Fatigue risk management guidance for policing

Many factors of everyday life contribute to fatigue. The causes can either be work-related, for example, shift work or long working hours; or individual, such as caring responsibilities at home or other lifestyle aspects.  Individuals also differ in their ability to cope with shift work, and some research shows that older workers generally cope better with the demands of early shifts and experience more difficulties with night shifts. 

In addition, fatigue can be acute or chronic, where acute sleep loss is not obtaining required sleep for one night, and chronic fatigue is cumulative sleep loss, or not getting sufficient sleep for multiple consecutive days.

Signs and symptoms of fatigue can vary widely, and some are easier to spot than others. The following are examples that may indicate a worker is fatigued:

• Yawning;
• Reduced communication skills;
• Reduced decision-making ability;
• Reduced productivity;
• Increased reaction time.

In addition, a fatigued worker may also experience symptoms that aren’t always obvious to others, such as:

• Feeling sleepy;
• Headaches;
• Difficulty concentrating;
• Impaired vision;
• Lack of motivation;
• Depression.

Working shifts and irregular hours causes sleep deprivation and fatigue. This is because humans are designed to be active through the day and to sleep at night, so we are working against the natural circadian rhythm. Circadian rhythm is the body’s 24-hour internal clock that helps us perform essential functions by regulating cycles of sleep and responding to light changes in our environment. Fatigue, along with irregular and disrupted sleep, are often seen as “normal” aspects of policing and police shift workers are often sleep deprived and in a constant state of “shift lag”, which is a term that refers to the associated disruption to circadian rhythms.

During the night, many of the processes that are active during the day slow down as our bodies prepare for sleep.  Melatonin, the ‘sleep hormone’ is also released at night, which has the effect of lowering alertness and increasing the desire for sleep.  Working at night involves battling against these rhythms.

Sleepiness and fatigue are repeatedly highlighted in the Oscar Kilo national surveys. This is why we have worked with international experts, to conduct a number of research studies and to develop police-specific resources.

Working with experts at Washington State University, Oscar Kilo have conducted pilot studies to evaluate training interventions. The studies gathered self-reported sleep, health, and wellbeing data from the participants and utilised actigraphy to measure sleep and wakefulness. A training package was then provided for participants, and the data collection was repeated. Findings indicated that the training programme resulted in improved sleep quantity and quality, increased sleep satisfaction, along with improved mental and physical health, and reduced Post Traumatic Stress symptoms. 

Access the training

To access the course you must have a College Learn account, available to anyone with a .police.uk email, they can be created on the College of Policing website 

Once you are logged in just search Fatigue Risk Management, the course lasts around 50 minutes.

If you have difficulties accessing College Learn please contact the College Customer Contact Centre at [email protected]

Fatigue reduces alertness, vigilance, and cognitive reasoning and therefore reduces performance.  Studies comparing the effects of lack of sleep to blood alcohol concentration have shown that sustained wakefulness of 20-24 hours produces decrements equivalent to being over the current drink drive limit in England and Wales (Dawson and Reid, 1997).

Circadian disruption, particularly that associated with night shift work, substantially degrades cognitive performance.  Humans are designed to be awake during the day and to sleep at night, so difficulties arise when we disrupt that pattern and the body clock becomes misaligned with the external environment.  When personnel change work patterns from day to night, adaptation is slow and may only be partial, which interferes with sleep, causing a sleep debt and impaired performance (Caldwell et al., 2019).

The probability of falling asleep, along with the subsequent sleep duration, vary significantly over a 24-hour period.  In view of the pattern of human sleep and wakefulness, it’s not unusual for accidents, incidents, and road traffic collisions to occur during hours when we are normally asleep.  Indeed, some high-profile incidents, such as the Exon Valdez, Three Mile Island, and the Chernobyl disaster have all been linked to fatigue. In short, the risk of being involved in an accident or being injured is substantially increased during times when we would normally be asleep (Williamson et al., 2011).

A FRMS is an evidence-based alternative, or addition, to HoW limitations that aims to identify and manage employee fatigue-related safety risks, in an appropriate way, whilst having an honest and open culture regarding the reporting of fatigue-related issues (Sprajcer et al., 2022).

As in any other workplace safety hazard, fatigue should be risk managed.  Fatigue is both an occupational and a personal risk factor (Schutte, 2010). Hence FRMS should be seen as a shared responsibility between an organisation and employees. The organisation should comply with legislation, provide schedules, and rotas that ensure sufficient opportunity for rest and recuperation, along with training and procedures for managing fatigue, suitable rest facilities and a means of reporting incidents or concerns.  Employees are responsible for using their free time appropriately, to ensure they are well rested and prepared for work.  In addition, they are responsible for attending any training provided and to report any instances of undue fatigue (Lerman et al., 2012).

A FRMS is a data driven system, allowing policies, procedures and practices to be developed and adapted to reduce safety risks.  It can utilise predictive, proactive, and reactive elements, including (but not limited to):

• Predictive – e.g. biomathematical models and fatigue informed rotas

It is helpful to assess current conditions in terms of current shift patterns and operations by, for example, collecting information on self-reported fatigue.  The national police wellbeing survey (Graham et al., 2023) does this and illustrates high levels of fatigue. Fatigue assessment tools can then help in identifying any specific factors contributing to the risk.

• Proactive – e.g. training, improving sleep habits, sleep disorder screening

Control measures can then be implemented, such as staff training or improved processes to reduce short notice shift changes or cancelled rest days.

• Reactive – e.g. reporting mechanisms and identifying risky behaviour / fatigue 

Evidence needs to be available of incidents, accidents and near misses, in order to review and implement improvements or necessary changes in operating procedures.

The Health and Safety at Work Act (1974), the Management of Health and Safety at Work Regulations (1999), and the Police (Health and Safety) Act 1997, impose a duty of care on employers in respect of employee physical and mental health, safety and welfare. For the purposes of the Police (Health and Safety) Act 1997, a person who holds the position of office of constable shall be treated as an employee. The duty of care  includes working practices and working hours, staffing levels, and supervision and training. In addition, there are also duties on employees to co-operate with their employer, and to take reasonable care of themselves and others – this includes taking positive steps to understand the risks in their work, such as causes of fatigue, and to comply with safety procedures. 

Legislation also specifies the need for employers to consult with employees regarding the introduction of measures likely to affect health and safety, such as, for example, a change in shift patterns (Health and Safety at Work Act 1974). 

Occupational health and safety affects all aspects of work, and the objective of legislation is to ensure that the risks to health and safety of employees are properly controlled.  Organisations are encouraged to demonstrate the importance of health and safety, improve health and safety management systems to reduce ill health and injuries, and report publicly on any issues within their organisation (Hughes and Ferrett, 2011).  In addition, effective management of health and safety is necessary for employee welfare, can enhance the reputation of the organisation and can be financially beneficial to the organisation (Hughes and Ferrett, 2011).

As a result of the European Working Time Directives (Cairns et al., 2008), the Working Time Regulations (WTR)  were introduced   The purpose of the WTR was to assist in regulating and monitoring the working hours of employees in order to provide safe and healthy working environments.

Employers are required to take all reasonable steps to provide this protection. For the purposes of these regulations, the ‘Office of Constable; is treated as employment, which means that the regulations also apply to police officers.  There are partial exemptions, however, such as spontaneous public order incidents, where it cannot be determined how long these may last, and therefore how long officers may be on duty (Wardman and Mason, 1999). 

Police officers are also governed by the Police Regulations 2003 that provide a statutory framework for working time, stipulating normal periods of duty and rosters, and the WTR have not changed this (Police Federation of England & Wales, 2006). This means that in some respects, the Police Regulations are considered more favourable than WTR because they also provide for annual leave, weekly rest and daily rest breaks.  For example, WTR allow for 2 days rest per fortnight, and Police Regulations allow for 2 rest days per week.  However, these provisions are subject to exigencies of duty, similar to the exemptions under the WTR, should an unforeseen event occur, in which case, usual patterns of work fall by the wayside (Police Federation of England & Wales, 2006). 

Employees also have a duty to take reasonable care of their own health and safety, and that of others at work who may be affected by their activities. Employers should take positive action to assist staff in understanding potential risks and causes of work-related fatigue, along with making them aware of relevant policies and procedures.

In terms of welfare and wellbeing, in addition to the specific health and safety legislation already discussed, the onus for welfare and wellbeing is on the organisation, and Chief Constables hold a statutory responsibility to manage the welfare of officers and staff (Home Office, 2018). Police officers and staff also often perform emotionally and physically demanding roles in a high pressure environment, and have been found to experience psychological distress and be at high risk of developing post-traumatic stress disorder (PTSD) (Green, 2004).  This can come about due to repeated exposure to physically or emotionally distressing and difficult scenes, or work demands such as extended shifts (Haslam and Mallon, 2003; Kinman et al., 2012).  In this respect, it is perhaps all the more important that work-life balance and officer welfare needs to be considered by employers when designing and implementing any changes to shift patterns (Eriksen and Kecklund, 2007). 

The most recent guidance regarding the design of working hours for policing was published following an agreement reached in the Federated Ranks Committee in 2010 (Home Office, 2010).  Based on academic research in policing, along with other shift working disciplines, this guidance is still relevant today. There are many aspects for consideration when designing shift patterns, such as balancing the needs of the officers and staff with the demands of the public, resource management and demand profiling, flexible working and forward planning. However, the basic guidance on roster design is outlined as follows:

The most effective and efficient shift arrangements are either the 2x2x2 or the five block variable shift arrangement (VSA) shift pattern.

When designing or reviewing such patterns, a particular shift pattern shall take into account the following principles:

• Shift lengths and start and finish times should be determined by local operational demands.
• A shift should ideally be between 8 and 10 hours in length.  12-hour shifts, whilst popular with some, are not recommended on the grounds of operational efficiency, service provision and health and welfare.
• Where possible, rest days are rostered no less than two together.
• Where possible, rosters should follow the sequence of earlies, lates and nights, unless there are sound reasons for not doing so.
• There should be no more than four consecutive night shifts.
• Where possible, overtime should be avoided at the end of a night shift.
• Rest days shall be planned to allow for recovery following night shifts.
• There should be no more than 6 consecutive shifts before a rest day.
• Regular shortfalls should be accommodated through the intelligent use of flexible working opportunities to fill areas of peak demand.

It must be recognised that, due to the nature of police work, published rostered shifts may have to be changed subject to the exigencies of duty; however, adherence to these principles should minimise such occurrences.

Health screening plays an important part in maintaining a healthy workforce, allowing early detection of potential health issues, often before any outward symptoms are noticeable.  Early detection allows for timely intervention, benefitting both the individual and the organisation, by reducing the potential for long-term absences from the workplace.

Night worker health assessments

In addition to the regulations and legislation set out above, all night workers are entitled to be offered a health assessment prior to beginning such work and at regular intervals throughout.  There is no specified time period in relation to ‘regular intervals’, instead, the legislation simply states ‘at regular intervals of whatever duration may be appropriate in his case’.  The regulations also specify that;

• There should be no cost to the worker for this assessment.
• There is no obligation for any worker to partake in a health assessment, it should simply be available should they so choose.
• The assessment should be confidential, unless the worker to whom it relates provides written consent for its disclosure, or any disclosure simply relates to the worker being ‘fit’.
• Where a registered medical practitioner has advised an employer that a worker is suffering from health problems believed to be connected to night work, and where it is possible to transfer that worker to a suitable role during periods where they cease to be a night worker, the employer shall transfer the worker accordingly.

Sleep, alertness, and fatigue in emergency responders (SAFER): Sleep disorder screening survey

In academic studies, policing has been identified as an occupation with a high prevalence of potential sleep disorders (Rajaratnam et al., 2011).  In addition, the National Police Wellbeing Surveys consistently illustrate reduced sleep and high levels of fatigue are common amongst police officers and staff (Graham et al., 2023).

We teamed up with experts at the University of Surrey to launch a sleep disorder screening programme. The Sleep, Alertness and Fatigue in Emergency Responders (SAFER) programme was provided by Professor Steve Lockley, who has been studying sleep and circadian rhythms for over 30 years.

While working at Harvard Medical School, he and his colleagues implemented similar education and screening programmes for police officers and firefighters and found that over a third of active-duty personnel were at risk of at least one sleep disorder, such as sleep apnoea, insomnia or shift work sleep disorder, without knowing it.

In follow-up studies, these programmes resulted in large numbers of police officers and firefighters seeking treatment for their sleep disorder, helping their long-term health. In one fire department study, this led to nearly a 50% reduction in reported long-term sickness and a 24% lower odds of having an accident or injury on duty.

The SAFER survey assesses your risk of sleepiness, major sleep disorders and burnout. It asks a number of questions on sleep and all answers are anonymous, so we will not know who you are.

After completing the questions, if the screening shows that you may be at risk of any of these disorders, then a letter will automatically be generated that you can save or print and take to your occupational health team or GP for further investigation. If nothing appears for you at the time, you are deemed not at risk.

Please note this process is not a diagnosis of a particular disorder but offers an indication that you might need to seek further investigation into the issue(s) identified in the letter.

Further information on the SAFER programme can be found here: 

Go to SAFER

Shift work is associated with a variety of health issues, including type-2 diabetes, heart disease, increased rates of stress, depression and sleep disorders.  It is for this reason that it is important to ensure shift workers are knowledgeable and can take a proactive approach in mitigating the risks.

Educating workers to better understand and manage their sleep and fatigue risk is a key factor in FRMS.  Issues such as undiagnosed or mismanaged sleep disorders, caring responsibilities or the absence of shiftwork lifestyle coping skills, may prevent employees from obtaining sufficient sleep, even when shift schedules provide adequate opportunity for rest and sleep.

Sleep, nutrition, and physical health are deeply intertwined and contribute heavily to overall health and wellbeing.  Each has a direct impact on the other and all three are important.  Research shows that if just one of these gets out of shape, it can affect the others, potentially leading to increased stress and an overall decline in wellbeing.

The Health and Safety executive recognise that driving for work is one of the most dangerous activities many workers will do. It is estimated that up to 1/3 of all road traffic incidents involve someone who is ‘driving for work’ (Health and Safety Executive, nd) and 20% of road traffic collisions are as a result of driver fatigue (Jackson et al., 2011).  Add to this the long working hours, shift work and heightened risk during emergency driving, all of which combine to increase the risk even further in policing.

Mitigation on shift can include education and training, along with health screening and suitable shift scheduling, such as is suggested earlier in this document.  In addition, consideration needs to be given to self-monitoring, dynamic risk assessments, journey management (closest unit deployment), time behind the wheel, behavioural interventions such as crewing policies or task changes, or supervisory interventions.

Commuting time, particularly following extended shifts or night shifts, which increases time awake, has also been associated with increased risk of sleep-related near miss incidents and collisions (Taylor, 2020). Time spent travelling to and from work does not provide rest.  In view of this, officers and staff should be encouraged to lift-share where possible or use alternative means of transport to driving (where available).  In addition, consideration should be given to decision making around excessive journey times and potential posting decisions.

There are now many varieties of in-vehicle technologies that can detect fatigue, or performance decrements due to sleepiness.  However, whilst these technologies are useful, what needs to be considered is that when related warnings are given, the driver is already impaired and transition to sleep has likely already begun.  In adopting education and training, along with suitable prevention measures and procedures, many issues could be prevented before this stage.