activities of daily living such as food shopping and preparation, laundry, home maintenance, socializing, and so forth. Levels of Defense in Fatigue Risk Management In the research literature, conceptualization of fatigue risk management is based on multiple layers of defense. Gander et al. (2011) summarize the layers as follows: • “Level 1 defence involves providing adequate opportuni­ ties for sleep, including recognising the importance of the placement of sleep opportunities with respect to the cir­ cadian cycle. This is the level partially addressed by tradi­ tional HOS regulations. • “Level 2 involves processes for confirming that adequate sleep is obtained. • “Level 3 involves processes to detect and prevent behavioural symptoms of fatigue. Table 4.1. Fatigue Countermeasures Classified by Type and Judged Level of Effectiveness and Implementation Complexity Impact Countermeasure Type Preventive Operational Generally Effective • Adequate Sleep • Defensive Napping • Good Sleep Environment • Limiting Overtime and/or Work Sched- ule Modification • Caffeine • Napping • Anchor Sleep • Rest Breaks • Fatigue Education Less Effective • Diet • Temperature and Ventilation • Self- and Peer- Monitoring • Exercise Limited Evidence or Implementation Complexities • Hypnotics or Stimulants • Model-Based Schedule Optimization • Fatigue Risk Man- agement System • Worker Status Monitoring and Alerting Technologies • Bright Light or Melatonin for Cir- cadian Shifting

34 • “Level 4 involves processes for detecting fatigue­related errors. • “Level 5 involves processes for investigation of fatigue­ related incidents and accidents” (Gander et al. 2011). Although many early hours­of­service rules were based more on operational experience and common sense than on research­based findings, the levels of defense classification scheme described here appears to assume that there is an adequate knowledge base of information concerning fatigue and circadian rhythm effects on worker performance. While this assumption may be correct in the highly regulated trans­ portation industries because of the considerable research and development devoted to fatigue in these domains, it does not necessarily apply to the highway construction industry. Thus, the team proposes an enhancement to the Levels of Defense model to include the following: • Level 0 involves fundamental education and training on sleep and fatigue effects upon work performance, the importance of adequate sleep to avoid these effects, and various other prevention and mitigation techniques (countermeasures). For Level 2, confirming that adequate sleep has been obtained, Dawson and McCulloch (2005) focus on the use of PSWM on the basis of reported sleep obtained. Level 2 defenses are essentially treated as an organizational element to deter­ mine that the sleep opportunity provided by Level 1 defense is being acted upon appropriately. However, in considering the responsibility elements, it is reasonable to expand the defi­ nition of Level 2 to include individual checks on sleep obtained—basically information provided to the individual through training to ensure that fatigue countermeasures are properly applied. The 11 countermeasures that the team judges to have near­ term applicability in the highway construction environment are categorized within this taxonomy in Table 4.2. Field Research Findings on Countermeasures The team’s field research results suggest some, but not all, of these measures are implemented in a somewhat informal manner in highway construction companies. For example, fatigue training was reported, although not illustrated, by about half the respondents. It is unclear, however, as to the specific content of this training. Similarly, for Level 1 defenses of ensuring an adequate sleep opportunity by limiting over­ time or schedule modification, the team’s field research indicates that project labor agreements tend to influence the maximum number of hours per day, in combination with superintendents’ heuristics as to acceptable levels of produc­ tivity. Level 2 defenses of confirming that adequate sleep is obtained do not appear to be implemented. Management did not report using techniques such as prior sleep–wake assess­ ment, and workers did not report strategies for ensuring the priority of sufficient sleep. Some Level 3 defenses are imple­ mented on an individualized basis—for example, caffeine tends to be brought to the job sites by individual workers and Table 4.2. Levels of Defense in Fatigue Management and Applicable Near-Term Countermeasures Level of Defense Countermeasures Current State of Implementation Level 0–Education and Training • Fatigue education program for highway construction contractors • Training reported; content and quality not available for assessment Level 1–Ensuring adequate sleep opportunity and proper placement within the circadian cycle • Limiting overtime and/or work schedule modification • Project labor agreements and superintendent heuristics • Job requirements may supersede usual practice (e.g., closures, need for work to task completion) Level 2–Confirming that adequate sleep is obtained • Obtaining adequate sleep • Good sleeping environment • Defensive napping • Anchor sleep • No formal reporting or assessment • Variable level of knowledge among workers Level 3–Processes to detect or prevent behavioral fatigue • Napping • Caffeine • Rest breaks • Exercise • Self and peer observation • Informal implementation of selected measures Level 4–Processes for detecting fatigue- related errors • Self and peer observation • No data Level 5–Processes for investigation of fatigue-related incidents and accidents • N/A • N/A

35 rest breaks are taken as needed—primarily in relation to hydration. Napping is not generally sanctioned, and self or peer observation was not reported. Workers do report being able to get up and move around should they need to, which constitutes a form of exercise that may have a brief alerting function. Level 4 defenses involve detecting fatigue­related errors and are often associated with concepts of technologi­ cal monitoring that are still in the research phase. Self­ and peer­monitoring, however, can be used as a means to verify critical actions, and it has been suggested that this approach has contributed to the success of medical work­hour changes (Landrigan et al. 2004). Detailed descriptions of the countermeasures listed in Table 4.2 are provided in Appendix C. Each of the counter­ measures has an appropriate application and should be imple­ mented in a systematic manner in order to ensure optimal benefits. The current approach of informal training and ad­hoc application of countermeasures may provide the appearance of attention to the fatigue problem without addressing it in a sys­ tematic and continuing way. The following section discusses the key issues associated with implementing more formalized approaches to fatigue management in the highway construction industry and suggests a path forward. Implementation of Fatigue Countermeasures in Rapid Renewal highway Construction Motivations The key challenge in implementing fatigue countermeasures in the highway construction industry is the lack of an economic framework that raises the issue to the level of a critical safety problem. Compounding this issue is the problem of a very wide range of organizations engaged in highway construction. They can range from relatively small companies to large joint ventures formed for the purpose of specific mega­projects. Organizational safety culture is a related issue. Although the team has not conducted a detailed assessment of highway construction safety culture, the team is reasonably confident that most contractors working in highway construction may be thought of as having a “compliance culture.” That is, the safety function is established at a level to address the most frequent and tangible safety elements, such as traffic incur­ sions or slips and falls, without mechanisms to identify and mitigate various “latent” problems, such as fatigue related to weekend closures that could lead to accidents and injury either on the job or during the commute home. The nature of the industry and the safety problems it engenders is another consideration. All of the industries asso­ ciated with regulatory approaches to work­hour limitations tend to have substantial public safety aspects. For example, airline pilots are responsible for hundreds of lives aboard their aircraft; nuclear power plant operators are indirectly responsible for the safety of the public in wide geographic areas surrounding the plants they control; commercial truck drivers sometimes haul hazardous material and crashes of non­hazardous loads can injure or kill numerous others. Commercial ship crews are responsible for marine traffic safety and environmental integrity. Each of these industries is regulated at the federal level by work­hour limitations and many of the industries, particularly airlines, are leaders in the implementation of fatigue risk management systems. The domestic and international political climate has shifted considerably over the past generation in such a way as to empha­ size markets, privatization, and deregulation, in contrast with earlier periods of industrial regulation. In the United States, implementation or enhancement of work­hour limitations in selected industries is a countervailing trend and is advocated typically by safety and labor organizations, often in response to highly publicized events resulting in significant casualties or damage. Examples include the work­hour restrictions intro­ duced by the Oil Pollution Act of 1990 in response to the Exxon Valdez crash and work­hour limits placed upon nuclear power plant operators by the Nuclear Regulatory Commission in rela­ tion to fitness­for­duty concerns. Fatigue risk management systems are a potential alterna­ tive to prescriptive hours­of­service rules that would permit individual organizations more flexibility in conducting opera­ tions. This essentially involves adopting a risk­based approach to fatigue management that addresses work circumstances on a more individualized basis. It can permit organizations to analytically demonstrate to regulators either the rationale for exception to existing work­hour limits or to show regulators that existing work­hour limits are unnecessary in a currently unregulated industry. Fatigue risk management systems and modeling also are sometimes adopted by small subset inno­ vator organizations to enhance worker safety (Dawson et al. 2011). It is this latter approach that is most likely to be effec­ tive in the highway construction industry, by focusing on companies and industry organizations that are trying to anticipate change and respond appropriately. As the team dis­ cusses in the following section, market analyses suggest that rapid renewal practices will increase over the next 10 years, and tens of thousands of workers and managers will be engaged in work that has increased risk for fatigue. The follow ing sec­ tion discusses a general approach for organizations to antici­ pate and respond to the likely problem of increasing fatigue risk factors in their business. Risk-Based Approach to Fatigue Management and Fatigue-Proofing The implementation of fatigue risk management will need to be carried out on an individual organizational basis, within

36 the parameters of guidance established by a credible body. A number of such guidance documents exist today, one of the most comprehensive being that developed for Transport Canada civil aviation by McCulloch and colleagues (McCulloch et al. 2007; see http://www.tc.gc.ca/eng/civilaviation/standards/ sms­frms­menu­634.htm). Much of this guidance material is quite detailed and of general applicability, although there is a substantial aviation component. The team’s experience in the field research, however, suggests material of this type is unlikely to be accessed and adapted by individual contractor safety personnel. There is simply too much of it, and they do not have the training or experience to knowledgably modify the material to their specific circumstances. Instead, the team foresees a need to (1) raise awareness of rapid renewal fatigue risk factors and potential consequences within the workforce, (2) develop simple risk assessment methods that can be applied to individual projects and work schedules, (3) provide contextualized fatigue training material to increase organizational and individual understanding of fatigue risk factors, countermeasures, and roles and responsi­ bilities, (4) develop simple evaluation methods for assessing the application of countermeasures, and (5) identify potential methods to reduce the likelihood of fatigue­related error (“fatigue­proofing”). At this point, the team sees no utility in addressing project selection, since the team’s field research indi­ cated that work scheduling is not considered in the state DOT award process, and attempting to implement this approach would encroach upon the safety responsibilities of state occu­ pational safety and health agencies. The main phases of implementation of fatigue risk manage­ ment in the rapid renewal highway construction industry are as follows: • Awareness of risk factors and motivation to mitigate them. • Assessment of risk factors for specific project operations. • Development and implementation of fatigue training for workers and managers. • Development of methods for monitoring and assessing risk factors and countermeasures, and • Identification of fatigue­proofing strategies for specific operations. Each of these elements is discussed in the following sections. Fatigue Risk awareness Fatigue risk awareness appears to be present in the stakeholders the team has surveyed, although it does not appear to be par­ ticularly salient as a worker safety issue. Thus, an initial phase of fatigue risk management implementation is to ensure the problem is properly understood as an enhanced risk associated with rapid renewal construction practices—an issue that goes beyond those typically encountered by shift workers. Risk awareness is a process that needs to be undertaken at the industry sector level, within state DOTs, and with individual contractors. The team believes that a key element of this pro­ cess is an appropriate dissemination pathway, a means of pro­ viding information to stakeholders through a recognized and respected authority within the construction industry. This will help to establish credibility. Fatigue risk awareness can be raised through a variety of dis­ semination pathways, including the American Association of State and Highway Transportation Officials, the National Coop­ erative Highway Research Program, and the Association of General Contractors. Each of these organizations holds meet­ ings at national, regional, and local levels that would be appro­ priate for presenting fatigue awareness briefings. Additionally, outreach material provided through the organizations to con­ stituent members would facilitate awareness. A critical issue for this process is identifying the most appropriate dissemination pathway(s), and then defining outreach material based on cur­ rent communication approaches. Fletcher et al. (2005) review approaches to driver fatigue awareness campaigns and suggest fatigue should have parity with other safety concerns, such as drinking and driving, speeding, and so on. A similar approach could be taken in the highway construction industry. project-Specific Fatigue Risk Scenarios Since highway construction is project­based and episodic, that is, there are different activities scheduled for different times, it is important to develop a range of scenarios for worker scheduling based upon the major risk factors. This is likely to incorporate variants of the major risk factors, such as 55­h closures, extended shifts, and others. Operational exigen­ cies dictate the need for these types of schedules, and general guidance may be of limited use in any particular set of circum­ stances. Therefore, it is appropriate to develop a set of articu­ lated risk scenarios corresponding to some of the most common situations that contractors may have to address on an ad­hoc basis. This might include the unexpected need for double shifts, shifting to night shifts with no intervening day off, extended numbers of sequential days following a closure, over­ seeing closure work by salaried personnel not subject to hourly labor agreements, and so forth. Fatigue risk analysis via PSWM and countermeasure alternatives can be used to characterize these scenarios and is illustrated in the following chapter. Contextualized training for Workers and Managers An understanding of the fundamental nature of sleep loss, cir­ cadian rhythm, fatigue, performance impacts, and amelioration strategies is a key element of both preventive and operational

37 probably be aimed at building confidence in the utility of the fatigue risk management approaches through other means. This might include informally surveying personnel about their knowledge of fatigue fundamentals, how well certain countermeasures work for them, and their ideas for program enhancement. Specific tests of knowledge related to training programs can be developed, based on material already available, such as that for Transport Canada. Care must be taken, however, not to portray the assessments as potentially punitive, and reactions regarding questions of sleep obtained need to be monitored for concerns related to privacy. Fatigue-proofing Strategies Most of the discussion of fatigue tends to focus on fatigue reduction through interventions that provide greater oppor­ tunities for recovery sleep. Safety management systems theory and practical experience, however, indicate such controls will not always be effective. Either because of project work require­ ments or schedule risks that are considered acceptable, there will be situations in which fatigued workers are at work (Dawson et al. 2012). In these situations, risk reduction is handled by “reducing the likelihood that a fatigue­related error will cause an accident or injury” (Dawson et al. 2012). This approach is referred to as “fatigue­proofing” and can be considered an approach to fail­safe operation. Dawson et al. (2012) suggest that fatigue­proofing tech­ niques are in common use, but tend to be hidden as “implicit elements of the safety system” that have evolved with work practices. They illustrate a number of examples from the maritime, aviation, health care, and power industries that involve approaches such as verbal call­backs of commands, additional preparation for critical operations, repetition and confirmation of instruction, and use of higher levels of team jocularity during early morning work. In this latest example, individuals who are more irritable or unresponsive tend to be fatigued and are assigned lower­risk tasks. The common themes in these examples are the pre­signaling of higher risk and a higher level of scrutiny for potential error. This is communicated to other individuals, so the result is greater team situational awareness and error scrutiny. Identi­ fication and development of these types of strategies during extended work periods for highway construction is warranted, since fatigue reduction by means of schedule adjustments may not always be feasible. approaches to reducing fatigue. Education and training formed the basis of the highly successful NASA fatigue countermea­ sures program and over time led to a fundamental change in culture and philosophy regarding fatigue, both at the worker and management level. Education is a basic element of current approaches to fatigue risk management systems and can help to overcome widely held misconceptions about the nature of the problem and ways to deal with it. While important as a fundamental component in fatigue management, translation of existing scientific knowledge into usable programs for employers and workers is not straight­ forward. The interviews with management SMEs suggested that fatigue is a topic of concern, and that there is some cover­ age of the topic in company safety training. The results of the interviews, however, yielded no material that would allow for assessing the quantity or quality of the training. The single source the team reviewed, “toolbox talks,” yielded some rela­ tively cursory material that was not contextualized to the rapid renewal environment. Educational programs could be imported and adapted from transportation industries such as commercial aviation. Comprehensive and contextualized training about fatigue for the rapid renewal environment will need to address the risk factors and operational constraints specific to this work domain. These include long shifts, occasional double shifts, rapid switch to night work from day work, and continuous weekend closure effects upon sleep opportunity. Now there are no standards to guide contractors in their selection of consultants or material for fatigue training, nor is there a well­developed information dissemination pathway. This may be an appropriate role for industry association groups, which have established training material and guidance for other areas of safety concern. assessment Methods and Metrics A legitimate question concerning any new technique imple­ mented in organizations is “how can we tell if it is working?” An ideal evaluation would involve longitudinal data collec­ tion from groups working identical projects and schedules, with and without fatigue management techniques. Data for such an evaluation would range from knowledge comprehen­ sion to measured sleep obtained and safety impacts on the job. Practically, however, this will not happen in the rapid renewal construction environment, and so evaluation should