Guidelines for Health and Safety on Board Small Fishing Boats

If you are suffering from fatigue you will not be able to do your work properly and safely. Sometimes people do not actually realise that they are fatigued.

Fatigue happens when people:

• Don't get enough sleep
• Work very hard, either physically or mentally, and don't have time to recover from the work
• Work for too long
• Work when the body is programmed to sleep (e.g. in the middle of the night)
• Can't sleep when they have the chance
• Have poor quality sleep (e.g. sleep might be interrupted, or there might be something wrong with where you're trying to sleep - too much light, noise, vibration, the vessel is moving, it is too hot or too cold).

Most people need 7 – 8 hours of sleep a night to be fully rested. Most (but not all) can get by on 6 hours of unbroken sleep a night for a few nights until the pressure for sleep increases to dangerous levels.

With less than 6 hours sleep a night the pressure for sleep increases rapidly. The risk of falling asleep or making a mistake also increases rapidly and needs to be managed. With lack of sleep the brain takes ‘micro sleeps’, turning itself off from the outside work for a short time (people who are ‘asleep on their feet’). Eventually this will turn into continuous sleep. If people go for several days without enough sleep, they are more likely to be affected by fatigue and to take longer to recover from the lack of sleep. This is called "sleep debt".

People naturally want to sleep at night, especially in the early morning, and feel sleepy in mid-afternoon. Late morning and early afternoon is when we feel naturally alert. So as a result night workers usually sleep 2 – 3 hours less every 24 hours than they need to be fully rested, because they try to sleep in their natural "alert times".

Is fatigue a significant hazard on my vessel?

Fatigue is likely to be an issue at some point on nearly every fishing vessel because of the sort of work that is being done – hard, physical and sometimes monotonous. If the answer to any of the following questions is yes, fatigue is likely to be a significant hazard on your vessel:

• Does anyone on the boat usually start work before 0700 or finish after 2200?
• Is the work day usually longer than 12 hours?
• Is it a demanding work environment (e.g. lots of noise, vibration, heat or cold, rough sea conditions)?
• Are work demands unpredictable?
• Is working on the boat constantly physically or mentally demanding?
• Do people working on the boat say they’re tired a lot or at particular times of trips?
• Does the crew report feeling excessively tired, or have health problems that affect their sleep?
• Do employees commute long distances to work?

The use of alcohol and drugs can also lead to people falling asleep or becoming fatigued when they normally wouldn't.

How can I tell if someone is fatigued?

Someone who is fatigued won’t always look or feel fatigued, particularly if they have come off a ‘high’, such as handling a good catch. It sometimes helps to think about the amount of sleep a person had recently, and what kind of work they have been doing. This "history" helps to identify if someone is at risk of being fatigued.

People who are fatigued might:

• Be very irritable (more than usual)
• Be uncommunicative, or unclear when they talk
• Forget things quickly, like something you’ve just told them or how to do something they know how to do
• Be unable to stay focused on a task
• Be preoccupied with parts of a problem, missing warning signs and losing “the big picture”
• Cut corners to get the job finished
• Take unusual risks
• Poor judgement of distance, speed and/or time
• Have slow reactions to things that happen, or people talking to them
• Slurred or muddled speech
• Clumsiness
• Be obviously asleep

Legal Requirements

• Fatigue is a hazard under the HSE Act.
• Employers have to take all practicable steps to manage fatigue as a hazard and need to involve employees in identifying fatigue problems and how to control them.
• Maritime New Zealand will be requiring every vessel owner to develop and have approved a Fatigue Management Plan as part of the SSM Manual, where fatigue is a significant hazard.

How can we manage fatigue on board our vessel?

If people on your vessel are at risk of fatigue, the skipper will need to write a fatigue management plan (which is the details about how you are going to manage fatigue as a hazard). There is more information about fatigue management plans later in this section.

If fatigue is not an issue for people on your vessel, everyone involved (owner, skipper and crew) should agree that fatigue doesn't need to be actively managed at the moment. The skipper should write down when and why you decided to do this (so that anyone checking your hazard management systems knows you've thought about it).

Action Points

• There is no one right way to manage fatigue – the solutions need to fit your boat, its operation, and the skipper and crew who work on board
• Owners, skippers, crew, partners and safety advisors should be involved in developing the fatigue management plan
• Everyone should learn about fatigue. It’s a good idea for everyone to attend a training session about fatigue management.
• Make sure everyone regularly has time off for sleep. A minimum of six hours continuous sleep in every 24 hours is recommended (time sleeping is not the same as time off)
• Take short naps whenever possible (40 minute and two hour naps are the best timing, if you want to work soon after waking up). This works best before a person actually gets tired.

For Skippers

• Assess whether fatigue is a significant hazard and develop a Fatigue Management Plan
• Work out what you’re going to do when things occasionally go wrong and you can’t stick to your Fatigue Management Plan. (These Contingency Plans should form part of the Fatigue Management Plan)
• Make sure you are regularly reviewing levels of fatigue and how well your Fatigue Management Plan is working. You could make fatigue an item at each of your regular safety meetings. Any time you monitor or review the plan, make a note in your SSM Manual. This will prove that you’re doing what is required.
• Make sure everyone has somewhere dry and light-proof to sleep
• Talk about fatigue with the crew before they actually get tired. Make sure they know you know its human to get tired and that it’s better to admit it than hide it
• Provide healthy food
• Plan ‘rest days’ so that cumulative fatigue doesn’t become a problem.
• Work out in advance how you’ll cope if someone gets fatigued
• Install watchkeeper alarms if appropriate. It is important not to rely solely on watchkeeper alarms as some people will sleep through them. The long-term solution is good planning and management of the watch activity.
• Make sure people on watch at night have activities to keep them active.
• Provide caffeine and energy drinks which can help keep people alert for short periods of time
• Make sure watchkeepers feel comfortable waking someone else if they get tired

A Fatigue Management Plan

A fatigue management plan is an organized way of managing fatigue as a hazard. In practice, a good fatigue management plan has two major parts –

• What to do on the boat to manage fatigue; and
• What the owner or skipper has to do to keep an eye on how the plan is implemented and make sure it’s up to date.

The owner, skipper and crew should work together to develop the fatigue management plan. Everyone has different job demands and experiences fatigue differently.

If you have decided that fatigue is a significant hazard on board your vessel, you need to show that you have thought about

• Why people are getting fatigued
• How you can stop it happening
• How you can cut down on how much it happens.

You should also look at how you will deal with someone who is fatigued. When you’ve worked these things through, you need to write them down.

The fatigue management plan should be put up where everyone can see it and read it. A laminated sheet on the bridge and in the crew mess is a good way to do this. How the plan will be monitored and kept up to date should go in the SSM manual.

Some stress is good for us. If we don't have enough challenges, it can be hard to "get going" however, if we have too many challenges, we may get stressed and not cope as well. We need the right balance. Whether stress is ‘good’ or ‘bad’ depends on the individual - everyone reacts in different ways. As a general rule though, stress which goes on for a long time will be bad for a person and for the people they’re working with. The right balance can also change over time.

Workplace stress is defined as when someone becomes aware that they are not able to cope with the demands of their work environment, and they have a negative emotional response to that awareness. The key is that they are overwhelmed by the situation and they care about feeling that way - it is having an impact on their happiness or enjoyment of life.

Stressors are things that lead to someone feeling that they are unable to cope with either physical or psychological demands.

Stressors can:

• Be because of things that make the job what it is – for example, the peak workloads in fishing, knowing that the work of being a commercial fisherman is to some degree inherently dangerous, working in cramped conditions on board a vessel.
• Arise because of the way the work is organised. This can include physical factors (such as cold, wetness, noise etc.) as well as physiological factors (such as shift work, lack of time to rest etc.)
• Arise out of excessive work demands such as unrealistic deadlines
• Arise out of personal factors such as health status, relationships, ability to cope with difficult situation etc.

Is stress a significant hazard on my vessel?

In terms of legal liability, an employer is required to take all practicable steps only for those circumstances that they know or ought to know about. If someone says they are stressed, or is acting in such a way that most people would agree they were stressed, then you need to do something.

Fishing work can be difficult for people to cope with. People work long hours and in bad weather. There is not much space on the vessel to get away from other people. This means that owners and skippers need to be looking out for signs of stress in the crew and, where you find it, have effective systems in place to deal with it.

The situation on each vessel will be different. To decide if stress is a significant hazard, you should ask yourself the following questions:

• Is the work emotionally draining or unpleasant?
• Does the work require intense, prolonged concentration?
• Would a mistake have big consequences?
• Is the work inherently hazardous?
• Is the workload unrealistic?
• Is the work too hard for the person?
• Are there factors such as persistent bullying in the workplace?
• Are people separated from their families and/or friends for long periods of time?
• Are people forced to both live and work in close confines with people that they may not necessarily get along well with?

How can I tell if someone is stressed?

Stress is a complex issue. No two people will react in exactly the same way to situations. Owners and skippers need to watch for signs of stress in people who are working on the vessel. Crew need to tell the skipper or owner when they’re feeling stressed, and know that everything possible will be done to deal with the situation.

People who are stressed might show some of these signs:

• Not being aware of safety issues or putting themselves into harm’s way
• Long-term health problems such as depression, ‘burnout’ and heart disease
• Being ‘down’, anxious, irritable of clinically depressed
• Lose confidence, talk about sleeping badly, have slow reactions or behave oddly
• Not be able to get along with people that they used to work well with
• Be irritable or indecisive, or perform poorly and make more mistakes
• Drink more alcohol than usual or use recreational drugs
• Complain about their health and, for example, get frequent headaches.

Legal Requirements

• Stress is a hazard under the HSE Act. It must be managed like any other hazard. Don't wait until an employee has a physical or mental health problem before taking steps to deal with stressors in the workplace.
• The law only requires employers to manage work stressors or the individual’s stressed situation when you can be reasonably expected to know about the stress. Employers then need to do what can reasonably be done in the circumstances to manage the stress.
• Crew should be involved in identifying stress problems and suggest ways to control them.
• There need to be systems in place to assess and deal with identified stress, whatever the source, if the stress places that employee or anyone in the workplace at risk of harm.
• Employees must have confidence that if they report the situation (experiencing stress) that something will be done about it.
• Employers have no direct control over (nor responsibility for) non-work factors. However, if an employer knows about non-work sources of stress, steps may need to be taken to prevent harm where the safety of people in the workplace – the employee included – may be an issue.

How do I manage stress as a hazard?

For all crew

• Identify areas pf the work that are inherently stressful - the list of stressors at the begining of this section.
• Work with the skipper to figure out how to eliminate or reduce the impact of those stressors
• Learn ways that help you to manage your own stress levels.
• Tell your skipper when stress levels get too high.

For the Skipper

• Make sure that work practices on your vessel don't cause unnecessary stress, and have systems in place to deal with crew member stress. You are not required to monitor all your crew members' stress levels all the time. You are required to put things in place to minimise stress and if a crew member says they are stressed you need to take this seriously
• Where possible, create clear work routines and operating procedures so there is a more predictable work environment.
• If a crew member is consistently unable to carry out their work because of non work stress factors, manage this as you would any performance issue. Talk to the crew member about your concerns and work out a way to resolve the situation if possible (remember you only have to take ‘all practicable steps’ to deal with the hazard).
• Be aware that someone who is suffering from stress may be a danger to themselves or to others while working.
• Work out how you will handle a situation where a crew member tells you that they are stressed. Document this and make sure that the crew know that there is s system in place for dealing with stress and that everything possible will be done to deal with the situation in a confidential manner.
• Consider how you will decide whether a crew member is coping with their work or whether they are affected by stress. Schedule time to regularly think about whether stress is a problem on your vessel. Make sure you treat each person as an individual, as different people cope with things in different ways.
• Ensure that there are different activities available on board to allow people to relax on their off duty hours.
• Make sure that there is adequate time available for rest.
• Work to create a supportive environment on board the vessel, and recognition of people’s different needs for space and time to themselves.
• Carefully investigate any crew claims of feeling stressed and put in place any necessary measures to reduce their stress levels.
• Make sure you identify the things in the job that are inherently stressful, and talk about them with potential employees before you offer them the job.

Drug and alcohol abuse on the vessel can cause serious problems. This makes it a serious health and safety issue.

Alcohol and drug use affects the:

• Ability to make good decisions
• Co-ordination
• Motor control
• Concentration and alertness.

Some crew members may use prescribed drugs for health conditions. The skipper needs to know about this, and of how to manage any side effects from medication or from the health condition requiring the medication.

Why is the use of Alcohol and Other Drugs on board the vessel a hazard?

Here is a list of problems that might happen when people use alcohol and other drugs on board:

• Potential for misuse of machinery or equipment
• Increased risk of causing harm of injury to self or other employees
• Falling from heights, into holds, overboard, boarding and leaving vessel etc.
• Decreased skills, poor judgement, slower reaction times
• Inappropriate behaviour, like fighting, abusive language
• Increased risk of fatigue.

Legal Requirements

• Alcohol and drugs are defined in the HSE Act as hazards. Employers should check to see if they are a significant hazard on the vessel.
• The Misuse of Drugs Act 1975 makes it an offence for anyone to procure (buy or receive), or have in their possession, or consume, smoke or other use, any controlled drug. It is also an offence to supply or offer to supply or administer, and Class C controlled drug to any other person.
• It is illegal to bring controlled drugs onto a vessel. The possession or use of illegal drugs on the boat should not be condoned or allowed.
• It is also illegal to possess instruments (pipes, bongs, syringes etc) for the purpose of taking illegal drugs.
• Parents and guardians are the only people who can supply alcohol to people under the age of 18.
• If you have an accident or are injured while under the influence of alcohol or other drugs, this can affect your ability to claim insurance.

Action Points for everybody

• If there is an alcohol and drug policy for the vessel, follow it.
• Don't bring illegal drugs on board the vessel.
• Don't use illegal drugs on board the vessel.
• If you are allowed to drink alcohol on the vessel, don't drink too much or too close to when you need to be ready for work.
• Don't use machinery or steer the vessel when you are under the influence of drugs or alcohol.

For the Skipper

• Develop a policy on the use of alcohol and other drugs at work. The policy should apply to everyone. It should be developed in consultation with crew and given to each new and existing crew member.
• Make sure that everyone who works on the boat is regularly reminded of the policy on the use of alcohol and other drugs at work and the consequences of not complying with it.
• It is strongly recommended that the use of alcohol and other drugs be banned on board the vessel. The use of alcohol and other drugs can impair judgement and result in people affecting the health and safety of themselves and others on board the vessel.
• State and reinforce that it is unacceptable behaviour to bring illegal drugs onto the vessel, or use them on the vessel.

How do I develop an Alcohol and Drug Policy?

An alcohol and drug policy is a way to set out what you expect of all those working on the vessel. The policy should aim to eliminate or minimise the hazards associated with the use of alcohol and other drugs in the workplace. Develop the policy in consultation with all those who are going to be affected by it.

The policy should cover the following areas:

• Why a policy is needed – the importance of preventing harm and managing hazards
• Scope – that the policy covers everyone who comes on board the boat, including visitors
• Infringements – what is an infringement, and what will happen if someone doesn’t follow the policy
• How to tell when someone is affected by drugs and alcohol – list the common signs and symptoms of being under the influence
• How to deal with an intoxicated person
• Information and training – explain what training and information around managing the hazards of alcohol and drug use will be given and what it will cover
• Workplace induction – how skippers/crew/sharefishers/visitors will be made aware of the policy
• Confidentiality – make sure everyone understands that any action taken under the policy will be confidential and how you will ensure this happens
• Screening/testing – if applicable, explain the company’s screening and testing procedures.

It is strongly recommended that the use of alcohol and other drugs on board the boat be prohibited.

If alcohol is used on board the boat, an alcohol policy also needs to cover:

• When it is considered appropriate to drink alcohol;
• Acceptable standards of work performance; and
• A prohibition on being drunk on the boat.