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Please provide any general feedback about the draft model Code.
This document will be useful in my industry where overtime is regularly offered and fatigue is not generally well managed.
Which sections of the code would you like to add specific comments on?
Comments on section 1.2 How fatigue causes harm
In the 'Health risk of fatigue' section (pp. 6-7), the document states:
"You must eliminate or minimise the risk of workers or others becoming fatigued, not just manage the risks arising from fatigued workers or others".
I think the distinction could be clearer through changing the structure - eg:
You must:
⦁ Eliminate or minimise the risk of workers becoming fatigued; and
⦁ Manage the risks arising from fatigued workers.
In the 'Broader health, safety and wellbeing text box (p.7), the document states:
"For physical and mental health, adults generally require:
• 7 or more hours sleep a night (or each 24-hour period)"
This appears to be based on sleep studies done with men. The few recent sleep studies done with women indicate they need more sleep for adequate functioning and, this can vary due to normal life events such as pregnancy and menopause.
I’m not sure this difference is captured by the modifier ‘generally’.
Comments on section 3.1 Risk of workers becoming fatigued
In 3.1 Risk of workers becoming fatigued (pp. 15-16), the document includes a list of hazards and examples.
This list should specifically identify working planned overtime in addition to planned full time hours.
I don’t think it’s adequately covered by the ‘frequent unplanned overtime’ identified under ‘Irregular hours’.
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