What is a Fatigue Risk Management Plan and How to Develop One?

What is a Fatigue Risk Management Plan and How to Develop One?

In operations with work hours beyond the traditional 9-5, fatigue is an inherent operational challenge because our bodies are not designed to operate around-the-clock. This has led to the development of  a number of safety initiatives designed to reduce the costs, risks, and liabilities of fatigue and the human error incidents that comes from fatigue.

Key Takeaways:

  • Fatigue risk is inherent in extended hours & shiftwork operations and negatively impacts safety, morale, and productivity.
  • A Fatigue Risk Management Plan (FRMP) is the playbook for how an organization manages and reduces fatigue risk for all stakeholders (employees, managers, etc.).
  • Not having a FRMP/FRMS can be a serious liability for organizations (safety, performance and legal exposure).
  • This article reviews key components of a FRMP and how to start developing one.


In extended hours and 24/7 operations, fatigue is an inherent operational challenge because our bodies are not designed to operate around-the-clock. This has led to the development of a number of safety initiatives designed to reduce the costs, risks, and liabilities of fatigue and the human error incidents that comes from fatigue.

Traditional strategies to reduce fatigue risk have been singular in focus such as hours of work limitations or fatigue awareness training. Over time, a broad international consensus has emerged across many 24/7 and extended hours industries that the optimal way to manage and reduce employee fatigue risk is through a systematic process that considers the many work-related and individual  factors that cause fatigue, called a Fatigue Risk Management System (“FRMS”). And the backbone of any FRMS is the Fatigue Risk Management Plan (“FRMP”) – or playbook.

Fatigue Risk Management System:

FRMS is a holistic and comprehensive approach to managing fatigue risk. It's data-driven, risk-informed, performance-based and addresses fatigue risk from multiple perspectives, including:

  1. Workload & Staffing Levels
  2. Shift Schedule & Work Hours
  3. Fatigue & Sleep Training 
  4. Workplace Environment
  5. Fatigue Monitoring


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Figure 1: The Five Defenses of Fatigue Risk


FRMS also have feedback loops which strengthen the five defenses against fatigue by providing risk-informed and performance-based data that can be used to adjust and more accurately align the fatigue mitigating strategies and foster continuous improvement. (Learn more about 5 defenses with our white paper: Evolution of FRMS)

What is a Fatigue Risk Management Plan?

The backbone of any FRMS is the Fatigue Risk Management Plan (“FRMP”) – or playbook. IconDescription automatically generated

A FRMP provides all company stakeholders (e.g., employees, front-line supervisors, senior management, contractors, etc.) with an overall operating standard – ensuring everyone understands their roles and responsibilities for managing fatigue in the workplace. 

Furthermore, as a playbook, a FRMP  defines and describes the company’s fatigue mitigating policies and procedures. And it  provides practical step-by-step guidance on how to assess fatigue risk and implement strategies to manage and lower current and future fatigue risk.

To accomplish its objectives a FRMP needs to be multi-faceted and contain fatigue mitigating strategies that focus on all of the five defenses and are customized to the unique needs of the company. 

It is important to integrate the principle of shared responsibility for the fatigue mitigating initiative throughout the FRMP and clearly define the roles and responsibilities of all of the involved parties in the organization, from the leadership to the workforce.

How do I develop a Fatigue Risk Management Plan?

There are multiple stages to take when developing a customized and comprehensive FRMP. Keeping in mind that there is flexibility in any process, to maximize the FRMP’s effectiveness the following steps are recommended:

  1. Assessing the Operation and Its Fatigue Hazards: The first step in developing a customized playbook is to assess your operation. Talk to people at all levels of the organziation to better understand how they see fatigue impacting the operation. The goal here is to identify and document the fatigue hazards in specific operating environments (i.e., the drivers of fatigue risk in the operation).

  2. A picture containing diagramDescription automatically generatedIdentifying Gaps: Once you have identified the fatigue hazards, the second step in the process involves uncovering the gaps in your organzation's policies and processes related to managing those risks. We recommend looking at those gaps through the lense of the 5 Defenses of Fatigue Risk (see Fig 1 above). As part of this process, staffing levels and actual work schedules are evaluated, current education and training programs are reviewed, mitigation strategies and policies in the workplace related to fatigue risk (fatigue monitoring, napping policies, etc.) are examined.

  3. Fatigue Risk Analysis: The third step in developing a customized FRMP is an objective assessment of the fatigue risk present in the actual work schedules. This is accomplished by using a biomathematical model to calculate a quantified level of risk and by establishing a shift schedule matrix that identifies the frequency that the work schedules exceed acceptable thresholds of health and safety parameters.

  4. Accident & Incident Analysis: Fatigue is one of the most prevalent causes of human error-related accidents, incidents, and injuries, costing companies millions (or more) of dollars each year. The fourth stage in developing a customized FRMP involves assessing fatigue risk at or around the time of reported incidents or accidents to gain a better understanding of how frequent fatigue is a contributing factor in work-related incidents and to better understand the operation's risk profile (i.e., when does fatigue start to impact safety).  This information can help inform new policies and procedures to better manage fatigue risk.

  5. Start Drafting a FRMP: A task-team comprised of different representatives in the organzation (e.g., safety, HR, operations, etc.) should work together to draft and refine the FRMP. The FRMP should include the 5 Defenses of Fatigue Risk and clearly state the objective of each defense, the actions that will be taken to uphold the defense and the KPI data that will be collected to assess the how well the defense is working. The plan should also include a continuous improvement process to review the plan and how well it's working on a regular basis.

We have an FRMP, now what?

To fully integrate a FRMP into any workplace culture, it is critical to communicate the plan to the impacted workforce as well as its leaders. Not only does this ensure that the workforce is aware of the elements and objectives of the plan, but it also informs them of their individual roles and responsibilities for managing fatigue in the workplace.

It’s also critical to remember that a FRMP is a living document that should be part of a continuous improvement process. A FRMP committee should meet on a regular basis to review fatigue related KPIs and evaluate how well the defenses are working. Do they need to be tightened; for example, are the work-hour limits too lenient and leading to an increase in safety and errors? Or, should the be maintained or even loosened?


The bottom-line result of developing a customized FRMP playbook is a new level of safe, efficient, and cost-effective operation. By establishing policies and procedures, your FRMP will serve to systematically control and reduce the costs, risks, and liabilities of fatigue-related human error.

Need help in getting started with your FRMP? 

If you are interested in having a conversation about the steps involved with developing an FRMP reach out to us, we would be please to answer your questions and have a discussion about the unique challenges in your workplace.

CIRCADIAN® has extensive experience with the development and implementation of Fatigue Risk Management Plans (and systems) in a multitude of industries, including with energy, utilities, transportation, etc. Furthermore, CIRCADIAN® was the scientific advisor to the American Petroleum Institute’s ANSI standard on Fatigue Risk Management Systems

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