Ninth Asia-Pacific Heads of Maritime Safety Agencies Forum. Chile April 2006 AGENDA ITEM 5:SAFETY OF PEOPLE TARGETTING SEAFARER FATIGUE

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1 Ninth Asia-Pacific Heads of Maritime Safety Agencies Forum Chile April 2006 AGENDA ITEM 5:SAFETY OF PEOPLE TARGETTING SEAFARER FATIGUE Introduction Maritime worker fatigue is a known initiating and contributing cause of accidents. It is also implicated in workers health. Fatigue, therefore, is a safety management and a health and safety issue requiring the active involvement of Maritime New Zealand, operators and maritime workers. Accordingly, Maritime New Zealand is pursuing a maritime worker fatigue programme to reduce the incidence of fatigue-related accidents. There are two elements to the programme: new initiatives and business as usual. The new initiatives involve: developing a range of educational and advisory materials for use by industry participants; training relevant people in the use of these materials, particularly industry advisers; and integrating fatigue management into safety management systems where fatigue is a significant hazard. The business as usual comprises the existing legislative interventions ranging over manning levels, seafarer medical fitness, prescribed minimum rest periods, and minimum standards of crew accommodation and catering. The programme is described in this paper, along with a summary of what is known and not known about the incidence of fatigue-related accidents. What Is Fatigue? According to the International Maritime Organisation, fatigue is a reduction in physical and/or mental capacity as a result of physical, mental or emotional exertion. It may impair a wide range of capacities such as strength, speed, reaction time, coordination, decision-making and balance. Doc ID

2 Fatigue is an attribute of the human constitution and an inevitable consequence of working in circumstances that lead to conflict with certain hard-wired capacities and requirements, including the brain s need for sleep, the body s limited capacity for hard physical activity, and a body rhythm that s programmed for wakefulness during the day and sleep at night. Maritime work can cut across a number of these biological imperatives: it is often physically and mentally demanding, and in some cases involves 24- hour operations that call for shift work; and in operations where seafarers live on board, the environment is frequently not ideal for restorative sleep. Furthermore, these demands and limitations are combined with an inherently hazardous environment where a fatigued response can have significant consequences in terms of harm to human life, ships and the marine environment. How Big is the Problem? The extent to which fatigue is a hazard and a contributor to maritime accidents can be gauged from accident databases and maritime worker surveys. Survey results A 2003 Maritime NZ survey of seafarers on all classes of ship, commercial river jet boat drivers and raft guides reported that: 25 percent consider fatigue a significant issue 43 percent regularly work more than nine hours in a day, with 55 percent working into scheduled breaks 35 percent of those reporting fatigue as an issue only occasionally or never recovered from fatigue during the course of the voyage 21 per cent reported seeing other workers have accidents while fatigued, compared to 8 percent having themselves had an accident while fatigued. Accident data Overseas databases and studies indicate seafarer fatigue as a significant initiating cause and contributing factor in accidents. A recent analysis of accident databases from three jurisdictions indicates that fatigue played a greater or lesser role in some 70 percent of instances of human element error, which in turn were implicated in some per cent of total maritime accidents. Over the last ten years, investigation of commercial vessels accidents in New Zealand has identified seafarer fatigue as a factor in a number of cases, either as an initiating cause or a contributing factor. Most frequently, fatigue has been implicated in the grounding of small ships (some twenty instances on file), most involving small inshore fishing vessels. The common theme is a single fatigued watchkeeper falling asleep, and the loss of awareness in the wheelhouse of the proximity of land. The other crew members were also asleep. All had worked for long periods with little or no Doc ID

3 recovery time. Typically, in these cases, there is little evidence of systematic planning of voyages and watchkeeping schedules. The consequences of these fatigue-related vessel groundings have been limited to property damage (vessel loss/damage), and environmental harm. None resulted in harm to people, but the potential for serious harm was present in many cases. In the UK and USA, where such accidents are more numerous, this type of accident has resulted in fatalities. This suggests that the absence of harm to individuals in New Zealand may be a case of good fortune and a function of the relatively small number of groundings in this country - the implication is that any similar events in future will sooner or later realise the potential for serious harm. The data for personal injury accidents on board vessels in New Zealand do not allow fatigue-related causes to be readily identified. This is a gap in our knowledge. It may be a serious one - in at least one other jurisdiction (USA), fatigue is implicated in twice the proportion of personal injury accidents as vessel accidents. The application of human element analysis in accident investigation (both vessel and injury) is a developing art (part of the Maritime New Zealand programme is to provide training to investigators in this area) and future investigations in New Zealand should more accurately identify fatigue as a factor in accidents. Legislative Requirements Legislative instructions bearing on fatigue provide for: safe manning of ships. Rules require a ship-specific assessment of SOLAS and certain ships under safe ship management to determine safe manning. The assessments are required to be submitted to the Director, who, if satisfied that a proper assessment has been made, issues a safe manning document specifying the number of crew required in each position on board. One element of the assessments takes into account the need to ensure crew in safety sensitive positions are not fatigued at the commencement of duties and are rested before fatigue becomes a significant hazard; minimum standards of crew accommodation and catering. The latter requirements are set out in the Maritime Transport Act and derive from ILO conventions to which New Zealand is party. Crew accommodation requirements for SOLAS ships, again, based on ILO standards, are set out in maritime rules. Rules for crew accommodation on other ships (ships covered by safe ship management systems) are set out in the applicable rules dealing with the design, construction and equipment of ships; minimum hours of rest for seafarers for crew assigned to navigational and engineering watches on board ships (other than fishing ships) greater than 45 metres in length proceeding beyond restricted limits. These requirements, found in maritime rules, apply to SOLAS ships Doc ID

4 and derive from the international convention on standards of training, certification and watchkeeping; certificates of medical fitness for certain seafarers. The requirements, set out in rules, are derived from the ILO and IMO instruments. The certification, issued by Maritime New Zealand approved medical practitioners using ILO/IMO guidelines, is required by: o young persons under 18 years of age working on a New Zealand ship in any capacity at sea outside restricted limits, and any such person engaged to work at sea in New Zealand o all seafarers on New Zealand SOLAS ships; and training/education of seafarers in human element issues, including fatigue. These requirements are found in training syllabuses approved by the Director under rules. The training is for crews on SOLAS ships. They reflect requirements from the international convention on standards of training, certification and watchkeeping. In the case of able seamen, the fatigue component in the training syllabus was inserted at the initiative of Maritime New Zealand. Broad legislative requirements to manage safety and hazards also bear on fatigue. Two such requirements are particularly relevant: health and safety legislation (which applies to ships and is administered by Maritime New Zealand) specifically defines fatigue as a hazard. Thus defined, the employer is duty bound to consider whether it is a hazard to employees in his operation and, if it is significant, to take all practicable steps to manage it; and safety management requirements in maritime rules require operators to develop safety systems that provide safeguards against all identified risks including, by implication, fatigue. These requirements apply equally to ships covered by the international safety management requirements under the SOLAS convention and to ships covered by the New Zealand safe ship management code. These broad requirements provide the legislative basis for taking fatigue management on board New Zealand ships beyond business as usual. Fatigue Policy The broad policy objective is to achieve the effective management of fatigue in the New Zealand commercial maritime fleet through the use of existing safety management frameworks. A key assumption is that the fatigue programme can only be as effective as the existing safety management systems allow it to be. These systems are New Zealand s health and safety legislation and the safety management requirements in maritime rules. In particular, the fatigue programme is designed to take advantage of the revised approach to safe ship management. Doc ID

5 The safety management systems are risk-based approaches to legislation that allow operators a flexible approach to achieving a safety objective. Key Relationships and Roles The safety management approach used in New Zealand requires all sections of the maritime community to be actively engaged for the fatigue management programme to work. The principal participants are: vessel owners or operators masters and crews of vessels Maritime New Zealand safe ship management companies industry organisations industry advisers maritime training schools These are supported by university based fatigue experts. Maritime New Zealand has the overarching role of leading the other system participants to achieve the objective. Details of the roles each of the above are set out in below: Sector Advisory Groups Schools Maritime Training The vessel: owners, skippers, crew, shore support staff Maritime New Zealand/ Safe Ship Management Companies Industry Advisors The programme recognises that vessel owners require short, to the point material. It is expected that most vessel owners will also use safe ship Doc ID

6 management companies and industry advisers to assist them develop fatigue management plans. The roles of each of the above are: Industry sector groups o To identify fatigue risks in the industry sector and propose ways to mitigate them. o To propose minimum standards for fatigue-related safety practices o To write the sector fatigue guidelines Maritime training schools o To develop teaching fatigue related material for maritime qualifications o To teach and examine for fatigue knowledge o To run general industry seminars on fatigue for industry (voluntary basis) Maritime New Zealand/safe ship management companies o To set clear expectations as to what is required o To approve fatigue management plans o To audit the operation of fatigue management plans o To provide advice to vessels and individuals o To provide access to outside experts, when required. o To set syllabus requirements for fatigue related knowledge, in maritime Industry advisers o Provide advice to individual vessels o Provide advice to individuals o Encourage vessels to adopt a good standard of practice toward fatigue identification and management o Run industry seminars Maritime NZ Fatigue Work Programme The New Zealand maritime industry is regulated according to types of vessels. In developing the work programme, priority areas were identified to form the basis of the materials and other interventions. Based both on the relative numbers of vessels in the safe ship management sector and an identified fatigue-related accident problem, especially in the fishing industry. The focus of the work programme to date has been on vessels in the safe ship management sector. Having acknowledged that, it is expected that the materials produced will, with minor adjustments, be suitable for the other sectors. Doc ID

7 1 Safe Ship Management (SSM) Programme context All domestic commercial vessels (excluding SOLAS vessels) are required to be part of a safe ship management system, which is not dissimilar to the ISM Code referred to below. The Director of Maritime NZ delegates the running of the SSM system to approved SSM companies. Changes are being made that will make consideration of fatigue and its safety implications as an explicit requirement in the SSM process for certification of new vessels. Vessels new to SSM gain a fit for purpose certificate from their SSM company. An Exemption Certificate is obtained, which allows the vessel to operate for three months. To obtain the Exemption Certificate, the ship s safety management manual and maintenance plan must first be approved by the SSM Company. During the three months of the Exemption Certificate, the procedures in the safety management manual and maintenance plan are worked through and modified to suit the ship s operation. Before the expiry of the Exemption Certificate, the vessel owner must successfully complete an initial audit, upon successful completion of which, the vessel is issued with a full term SSM Certificate. To address fatigue management, three new steps in the process of approval are proposed: 1. a fatigue management plan, if required for the operation of the vessel, is submitted by the owner for approval by the SSM company as part of the initial approval of the manual 2. during the period of operation under the Exemption Certificate, the owner documents both the actual hours worked, fatigue problems discovered, solutions proposed, and how the crew were involved in their discovery and development 3. a revised fatigue management plan is submitted for approval by the SSM company prior to the initial audit Owners of vessels already issued with a full term SSM Certificate will also be required to demonstrate that they have an effective fatigue management plan in place, if required for the operation of the vessel. This will be checked as part of the SSM company audits and Maritime Safety Inspector risk assessments, as these fall due. Countermeasures (a) Business as usual promote compliance with existing regulatory interventions that bear on fatigue, including requirements for safe manning, catering, and crew accommodation. This business is carried on by work of the Maritime New Zealand safe manning review group, ship inspections and response (including enforcement action where appropriate) to complaints concerning catering Doc ID

8 and accommodation standards, and audits of organisations approving plans for the construction of new ships. (b) New initiatives train major operators and safe ship management companies to develop vessel fatigue management plans provide basic guidance material to other operators train Maritime New Zealand staff to support development of vessel fatigue management plans and identify fatigue as a factor in accident investigation require vessel-specific fatigue management plans on board ships where fatigue is considered on careful examination to be a significant hazard Most operators are expected to require support from industry advisers to develop their fatigue management programme. Knowledge and understanding of the requirements will be verified by audits of companies against the Code of Practice for Safe Ship Management, and by audits of operators by SSM companies and Maritime New Zealand. 2. International Safety Management (ISM) Code The ISM code contains some limited provisions relating to fatigue management, particularly focused on watch keepers. At this stage, no detailed consideration has been given to how the Maritime New Zealand fatigue management programme can be extended to the ISM vessels. Maritime New Zealand is cognisance of the requirements of the Health and Safety in Employment Act 1992 and its implications for the management of fatigue in this sector. Countermeasures Business as usual promote compliance with existing regulatory interventions that bear on fatigue, including standards for safe manning, catering, crew accommodation, medical fitness and minimum hours of rest. Usual business includes the work of Maritime New Zealand safe manning review group, ship inspections and response (including enforcement action where appropriate) to complaints concerning catering and accommodation standards, and recognition and contractual arrangements governing organisations approving plans for the construction of new ships. New initiatives train operators to develop ship fatigue management plans train Maritime New Zealand staff to support the development of ship fatigue management plans and identify fatigue as a factor in accident investigation Doc ID

9 require vessel-specific fatigue management plans on board ships where fatigue is considered, on careful examination, to be a significant hazard. Training is to be given by Maritime New Zealand staff supported by external expertise in fatigue management. Knowledge and understanding of the requirements will be verified by subsequent ISM audits of operators ship and shore-based safety systems. 3. Watchkeeping Alarms Countermeasures evaluate the cost-benefit of watchkeeping alarms as a fatigue countermeasure for ships that operate at night with a single watchkeeper. This will involve updating a 2002 Maritime New Zealand cost-benefit analysis taking into account the recent accident record and overseas data sets. This work will be carried out by Maritime New Zealand in the course of year 06. While a rules amendment to require the fitting of alarms is one possibility, this may be unnecessary if such a facility is dealt with through a consideration of fatigue management as part of the development of a vessel s risk management plan. provide industry with an agreed standard for watchkeeping alarms and advice on their operation This will be undertaken regardless of the outcome of the cost-benefit evaluation. Even if that fails to establish a significant benefit for this class of ships, alarms may still be justified in individual operations. Providing this information will assist those operators who conclude that such devices are an appropriate fatigue management measure. 4. Training and Educational Material Countermeasures Business as usual ensure training providers continue to deliver fatigue components of training syllabuses promote awareness of existing Maritime New Zealand advisory material on the signs and symptoms of fatigue. Usual business is carried out by programmed audits of training providers, SSM company and operator liaison, SSM and ISM audits, maritime safety inspector contacts with operators, Maritime New Zealand regional seminars, and provision of public domain material (Maritime New Zealand website principally). Doc ID

10 New initiatives produce educational and advisory material for industry and training provider use, and support industry in the material s application review syllabuses for seafarer qualifications and insert provision for awareness of fatigue as both a safety and a health and safety issue, and fatigue management. The following materials are planned: For industry advisers and major operators o guide to science of sleep/fatigue o generic fatigue risk management guide o an audit guide for MNZ and SSM staff o industry advisers will also be familiar with material produced for vessel operators and seafarers These materials are designed to be of maximum benefit when introduced with an advisers fatigue management workshop. It is estimated that the workshop should be around two days long. A question that has yet to be addresses is whether or not a person attending it should have to pass an assessment to be regarded as competent to advise on fatigue management, or must simply attend the workshop? For vessel operators and seafarers o questions and answers on fatigue management plans for vessel owners o seafarer pamphlet dealing with fatigue as a safety and a health issue, with the emphasis on personal management strategies o wheelhouse check-list for signs and symptoms of fatigue and how to respond o video for operators and seafarers illustrating how owners, operators, skippers, crew and shore staff can work together to develop ship-specific fatigue management plans o sector specific guides on risks and related safety management practices o an account of the true cost of fatigue-related accidents o circadian rhythm alertness-sleepiness poster These materials, on their own, are insufficient to allow an owner/skipper/crew to write an effective fatigue management programme. They are designed to be of maximum benefit when used in conjunction with a trained industry adviser. Advice on fatigue management is being incorporated in the guidelines on safe working practice for inshore fishing operations, currently under development as part of FishSAFE fishing industry safety programme. Doc ID

11 These products will form the resource and reference documents used in the training initiatives outlined above in relation to SSM. They will, in turn, be adapted to the needs of other sectors. Question for Discussion What fatigue specific programmes have other Asia-Pacific maritime safety administrations in place, and how successful have they been? Doc ID

12 Appendix 2. Brief Description of Educational Material Product: Science and strategies guide A document in two parts - Part one describes some of the science behind sleep and fatigue; while Part two suggests strategies that can prevent fatigue or mitigate against its effects. Product: Risk management guide A document that describes the required risk management steps and provides supporting material to make it possible to do so. Product: Audit guide A guide for Maritime NZ and SSM company staff for use when auditing a vessel for compliance with fatigue management requirements. Product: Questions and answers for vessel owners questions and answers on management issues some tools to assist owners assess the fatigue situation on their vessels Product: Seafarer s personal guide An easy to read leaflet/booklet that provides seafarers with information on: personal options on how to manage fatigue how they can assist vessel owners/operators/skippers manage fatigue at the vessel level Product: Sector guides A series of short leaflets/booklets that provides industry with: a list of typical fatigue-related hazards found in industry sectors and a range of options for mitigating their effects a short guide to the risk management process and their obligations Product: Video/DVD A number of vignettes on different aspects of fatigue management: use of an accident or two to illustrate key points model how the risk management process can work in a small boat situation emphasize main sleep/fatigue facts Product: Wheelhouse check-list one page poster for the wheelhouse one page on managing a fatigued seafarer Product: Biology and fatigue poster(s) a 24 hour clock with the main alert/sleep periods key implications for fatigue management Product: Cost of fatigue accidents Analysis of the full costs of a small number of fatigue-related accidents, in an easy to read format. Doc ID

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