4. Sleep Health and the Workplace

Introduction

4.1
Individuals experiencing inadequate sleep or a sleep disorder may be less productive at work, and may also be at a heightened risk of workplace accident or injury. Types of work which can affect sleep quality or duration, such as shift work, may also negatively impact an individuals’ health and work performance.
4.2
Industries including: health care, road and rail transport, aviation, and mining, depend on a high level of accuracy and alertness while also utilising shift work and/or long hours. Workplace initiatives such as guidelines for hours of work and rest periods, and enhanced awareness of the importance of sleep, may assist in minimising the impact of fatigue in the workplace.

Fatigue and Impaired Alertness in the Workplace

4.3
Inadequate sleep has been associated with impaired performance in the workplace, primarily through reduced productivity while at work and increased absenteeism.1 The Appleton Institute stated that this comes at a cost to both individuals and the community more broadly:
Many Australian workers are sleepy at work, sleepy on the roads on their commute to work, and may experience errors in the workplace or may miss work because they are too tired. This comes at a cost to employers, employees, and the safety of the broader community.2
4.4
In addition to reducing workplace productivity, inadequate sleep and sleep disorders have been linked to workplace injuries and accidents. The Cooperative Research Centre for Alertness, Safety and Productivity (Alertness CRC) stated that:
There is up to a 50 per cent increased risk of occupational injury, absenteeism and error or safety violation attributed to fatigue in employees with a sleep disorder, with up to 45 per cent of individuals in safety sensitive occupations such as law enforcement and commercial transportation in this category.3
4.5
Overall, the Alertness CRC stated that the ‘indirect financial cost to Australia of lost productivity and accidents due to poor sleep in 2016-2017 was over $24 billion.’4
4.6
Certain types of work have been found to impact negatively on sleep duration and quality. This includes shift work (particularly night shifts)5, flyin-fly-out work6, and work that involves being on call and/or long hours.7 The Appleton Institute also stated that inadequate sleep is more prevalent in ‘safety-critical’ occupations8, which include occupational drivers, emergency services, health care workers, and machinery operators.9
4.7
Safe Work Australia’s Guide to Managing the Risk of Fatigue outlines that employers, officers (such as company directors), and employees all have duties regarding the management of fatigue and associated risks in the workplace. These are outlined in Table 4.1.
Table 4.1:  Health and Safety duties in relation to managing the risks of fatigue
Who
Duties
Person conducting a business or undertaking
‘Has the primary duty to ensure, so far as is reasonably practicable, workers and other persons are not exposed to health and safety risks arising from the business or undertaking. This includes ensuring, so far as is reasonably practicable:
provision and maintenance of a work environment without risks to health and safety,
provision and maintenance of safe systems of work, and
monitoring the health of workers and the conditions at the workplace for the purpose of preventing illness or injury of workers arising from the conduct of the business or undertaking.
The duty on the person conducting the business or undertaking is not removed by a worker’s preference for certain shift patterns for social reasons, their willingness to work extra hours or to come to work when fatigued. The person conducting the business or undertaking should adopt risk management strategies to manage the risks of fatigue in these circumstances.’
Officers
‘Officers such as company directors, must exercise due diligence to ensure the business or undertaking complies with its work health and safety duties.
This includes taking reasonable steps to ensure the business or undertaking has and uses appropriate resources and processes to manage the risks associated with fatigue.’
Workers
‘Workers must take reasonable care for their own health and safety and must not adversely affect the health and safety of other persons. Workers must also comply with any reasonable instruction and cooperate with any reasonable policy or procedure relating to fatigue at the workplace, such as policies on fitness for work or second jobs.
Workers’ duties in relation to fatigue do not mean they must never work extra hours. However, they should talk to their manager or supervisor to let them know when they are fatigued. They should also avoid working additional hours and undertaking safety critical tasks when they know it is likely they are fatigued.’
Source: Safe Work Australia, ‘Guide for Managing the Risk of Fatigue at Work’, 2013, pp 3-4.
4.8
Safe Work Australia also advised that the states and territories are responsible for the regulation of work health and safety matters including fatigue. Specific industries may also be subject to additional regulation and legislation (such as the rail and heavy vehicle industries).10

Shift Work

4.9
The Sleep Health Foundation stated that approximately 16 per cent of Australian workers are shift workers.11 Some shift workers solely perform day shifts, while others may have a rotating roster of shifts through the day and night. Deloitte Access Economics cited health care and mining as two industries that use both day and night shift work.12
4.10
Austin Health and the Institute for Breathing and Sleep explained that shift work, particularly when involving night shifts, can result in ‘sleep restriction (less sleep) as well as circadian dyssynchrony (struggling against our sleep-wake drive).’13 The Australian Capital Territory (ACT) Government estimated that ‘night shift workers get on average 25 to 33 per cent less sleep than day or evening shift workers.’14
4.11
The Austin Health and Institute for Breathing and Sleep also highlighted that female shift workers may be ‘particularly vulnerable’ to inadequate sleep, as women often ‘take on a greater proportion of domestic duties than their male counterparts and have less time available for sleep and recovery.’15

Safety Risks Associated With Shift Work

4.12
Ms Crystal Grant and Associate Professor Siobhan Banks described how night shift work can have detrimental effects that include impaired driving performance and impaired decision making and reaction time. This may have serious implications for shift workers in safety-critical occupations.16 The Sleep Health Foundation stated that the accident rate of shift workers is double that of non-shift workers in Australia, and that it ‘is highly likely that much of this additional risk is sleep-related.’17 The Melbourne Sleep Disorders Centre further stated that there is also evidence of higher rates of industrial accidents amongst those workers who find night shift work particularly hard.18
4.13
As well as having an increased risk of accidents or errors while at work, the Woolcock Institute of Medical Research stated that night shift workers may be at heightened risk of vehicle accidents when driving home from a shift, due to fatigue.19

Health Impacts Associated With Shift Work

4.14
Ms Grant and Associate Professor Banks stated that night shift workers are at a higher risk of ‘developing the health conditions frequently associated with sleep loss.’20 The Austin Health and Institute for Breathing and Sleep similarly stated that appropriate management of shift work was ‘exceedingly important to prevent the development of mental and physical health disorders’, as well as preventing workplace errors and accidents.21
4.15
The Charles Perkins Centre at the University of Sydney outlined potential links between shift work and cancer and stated:
Night shift work, which disrupts the timing of sleep, was classified by the World Health Organisation as a probable carcinogen in 2007. Risk of breast and prostate cancer have been specifically linked to shift work.22
4.16
Dr Ian Dunican stated that ‘shift work leads to weight gain, which can lead to sleep apnoea.’23 Austin Health similarly highlighted the ‘two-way influence’ between sleep loss and obesity, as ‘impaired sleep causes obesity, but obesity causes sleep apnoea.’24
4.17
In addition to these health concerns generally associated with shift work, approximately 10 to 15 per cent of shift workers may experience Shift Work Sleep Disorder (SWSD).25 Austin Health and the Institute for Breathing and Sleep characterised SWSD as involving ‘chronic insomnia (difficulty falling asleep, staying asleep or waking too early at the end of sleep) and daytime sleepiness.’26
4.18
Professor Ron Grunstein outlined what he considered is needed to manage SWSD and stated:
SWSD requires workforce screening and intensive management with scheduling changes, behavioural management and pharmacotherapy of daytime insomnia and appropriate use of medications such as wakefulness promoters.27
4.19
Professor Grunstein further recommended: better education regarding SWSD and its risks; the development of SWSD clinics; and guidelines regarding the ‘use of hypnotics and wakefulness promoters for the management of SWSD.’28

Shift Rostering Practices

4.20
The ACT Government stated that ‘ideal rostering for shift workers’ should include consideration of:
‘Time of day (particularly midnight to 6 a.m. ensuring possibility of breaks)
Time spent working (especially shifts [greater than] 10 hours)
Avoiding rapid shift changes
Cumulative fatigue
Opportunities to rest and eat (fatal motor vehicle accidents after shift work are well recognised)
lncluding all time worked in assessing fatigue and not just what is rostered
Allow at least one day free in every seven in which opportunity for unrestricted sleep is possible.’29
4.21
When considering shift scheduling, the Canberra Sleep Clinic stated that working both day and night shifts over a short period of time can cause workers to feel ‘constantly jetlagged.’ The Canberra Sleep Clinic also cautioned against having workers ‘moving back from days, to nights, to evening shifts.’ Instead, the Canberra Sleep Clinic stated that a stable evening or night shift for several weeks may be preferable, as this will ‘allow the circadian position to stabilise.’30
4.22
In contrast, Dr Dunican cautioned against working a permanent night shift, instead recommending a rotating roster with adequate time off to recover.31 The ACT Government similarly recommended a shift pattern which includes no more than three night shifts in a row. The ACT Government outlined its recommended shift rotation pattern and stated:
A clockwise shift rotation pattern (known as the French System) is recommended, with simple and predictable scheduling templates used where possible (three day, three evening and three night shifts and three recuperative days off). The number of consecutive days on night shift should be optimally one or two but no more than three days. Shifts should ideally be eight hours. Recuperation time should be at least 24 hours following one or more night shifts but optimally three days of recuperation time is required to overcome sleep-disruption. Naps are recommended as a tool to increase alertness during shifts (especially for shifts longer than eight hours).32
4.23
The Sir Charles Gairdner Hospital emphasised that both the workplace and the individual have a role in managing fatigue. The Sir Charles Gairdner Hospital stated:
There are things that employers and workplaces can do to provide opportunities for sleep, and so they should. Shift work design, forward rotation of shifts, and making sure there is adequate time off for recuperation et cetera are very important. It is equally important that the individuals doing this sort of work take those opportunities and that the opportunities exist for them.33
4.24
Dr Sutapa Mukherjee described how she was ‘often surprised at the rosters that many workers are expected to work with no concern or understanding of the circadian clock and biological rhythms.’34 Dr Mukherjee stated that extensive data on rostering and scheduling considerations for shift work is available and should be used by Australian workplaces.35 The Canberra Sleep Clinic expressed similar concerns, and recommended the principles of circadian physiology be applied to shift work rostering.36
4.25
Dr Dunican described how modelling software can be used to optimise shift structures and stated:
… from an organisational point of view, we use things like biomathematical modelling, which is a sophisticated platform that allows us to compare and contrast different shift work options so that we can design adequate rest opportunities. We use that modelling type of software which predominantly was used in military and aviation in the [United States of America]. It is slowly coming into Australia.37
4.26
The University of Western Australia School of Psychological Science (UWASPS) was concerned that, regardless of shift structure, shift work and the associated sleep disruption may not be compatible with good psychological health and that more research was needed. The UWA-SPS stated that it was:
… not convinced that it is possible to be psychologically healthy and not sleep when we are designed to sleep … if you disturb someone's sleep in their 20s they have a fourfold increase in the risk of depression. We know that suicidality increases with poor sleep … if you don't sleep properly it impacts and can permanently impact your attention, problem-solving, memory, ability to learn and study, relationships—everything. So I am not convinced that we know the answer to that question, and I think we absolutely need to know the answer. For that, we need to do the research and, for that, we need the funding.38

Industries Using Shift Work

4.27
Dr Dunican stated that in some of the ‘biggest industries in Australia … such as mining, agriculture, manufacturing [and] transport, there is mainly shift work.’39 The health care sector, including nurses and emergency personnel, also widely utilises shift work.40 Dr Dunican stated that in general, ‘shift work and fatigue risk management are difficult areas for Australian businesses to manage.’41
4.28
Dr Dunican highlighted the industries and workplaces he considered to be ‘leading examples’ in relation to sleep management. These included the Civil Aviation Safety Authority, and some parts of the aviation, rail, oil and gas industries. At the same time, Dr Dunican stated that there was a lot of room for improvement within these industries, as well as the manufacturing and transportation sectors.42
4.29
The Alertness CRC stated that it was seeing ‘a proactive approach, to a certain extent’ to the management of fatigue in both the transport and mining sectors. The Alertness CRC also highlighted, however, that these sectors (as well as the healthcare sector) have ‘a lot of complex issues and barriers’ which can make it difficult to employ effective solutions.43
4.30
Neuroscience Research Australia (NeuRA) stated that the aviation industry has ‘been on the front foot’ about managing fatigue risk and shift work, while the rail industry has not been as proactive. The NeuRA further stated that ‘doctors are some of the worst offenders in this area.’44

Box 4.1:   Fatigue in the Aviation Industry

In January 2019 the Australian Transport Safety Bureau released its report Fatigue Experiences and Culture in Australian Commercial Air Transport Pilots (ATSB Report). The ATSB Report surveyed a sample of Australian pilots in order to ‘understand the level and perceptions of fatigue’ in the airline industry.45
The ATSB Report found that the majority of surveyed pilots stated that they were ‘sufficiently well rested by the end of their last duty’, but that a ‘small but significant number of pilots’ reported obtaining levels of sleep that have been associated with impaired performance.46
Other findings included that approximately half of the domestic and international pilots surveyed reported obtaining less sleep on duty then they did at home, and that ‘15 per cent of international pilots responded they had no rest during their last international flight.’47
The ATSB Report also stated that some domestic pilots ‘have negative perceptions of rest opportunities provided by their employers.’ Concerns raised by some respondents in this cohort included that rest periods were too short, duty periods were too long, and accessing food during duties could be difficult.48
In addition, over 90 per cent of respondents stated that their employer had a formal process for pilots to remove themselves from duty due to fatigue. The pilots that did remove themselves, however, ‘generally perceived their actions left a negative impression with management … and did not feel comfortable doing so.’49
In summary, the ATSB report stated that:
It is important for operators to implement policies to reduce the likelihood of fatigue-related issues through rostering practices and by providing an organisational culture where crew can report fatigue in a supportive environment.’50
The ATSB Report also drew attention to the responsibility of individual pilots to remove themselves from duty if they feel fatigued, and to use rest periods to obtain sufficient sleep.51
4.31
The Appleton Institute highlighted the disability care workforce, including Residential Support Workers, which it described as having ‘unique work environments and roster designs.’ The Appleton Institute further stated that the disability care workforce is ‘critically understudied from a sleep loss perspective’, but emerging evidence indicates that Residential Support Workers ‘experience insufficient sleep and may be at risk of burnout.’52

Health Sector and Shift Work

4.32
Health care is a sector that is reliant on shift work.53 The Royal Australasian College of Physicians (RACP) described that ‘fatigue in the health industry can have detrimental impacts on patient care (errors and adverse events) for nurses who are shift workers, and other medical practitioners who may be on call.’54
4.33
The Queensland Nurses and Midwives’ Union (QNMU) highlighted the common work hours for its members as including ‘extended work hours or overtime, being on call, consecutive shifts and short turnaround between shifts.’55 Health Business Solutions (HBS) stated that these work hours and shift patterns for nurses can ‘affect their sleep patterns and quality and thus pose risks to their health and safety and that of the patients they care for.’56
4.34
The HBS expressed concerns related to agency nursing staff who are contracted to work shifts in hospitals. The HBS stated that while laws in the states and territories usually require eight to 10 hours rest between shifts, ‘agency staff may work double shifts, which … is insufficient for the health care worker to rest and recover.’57
4.35
The HBS recommended that legislation and regulations regarding time off between shifts in the health sector be made consistent across jurisdictions and in line with other industries. In addition, the HBS recommended that health and aged care quality standards include management of working hours and rostering as a criterion, and that a review of staffing practices be mandatory in any accreditation review.58
4.36
The QNMU also made the point that ‘it is essential that rostering guidelines include fatigue risk management and have structured shift design and shift length to ensure disruption to sleep is minimal.’59
4.37
The Queensland Government stated negotiations with nurses and midwives regarding a new certified agreement in 2018 had a ‘focus on nurses' shift work and fatigue.’ The Queensland Government stated that as a result:
… Queensland Health agreed to introduce a new industrial entitlement for Queensland's public sector nurses and midwives. From 25 September 2018, if any nurse or midwife is recalled to the workplace for any period between rostered shifts, that recall triggers a fresh ten-hour break before they recommence duty.60
4.38
The Queensland Government further stated that the new agreement specified that ‘where practicable, nurses and midwives on night shift may sleep in an appropriately safe setting during their break to minimise fatigue.’61

Road and Workplace Accidents

4.39
The Queensland Government stated that fatigue can negatively impact driving performance through:
‘Vigilance and alertness deterioration;
Decreased concentration;
Performance impairment;
Slower reaction times; and
Judgement impairment.’62
4.40
Turning Point drew attention to data from Victoria which further highlighted the impact of inadequate sleep on accident rates and stated:
VicRoads estimate that sleep loss is a contributing factor in 23 per cent of all motor vehicle accidents, and experimental data has shown that driving capability after prolonged wake periods (greater than 17 hours) is similar to driving with a [blood alcohol level] of 0.05, the legal limit in all Australian jurisdictions.63
4.41
The Alertness CRC similarly provided statistics regarding impaired alertness and vehicle accidents and stated that:
It is … estimated that 20 per cent of serious car crash injuries (and 30 per cent of fatal crashes) are attributed to impaired alertness making it the largest identifiable and preventable cause of transport accidents.64

Road Transport Industry

4.42
Dr Dunican was of the view that the trucking sector is performing ‘quite poorly’ in relation to sleep management.65 Dr Dunican cited an example from Western Australia and stated:
In Western Australia [road transport workers] can drive 17 hours without taking small breaks … being awake for 17 hours is the equivalent of being intoxicated at 0.05 per cent. You will see the same reaction times. So we have a long way to go on that … That is a challenge given the remote operations, such as fly-in fly-out mines where we have road transport coming from Perth to Kalgoorlie or up to the Pilbara region. It can be quite difficult. It would be an area that would need a lot of support.66
4.43
The ACT Government stated that Australia would benefit from ‘uniform national legislation providing regulations for drivers' working hours and minimum rest.’ The ACT pointed to regulation in the European Union (EU) as an example Australia could follow and stated that:
… [in the EU] the non-stop driving time may not exceed 4.5 hours. After 4.5 hours of driving the driver must take a break period of at least 45 minutes. However, this can be split into two breaks, the first being at least 15 minutes, and the second being at least 30 minutes in length. The daily driving time shall not exceed nine hours. The daily driving time may be extended to at most 10 hours not more than twice during the week. The weekly driving time may not exceed 56 hours. In addition to this, a driver cannot exceed 90 hours driving in a fortnight.67
4.44
Dr Dunican similarly recommended that a ‘national guidance document across each state and territory’ regarding driving and rest times be developed in consultation with road transport stakeholders. Dr Dunican explained that currently, regulations regarding road and rest times differ across states and territories, which can be difficult for transport companies that operate across state lines to manage. Dr Dunican further explained that some industries (such as mining) may be subject to additional regulations, which add further complexity.68

Sleep Apnoea in Truck Drivers

4.45
The Adelaide Institute for Sleep Health (AISH) stated that ‘up to 38 per cent of Australian truck drivers have Obstructive Sleep Apnoea’ (OSA), and that sleep disorders such as OSA have been associated with increases in workplace and vehicle accidents.69 The AISH also made the point that there are ‘large individual differences’ in the way people respond to inadequate sleep in the workplace, which poses a ‘significant clinical challenge’ in how to recognise those who are at the highest risk of accident or error. The AISH recommended that tools be developed ‘that can identify those drivers with sleep apnoea who are most vulnerable to driving accidents.’70
4.46
Professor Grunstein stated that his organisation had ‘developed more accurate ways of detecting which drivers with sleep apnoea are at risk on the roads for crashes.’ Professor Grunstein recommended the development of new guidelines for crash risk assessments for drivers with sleep apnoea, which should be ‘based on the latest science.’71
4.47
The Melbourne Sleep Disorders Centre put forward a best practice example of a transport company in Queensland which has ‘actively investigated and treated sleep apnoea in transport drivers who do long haul drives.’72 The Melbourne Sleep Disorders Centre described the management process, and stated that this company:
… systematically [has] the patients assessed by a doctor, and, if appropriate, a sleep study performed. The transport company actually rented out … the treatment equipment for the sleep apnoea, for the drivers every month for the first 12 months. If a driver was consistent with treatment and was continuing to drive for that company, the company would buy the device outright. They then went back to their insurer with that risk reduction strategy and negotiated lower premiums and lower excesses … It was better for the business and so much nicer for the employment.73
4.48
The Melbourne Sleep Disorders Centre further explained that this type of best practice approach from a workplace is ‘rare’.74

Rail Industry

4.49
The Office of the National Rail Safety Regulator (ONRSR) described how fatigue risk is managed in the rail industry and stated:
Under the Rail Safety National Law, fatigue risk management is regulated under a risk-based approach with primary duties on rail transport operators, rail safety workers and other duty holders, to ensure rail safety work is undertaken safely, so far as is reasonably practicable. Operators in New South Wales and Queensland however have additional requirements under the National Regulations whereby hours of work are prescribed for train drivers.75
4.50
The ONRSR further advised that under this framework, it does not mandate standards; ‘rather the duty is on the operator to demonstrate, [so far as is reasonably practicable], the safety of railway operations and rail safety work.’76 The ONRSR also stated that rail operators are required to have a fatigue management plan in place.77
4.51
The ONRSR advised that since it began its role over five years ago, ‘a consistent approach to the legislative framework for managing fatigue [has not been] reached.’ The ONRSR stated that as a result, it was currently undertaking a review of the differing legislative requirements for managing fatigue, in order to make a recommendation on ‘the most effective consistent approach.’78
4.52
The increasing use of technology and automation in the rail industry, and the accompanying rise in ‘passive monitoring’ by workers, was identified as an emerging challenge by the ONRSR. The ONRSR stated that, while technology and automation can make railways safer, the associated increase in passive monitoring by workers may impact alertness and ‘introduce different fatigue factors which would require assessing as part of a fatigue risk management program.’79
4.53
The ONRSR stated that there was ‘limited data’ to conclusively determine the impacts of fatigue on rail safety, particularly in live operational settings. In addition, the ONRSR stated that there were ‘mixed findings’ relating to whether working a permanent night shift led to an elevated fatigue risk.80
4.54
In contrast, the Rail, Tram and Bus Union (RTBU) considered that the ONRSR’s description of the data and research findings was ‘incorrect and misleading’. The RTBU further stated that there is a ‘clear link between fatigue, reduced performance and elevated risk of accident or injury.’81
4.55
The RTBU also stated that Australia is behind other countries in terms of fatigue management:
Australia’s failure to adopt a prescriptive fatigue management system means we are lagging behind many other comparable countries. The [United States of America], the [United Kingdom] and EU have benchmarks for working hour regulations mandating prescriptive maximum duty hours and minimum rest period.82
4.56
Recognising these international examples, the RTBU recommended that ‘hours of service limits should be a central part of fatigue risk management within the rail industry, with additional fatigue risk management strategies incorporated within these limits.’83
4.57
The ONRSR put forward a different view and stated that in relation to hours worked:
ONRSR has been unable to find any evidence of greater rail safety outcomes when comparing the prescribed hours of operations for train drivers in New South Wales and Queensland compared with safety outcomes in other jurisdictions that operate under a purely risk-based approach to fatigue risk management in the rail industry in Australia.84

Workplace Awareness, Practices, and Assistance Available

4.58
The Alertness CRC outlined challenges associated with identifying, monitoring and reducing the impact of poor alertness in the workplace and stated:
‘The available tools to measure, monitor and manage the substantial public safety risks posed by reduced alertness [are] inadequate. The sleepy brain … cannot judge its own level of impairment and therefore ‘self-evaluation’ is unreliable. More evidence based objective measures are needed to support fitness for duty testing and roadside driver monitoring.
Sleep loss affects different people in different ways. Our ability to identify those individuals or groups who are most vulnerable to the effects of poor alertness, and will benefit most from countermeasures, has been limited in operational or community settings.
There has been failure to account for the variation between individuals when managing fatigue. A “one-size-fits-all” approach is not appropriate or cost-effective and leads to ineffective treatments and wasted resources.
Effective strategies to improve alertness in the workplace and to help shift workers reduce the health and safety risks inherent in their work schedule are lacking or poorly integrated with other aspects of their lives.’85
4.59
The NeuRA similarly highlighted that people respond to a lack of sleep and/or sleep disorders in a variety of ways, with some more able to cope than others. As such, the NeuRA emphasised that targeted approaches which can determine who is at more risk will be required.86
4.60
The Alertness CRC advised it is conducting research which can support the development of technologies to improve fatigue management in the workplace and on the road. This includes the development of tools for assessing alertness; improved scheduling solutions (particularly for the healthcare and mining sectors); and improved lighting in workplaces to increase alertness.87
4.61
The Alertness CRC stated that ‘industry driven, targeted research’ and ‘effective research translation pathways’ are critical to ongoing innovation in the area of sleep health and alertness management.88
4.62
Dr Dunican was concerned that many businesses were being provided with ‘misinformation’ about effective sleep health practices. Dr Dunican stated that this can affect a business' ‘safety and productivity, which ultimately [is] going to affect their retention and recruitment of their people and make them an unhappy workforce.’89
4.63
The AISH advised that a range of useful resources regarding shift work and SWSD are available to businesses, but that ‘none of this material is digitised or in a user-friendly format for organisations.’ The AISH advised that it was working with the Alertness CRC to develop ‘tools, algorithms and online systems’ to assist with the rostering and management of fatigue amongst shift workers.90
4.64
In addition to support for shift workers, the AISH highlighted that assistance was needed for individuals who work ‘non-standard hours’ (beyond the 9:00 am to 5:00 pm bracket). The AISH stated:
Shift workers working overnight account for … 15 to 20 per cent of workers in Australia, but non-standard work hours probably account for another 30 to 40 per cent. There are people getting up early going to work and getting home late who try and adjust their sleep … I think we have less-well-described means of helping those people, and that probably requires more work.91
4.65
A number of inquiry participants recommended the development of guidelines for fatigue and/or shift work. Dr Gemma Paech stated that it is ‘vital that there are guidelines in place to improve safety and productivity in the workplace, particularly within industries that involve shift work.’92
4.66
The Sleep Health Foundation similarly recommended ‘redoubling efforts to ensure adequate national guidelines regarding shift rosters to ensure there is adequate opportunity for sleep.’93 The Australasian Sleep Association also called for ‘guidelines to inform improved rostering practices and work environments’, with a focus on shift work, long work requirements, and the transport industry.94

Workplace Awareness and Education

4.67
Dr Paech advised that there is a need for greater awareness among shift workers of how to manage their sleep effectively and stated:
Workers … need to have a greater understanding into how to optimise their sleep between working hours and the appropriate use of stimulants to promote alertness during shifts.95
4.68
The Sleep Health Foundation recommended that, in addition to the development of national guidelines for shift rosters, action should be implemented ‘to encourage workers to ensure that those opportunities for sleep are taken.’96
4.69
Dr Mukherjee stated that ‘workplace education is essential both for workers and employers.’97 The QNMU similarly stated that there was a need for education of both employers and employees on ‘how inadequate and poor sleep can not only impact a person’s health and wellbeing but also reduces workplace productivity.’98
4.70
Dr Mukherjee recommended ‘targeted educational programs to assist industry with rostering, shift work management [and] fatigue management to maximise safety and productivity.’ In particular, Dr Mukherjee singled out the transport and mining industries as two ‘high risk’ sectors ‘where workplace accidents have the potential to be catastrophic.’99 The Sleep Health Foundation similarly recommended the ‘development and distribution of educational material specifically for those involved in safety critical occupations (such as occupational drivers) and shift work.’100
4.71
The Australasian Sleep Association recommended the development of education campaigns aimed at minimising workplace risks of inadequate sleep. These campaigns should focus on ways to avoid drowsiness when driving and target high risk groups including ‘young drivers, shift workers, and [the] transport industry.’101
4.72
The QNMU emphasised the importance of having a workplace culture ‘that is supportive of sleep health.’102 The Melbourne Sleep Disorders Centre similarly highlighted that implementing workplace measures to address fatigue risk may require ‘attitudinal change amongst the leaders [of a company] to actually implement it.’103
4.73
The RACP also supported the development of education and awareness programs for specific industries. The RACP stated that it:
… supports education and awareness programs that recognise the risks and manage risks associated with the hazard of fatigue … To this end, the RACP supports the availability of targeted programs in industries and workplaces that require periods of extended working hours (such as the police, fire and emergency services, typically in response to specific events), as well as those who are routinely engaged in evening and overnight shift work, such as the mining (such as Fly-In / Fly Out workers), transport (including those engaged in road, rail, maritime and/or air transport), and hospitality industries.104
4.74
The HBS recommended an awareness program be developed for health care workers, to increase recognition of ‘problems associated with “mixed” shift patterns and signs of fatigue.’ In addition, the HBS recommended ‘mandating that health care facilities provide resources for health care workers to fully understand the risks of fatigue and what they personally can do to prevent it.’105
4.75
Associate Professor Siobhan Banks and Professor David Hillman advised that farmers would benefit from an educational campaign to address the impact of inadequate sleep in the workplace. In particular, this education campaign could highlight practical strategies for farmers to use, including: optimal break times, the importance of hydration and eating well, using air conditioning and caffeine to remain alert and mental health support.106 Associate Professor Banks and Professor Hillman stated that:
These kinds of fatigue management strategies have long been used in other Australian industries such as mining, transportation and healthcare but have not found their way onto farms. Education is the key to changing this.107

Screening and Treatment in High-Risk Workplaces

4.76
The Sleep Health Foundation stated that fatigue becomes a major issue in safety critical occupations, such as occupational drivers, and industries that utilise shift work. Recognising these ‘at-risk’ cohorts, the Sleep Health Foundation recommended increased sleep health screening of these groups, in order to ‘help identify clinical sleep problems and other vulnerabilities and thereby reduce the risk of accidents or errors.’108
4.77
The Sleep Management Group similarly recommended that sleep studies be mandatory for professional drivers and machinery operators. If a sleep disorder is then diagnosed, treatment should also be compulsory.109
4.78
The AISH cautioned against penalising drivers with OSA, as has been recommended in the United States of America (US):
Currently, the US Federal Motor Carrier Safety Administration recommends disqualifying all drivers with “moderate to severe” OSA. In Australian terms that would mean taking 30 per cent of the driving workforce off the roads. This blanket screening and penalising of drivers based on presence or absence of OSA is inappropriate, would be an economic disaster, and is a scientifically flawed recommendation.110
4.79
SleepFit outlined its digital assessment and management model that workplaces can use to assess the sleep health of employees. SleepFit advised that its program includes workers being given a digital sleep risk assessment, with employees then being ‘triaged into programs suitable for their needs.’ These programs target poor sleep habits, insomnia, and sleep apnoea, and have a range of supports available. SleepFit recommended the government support ‘research programs in workplace settings’, as well as ‘sleep awareness and intervention programs in Australian workplaces’ to support greater sleep health.111

Testing for Drowsiness in Drivers

4.80
Associate Professor Mark Howard and Associate Professor Clare Anderson called for further research into technologies which can detect drowsiness in drivers and stated:
Australia is a world leader in research and commercial development of alertness monitoring and detection technology, which can detect drowsiness in real time. Further research is required to understand how to affectively implement this technology in order to reduce crashes through alerting drivers and using the data to identify high risk situations and adjust schedules and implement interventions when drowsiness is detected.112
4.81
Associate Professor Howard and Associate Professor Anderson also drew attention to new technology which can test for drowsiness at the roadside, in a similar way to current roadside testing for alcohol and drugs. Associate Professor Howard and Associate Professor Anderson stated that field trials are required to confirm the accuracy of this technology in real-life settings. The roll out of this technology would also need to be accompanied by the development of legislation to enable prosecution for ‘driving while drowsy.’113

Concluding Comment

4.82
Sleep health is essential for workers to be productive and alert in the workplace, as well as to maintain long term health and wellbeing. Work that involves long hours, working during the night, and/or a rotating schedule may impact on sleep quality and duration, which may then negatively affect work performance.
4.83
Shift work in particular has been linked to lower levels of workplace productivity, as well as increased risk of injury or accident. In addition, the Committee was concerned to hear that shift work has been linked to health conditions associated with inadequate sleep, including obesity, sleep disorders, mental health conditions and cancer.
4.84
It is particularly important that workers in safety-critical occupations have adequate rest opportunities to maintain alertness in the workplace. The Committee was concerned to hear that the road transport industry, where a lapse in concentration could be fatal, may not be as advanced as other sectors in the management of fatigue in the workplace. The high rates of sleep apnoea amongst truck drivers, which makes them more vulnerable to accidents, may also point to a need for sleep health screenings of this cohort.
4.85
Concerns were raised that many workplaces do not use the most up-to-date research and data regarding optimal shift structures and rest breaks when designing work rosters. Ensuring all workplaces have access to clear information about how to structure shift schedules may help increase workplace productivity and the wellbeing of employees.
4.86
The Committee also heard there is a need for increased awareness of the importance of sleep health in the workplace. This involves both individuals optimising opportunities for rest breaks and sleep, and workplaces creating a culture that is supportive of sleep health.
4.87
The Committee was pleased to hear about developments in technology that will enable roadside testing for drowsiness in drivers. While further research and development is needed, the Committee considers that this technology has the potential to significantly reduce accidents and improve road safety and possibly minimise road fatalities.

Recommendation 2

4.88
The Committee recommends Safe Work Australia and the Alertness CRC provide updated guidelines (based on current research and science) for industries using shift work, regarding optimal shift structures and other workplace practices that promote alertness, productivity and ensure worker safety.

Recommendation 3

4.89
The Committee recommends the Australian Government work with the states and territories to:
Develop a nationally consistent approach to working hours and rest breaks for shift workers; and
Consider whether there is a need for sleep health screenings for shift workers; and
That this approach be based on guidelines recommended by Safe Work Australia and the Alertness CRC.

  • 1
    Ms Melissa Webster, Chief Executive Officer (CEO), SleepFit, Official Committee Hansard, Sydney, 5 February 2019, p. 1.
  • 2
    Appleton Institute, Submission 88, p. 1.
  • 3
    Cooperative Research Centre for Alertness, Safety and Productivity (Alertness CRC), Submission 92, p. 1.
  • 4
    Alertness CRC, Submission 92, p. 1.
  • 5
    Sleep Health Foundation, Submission 54, p. 8.
  • 6
    National Mental Health Commission, Submission 62, p. 2.
  • 7
    Appleton Institute, Submission 88, pp 1-2.
  • 8
    Appleton Institute, Submission 88, p. 2.
  • 9
    Sleep Health Foundation, Submission 54, p. 8.
  • 10
    Ms Bianca Wellington, Acting Branch Manager, Legal and Workplace Health and Safety Strategy Branch, Safe Work Australia, Official Committee Hansard, Canberra, 11 February 2019, p. 4, 15.
  • 11
    Sleep Health Foundation, Submission 54, p. 8.
  • 12
    Deloitte Access Economics, Exhibit 2b: Asleep on the Job: Costs of Inadequate Sleep in Australia, 2017, p. 14.
  • 13
    Austin Health and the Institute for Breathing and Sleep, Submission 84, p. 3.
  • 14
    Australian Capital Territory (ACT) Government, Submission 126, p. 1.
  • 15
    Austin Health and the Institute for Breathing and Sleep, Submission 84, p. 3.
  • 16
    Ms Crystal Grant and Associate Professor Siobhan Banks, Submission 82, p. [6].
  • 17
    Sleep Health Foundation, Submission 54, p. 8.
  • 18
    Dr John Swieca, Sleep Physician and Medical Director, Melbourne Sleep Disorders Centre (MSDC), Official Committee Hansard, Melbourne, 6 February 2019, p. 40.
  • 19
    Professor Ronald Grunstein, Head, Sleep and Circadian Research Group, Woolcock Institute of Medical Research and Central Clinical School, University of Sydney, Official Committee Hansard, Canberra, 11 February 2019, p. 17.
  • 20
    Ms Crystal Grant and Associate Professor Siobhan Banks, Submission 82, p. [2].
  • 21
    Austin Health and Institute for Breathing and Sleep, Submission 84, p. 3.
  • 22
    Charles Perkins Centre, University of Sydney, Submission 46, p. 9.
  • 23
    Dr Ian Dunican, Director/Principal Consultant, Melius Consulting, Official Committee Hansard, Perth, 29 January 2019, p. 5.
  • 24
    Associate Professor Mark Howard, Director, Victorian Respiratory Support Service, Austin Health, Official Committee Hansard, Melbourne, 6 February 2019, p. 20.
  • 25
    Professor Ron Grunstein, Submission 112, p. 11.
  • 26
    Austin Health and Institute for Breathing and Sleep, Submission 84, p. 3.
  • 27
    Professor Ron Grunstein, Submission 112, p. 11.
  • 28
    Professor Ron Grunstein, Submission 112, p. 11.
  • 29
    ACT Government, Submission 126, p. 3.
  • 30
    Canberra Sleep Clinic, Submission 109, p. 3.
  • 31
    Dr Ian Dunican, Melius Consulting, Official Committee Hansard, Perth, 29 January 2019, p. 4.
  • 32
    ACT Government, Submission 126, p. 4.
  • 33
    Dr David Hillman, Sleep Physician, Sleep Health Foundation and Sir Charles Gairdner Hospital, Official Committee Hansard, Perth, 29 January 2019, p. 17.
  • 34
    Dr Sutapa Mukherjee, Submission 18, p. 2.
  • 35
    Dr Sutapa Mukherjee, Submission 18, p. 2.
  • 36
    Canberra Sleep Clinic, Submission 109, pp 3-4.
  • 37
    Dr Ian Dunican, Melius Consulting, Official Committee Hansard, Perth, 29 January 2019, p. 4.
  • 38
    Professor Romola Bucks, Head of School of Psychological Science, and Professor, University of Western Australia, Official Committee Hansard, Perth, 29 January 2019, p. 5.
  • 39
    Dr Ian Dunican, Melius Consulting, Official Committee Hansard, Perth, 29 January 2019, p. 4.
  • 40
    Deloitte Access Economics, Exhibit 2b: Asleep on the Job: Costs of Inadequate Sleep in Australia, p. 14.
  • 41
    Dr Ian Dunican, Melius Consulting, Official Committee Hansard, Perth, 29 January 2019, p. 2.
  • 42
    Dr Ian Dunican, Melius Consulting, Official Committee Hansard, Perth, 29 January 2019, p. 5, 7.
  • 43
    Mr Anthony Williams, CEO, Alertness CRC, Official Committee Hansard, Canberra, 11 February 2019, p. 17.
  • 44
    Professor Danny Eckert, Director, Sleep Research Program, Neuroscience Research Australia (NeuRA), University of New South Wales, and Matthew Flinders Fellow, Adelaide Institute for Sleep Health, Flinders University, Official Committee Hansard, Sydney, 5 February 2019, p. 27.
  • 45
    Australian Transport Safety Bureau (ATSB), Exhibit 10: Fatigue Experiences and Culture in Australian Commercial Air Transport Pilots, 2019, p. 1.
  • 46
    ATSB, Exhibit 10: Fatigue Experiences and Culture in Australian Commercial Air Transport Pilots, 2019, p. [3].
  • 47
    ATSB, Exhibit 10: Fatigue Experiences and Culture in Australian Commercial Air Transport Pilots, 2019, p. [3].
  • 48
    ATSB, Exhibit 10: Fatigue Experiences and Culture in Australian Commercial Air Transport Pilots, 2019, p. [3].
  • 49
    ATSB, Exhibit 10: Fatigue Experiences and Culture in Australian Commercial Air Transport Pilots, 2019, p. [3].
  • 50
    ATSB, Exhibit 10: Fatigue Experiences and Culture in Australian Commercial Air Transport Pilots, 2019, p. [3].
  • 51
    ATSB, Exhibit 10: Fatigue Experiences and Culture in Australian Commercial Air Transport Pilots, 2019, p. [3].
  • 52
    Appleton Institute, Submission 88, p. 1.
  • 53
    Health Business Solutions (HBS), Submission 58, p. 1.
  • 54
    Royal Australasian College of Physicians (RACP), Submission 122, pp 10-11.
  • 55
    Queensland Nurses and Midwives’ Union (QNMU), Submission 49, p. 5.
  • 56
    HBS, Submission 58, p. 1.
  • 57
    HBS, Submission 58, pp 3-4.
  • 58
    HBS, Submission 58, p. 5.
  • 59
    QNMU, Submission 49, p. 5.
  • 60
    Queensland Government, Submission 115, p. 11.
  • 61
    Queensland Government, Submission 115, p. 11.
  • 62
    Queensland Government, Submission 115, p. 4.
  • 63
    Turning Point, Submission 33, p. 3.
  • 64
    Alertness CRC, Submission 92, p. 1.
  • 65
    Dr Ian Dunican, Melius Consulting, Official Committee Hansard, Perth, 29 January 2019, p. 5.
  • 66
    Dr Ian Dunican, Melius Consulting, Official Committee Hansard, Perth, 29 January 2019, p. 5.
  • 67
    ACT Government, Submission 126, p. 4.
  • 68
    Dr Ian Dunican, Melius Consulting, Official Committee Hansard, Perth, 29 January 2019, p. 7.
  • 69
    Adelaide Institute for Sleep Health (AISH), Submission 100, p. 5.
  • 70
    AISH, Submission 100, p. 5.
  • 71
    Professor Ron Grunstein, Submission 112, pp 11-12.
  • 72
    Dr John Swieca, MSDC, Official Committee Hansard, Melbourne, 6 February 2019, p. 40.
  • 73
    Dr John Swieca, MSDC, Official Committee Hansard, Melbourne, 6 February 2019, p. 40.
  • 74
    Dr John Swieca, MSDC, Official Committee Hansard, Melbourne, 6 February 2019, p. 40.
  • 75
    Office of the National Rail Safety Regulator (ONRSR), Submission 63, p. 1.
  • 76
    ONRSR, Submission 63, p. 1.
  • 77
    Ms Sue McCarrey, Chief Executive, ONRSR, Official Committee Hansard, Sydney, 5 February 2019, p. 38.
  • 78
    ONRSR, Submission 63, p. 1.
  • 79
    ONRSR, Submission 63, p. 2.
  • 80
    ONRSR, Submission 63, p. 2.
  • 81
    Rail, Tram and Bus Union, Submission 127, pp 1-2.
  • 82
    Rail, Tram and Bus Union, Submission 127, p. 2.
  • 83
    Rail, Tram and Bus Union, Submission 127, p. 2.
  • 84
    ONRSR, Submission 63, p. 2.
  • 85
    Alertness CRC, Submission 92, p. 2.
  • 86
    Professor Danny Eckert, NeuRA, Official Committee Hansard, Sydney, 5 February 2019, p. 27.
  • 87
    Alertness CRC, Submission 92, p. 3.
  • 88
    Mr Anthony Williams, Alertness CRC, Official Committee Hansard, Canberra, 11 February 2019, p. 2.
  • 89
    Dr Ian Dunican, Melius Consulting, Official Committee Hansard, Perth, 29 January 2019, p. 7.
  • 90
    Dr Andrew Vakulin, NHMRC Career Development Fellow, AISH, Flinders University, Official Committee Hansard, Sydney, 5 February 2019, p. 37.
  • 91
    Professor Robert Adams, Professor of Sleep Medicine, AISH, Flinders University, Official Committee Hansard, Sydney, 5 February 2019, p. 37.
  • 92
    Dr Gemma Paech, Submission 19, p. 1.
  • 93
    Sleep Health Foundation, Submission 54, p. 8.
  • 94
    Australasian Sleep Association, Submission 118, p. 7.
  • 95
    Dr Gemma Paech, Submission 19, p. 1.
  • 96
    Sleep Health Foundation, Submission 54, p. 8.
  • 97
    Dr Sutapa Mukherjee, Submission 18, p. 2.
  • 98
    QNMU, Submission 49, p. 6.
  • 99
    Dr Sutapa Mukherjee, Submission 18, p. 2.
  • 100
    Sleep Health Foundation, Submission 54, p. 8.
  • 101
    Australasian Sleep Association, Submission 118, p. 7.
  • 102
    QNMU, Submission 49, p. 6.
  • 103
    Dr David Cunnington, Sleep Physician and Director, MSDC, Official Committee Hansard, Melbourne, 6 February 2019, p. 41.
  • 104
    Royal Australasian College of Physicians, Submission 122, p. 11.
  • 105
    Health Business Solutions, Submission 58, p. 5.
  • 106
    Associate Professor Siobhan Banks and Professor David Hillman, Submission 83, pp 1-2.
  • 107
    Associate Professor Siobhan Banks and Professor David Hillman, Submission 83, p. 2.
  • 108
    Sleep Health Foundation, Submission 54, p. 8.
  • 109
    Sleep Management Group, Submission 65, p. 3.
  • 110
    AISH, Submission 100, p. 5.
  • 111
    SleepFit, Submission 47, pp 1-2.
  • 112
    Associate Professor Mark Howard and Associate Professor Clare Anderson, Submission 9, p. 1.
  • 113
    Associate Professor Mark Howard and Associate Professor Clare Anderson, Submission 9, p. 1.

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