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Frequently Asked Questions (FAQ) Document for ANSI/API RP 755, Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries API 755-2 FIRST EDITION, APRIL 2016 Special Notes API publications necessarily address problems of a general nature With respect to particular circumstances, local, state, and federal laws and regulations should be reviewed Neither API nor any of API's employees, subcontractors, consultants, committees, or other assignees make any warranty or representation, either express or implied, with respect to the accuracy, completeness, or usefulness of the information contained herein, or assume any liability or responsibility for any use, or the results of such use, of any information or process disclosed in this publication Neither API nor any of API's employees, subcontractors, consultants, or other assignees represent that use of this publication would not infringe upon privately owned rights API publications may be used by anyone desiring to so Every effort has been made by the Institute to assure the accuracy and reliability of the data contained in them; however, the Institute makes no representation, warranty, or guarantee in connection with this publication and hereby expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any authorities having jurisdiction with which this publication may conflict API publications are published to facilitate the broad availability of proven, sound engineering and operating practices These publications are not intended to obviate the need for applying sound engineering judgment regarding when and where these publications should be utilized The formulation and publication of API publications is not intended in any way to inhibit anyone from using any other practices Any manufacturer marking equipment or materials in conformance with the marking requirements of an API standard is solely responsible for complying with all the applicable requirements of that standard API does not represent, warrant, or guarantee that such products in fact conform to the applicable API standard Nothing contained in any API publication is to be construed as granting any right, by implication or otherwise, for the manufacture, sale, or use of any method, apparatus, or product covered by letters patent Neither should anything contained in the publication be construed as insuring anyone against liability for infringement of letters patent Per API's Procedures for Standards Development, the following definitions apply: Shall: As used in a standard or recommended practice, “shall” denotes a minimum requirement in order to conform to the standard Should: As used in a standard or recommended practice, “should” denotes a recommendation or that which is advised but not required in order to conform to the standard NOTE This Frequently Asked Questions document was developed by a group of subject matter expert volunteers representing a cross section of the refining industry All rights reserved No part of this work may be reproduced, translated, stored in a retrieval system, or transmitted by any means, electronic, mechanical, photocopying, recording, or otherwise, without prior written permission from the publisher Contact the Publisher, API Publishing Services, 1220 L Street, NW, Washington, DC 20005 Copyright © 2016 American Petroleum Institute Foreword Nothing contained in any API publication is to be construed as granting any right, by implication or otherwise, for the manufacture, sale, or use of any method, apparatus, or product covered by letters patent Neither should anything contained in the publication be construed as insuring anyone against liability for infringement of letters patent Suggested revisions are invited and should be submitted to the Director of Downstream, API, 1220 L Street, NW, Washington, DC 20005 iii Frequently Asked Questions (FAQ) Document for ANSI/API RP 755, Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries Foreword 0.1 Are the “shall” statements in regards to work sets and shift duration truly mandatory, or can owner/operators modify these values as they see fit based on risk analysis? As noted above, the use of API publications is voluntary (or non-mandatory) For API publications, the following definitions apply Shall: As used in a recommended practice, “shall” denotes a minimum requirement in order to conform to the RP Should: As used in a recommended practice, “should” denotes a recommendation or that which is advised but not required in order to conform to the RP Scope For purposes of this FAQ document, the term “employee”, unless otherwise stated, is the person covered by RP 755 1.1 Does this RP apply to employees that live in company provided housing adjacent to the facility where they work? No RP 755 scope says: This document is intended to apply to a workforce that is commuting daily to a job location The intent is for the document to address employees who commute from home to work Terms and Definitions 3.0.1 Is mandatory training considered a shift? A shift is considered as or more hours worked, regardless of whether the time worked is for training or performing the regular job 3.0.2 Is a work set only regular scheduled shifts (i.e × for maintenance, 12-hour rotating for operations)? No A work set is defined as consecutive shifts with a minimum of 36 hours off (or 48 hours off for night shifts and 84-hour work sets) before starting another work set Work sets are dynamic, meaning they are a combination of regular scheduled shifts and overtime shifts an employee works, so the number of shifts can vary from work set to work set Consecutive shifts are shifts worked without the minimum hours off needed to end the work set 3.0.3 Are the same definitions for holdover and extended shifts applicable when the time occurs prior to the regular scheduled shift? Yes The definitions for extended shifts and holdovers are linked to the number of consecutive hours worked regardless of whether the additional hours occur before or after the regular scheduled shift -3 3.0.4 API RP 755, Section 4.8.1.3, states that “extended shifts (longer than 14 hours) shall occur only when necessary to avoid an unplanned open safety-critical position or accomplish an unplanned safety-critical task.” Does this mean that the only allowable extended shifts are for these reasons, even if an exception is written? An extended shift up to 14 hours long (regardless of the length of the scheduled shift) would be acceptable for other reasons, but an extended shift over 14 hours is only allowable for those reasons 3.0.5 Would an extended shift longer than 14 hours for training be allowable if an exception is written? No However, for a regularly scheduled 12-hour shift, an employee could work additional hours on trainingrelated activities without an exception; employees on 8- and 10-hour shifts could also work up to 14 hours for training purposes 3.0.6 How is “sleep debt” described? In TR 755-1, sleep debt is described as accumulated sleep deprivation 3.1 Call Out 3.1.1 Does a call out count as “hours worked”? Yes Options on how to record hours worked include attaching those hours to the closest shift prior to or after the call out or as a stand-alone shift RP 755 addresses call outs under 4.8.4 of the Hours of Service section: “because call outs by their nature involve unpredictable patterns of work and rest, attention should be given to call out practices to ensure adequate rest prior to returning to work.” “Returning to work” includes either the call out or returning to the next regular shift In these cases, additional fatigue risk mitigation steps should be considered Refer to TR-755, Section 4.8.4, for additional information on call outs 3.4 Holdovers 3.4.1 Is a holdover of up to hours for training, safety meetings, or any other purpose other than the person’s regular work or covering someone else’s regular work exempted from being defined as an extended shift and possible need for following the exception process? Holdovers are considered extended shifts but not require the exception process unless the holdover results in a shift duration that exceeds the Hours of Service limits Extended shifts are defined as time an employee is assigned to work that extends outside their regularly scheduled shift hours A holdover is defined as a periodic, occasional extended shift where employees are at work beyond their regular shift to participate in training, safety meetings, and the like This does not include time needed for normal shift handoff RP 755 does not require use of the exception process for shifts up to 14 hours 3.7 Outages 3.7.1 Who will determine when an outage is occurring? RP 755 does not define who determines when an outage occurs Each facility/company should decide the process and approval(s) for declaring an outage and include that in their site specific FRMS -2 3.7.2 In the event of an outage, who will be considered affected? Anyone working in units whose work schedule is impacted by the outage, as determined by management 3.7.3 Why are more consecutive shifts allowed in an outage than in normal operations? The Hours of Service limits recognize the need to appropriately manage business activities, especially in abnormal situations, which is why additional flexibility is allowed in an outage Outages take place for limited periods of time and generally are not routine operations Employees usually work fixed shifts during outages and minimize their non-work family and social commitments, and thus have more opportunity to adapt their sleep schedules (See TR 775-1 for further information.) 3.9 Work Sets 3.9.1 Can a work set be one shift? Yes A work set is defined as consecutive shifts with a minimum of 36 hours off before starting another work set Therefore, if one works a single shift prior to 36 consecutive hours off, the work set is one shift 4.1 Roles and Responsibilities 4.1.1 Why are employees responsible for being aware of their own fatigue since research indicates the individual is the least likely to recognize fatigue? API RP 755 states that, “everyone has a role in recognizing the importance of workplace fatigue risk mitigation and actively working to support the goals of the FRMS.” Companies provide training to employees to help them proactively manage fatigue and, through the Hours of Service guidelines, provides the opportunity for adequate sleep However, only the employee knows whether the rest obtained during the time away from the workplace was adequate To supplement self-awareness of fatigue, the FRMS also provides for the training of supervisors to recognize the signs and mitigate the fatigue risk However, the employee is ultimately responsible for securing adequate sleep during non-working hours 4.1.2 How should a supervisor respond when an employee expresses concerns about being fatigued? Similar to other fitness-to-work situations, concerns regarding employee fatigue should be evaluated on a case by case basis to determine the appropriate course of action For example, supervisors may address fatigue by recommending actions to enhance alertness, sending an employee home, or referring an employee to medical services Persistent patterns of fatigue may be addressed through performance management and/ or referral to resources that can assist the employee address the root causes 4.2 Positions Covered by the Fatigue Risk Management System 4.2.1 RP 755 mentions that the guidelines are intended for “employees working night shifts, rotating shifts, extended hours/days, or call outs involved in process safety sensitive actions.” Do the guidelines apply to straight day shift employees? -1 According to RP 755, straight day shift employees are not subject to night shifts or shift rotations that increase the likelihood of fatigue, so the hours of service limits not apply unless they are subject to extended hours or call outs However, site-specific FRMS plans may choose to include limits such as applying the outage hours of service limits to such employees, particularly if they are engaged in process safety-sensitive positions 4.2.2 How are individuals that work both covered and uncovered positions addressed under the standard? If an individual works both covered and uncovered positions during their work set, all hours/days worked during the current work set and the work limitations will apply at the time they are working in a covered position For example, if an individual works as instrument mechanic (covered position) and then he is stepped up to a contractor coordinator (non-covered position) during the same work set without a rest period, then the individual would not have a limit on the number of consecutive days if he stayed in this non-covered position If the individual moves back to a covered position and has exceeded the consecutive day limitations, then he would require a rest period before returning to the covered position 4.3 Staff–Workload Balance 4.3.1 Is an initial staff–workload balance assessment a requirement of the RP? While there is no specific “shall” statement in RP 755 regarding an initial staff–workload balance assessment, the document does state, “the FRMS includes an initial and periodic assessment of the staffing levels and workload balance, such that the implementation of the hours of service guidelines discussed below are feasible and that fatigue risk is adequately managed.” 4.3.2 The FRMS includes an initial assessment of staffing levels What are some guidelines on how to conduct this assessment and interpret the results? RP 755 does not specifically address how to conduct this assessment Several resources, such as TR 755-1, the American College of Occupational and Environmental Medicine (ACOEM) Guidance Statement; Fatigue Risk Management in the Workplace, and the International Petroleum Industry Environmental Conservation Association (IPIECA)/International Association of Oil and Gas Producers (OGP) Performance Indicators for Fatigue Risk Management Systems provide further information 4.4 Safety Promotion: Training, Education ,and Communication 4.4.1 Does training time count as “hours worked”? Yes 4.8 Hours of Service Limits 4.8.0.1 If I get appropriate sleep each night, why does it matter how many consecutive shifts I work? API, in conjunction with fatigue experts, evaluated the subject of workplace fatigue It was determined that a comprehensive FRMS that includes limits on consecutive hours worked per shift and consecutive shifts in a work set was the best approach for managing fatigue within our industry 4.8.0.2 How is transitioning to or from an Outage work schedule to or from Normal Operations handled in terms of applying Hours of Service Guidelines? When transitioning to an Outage condition, the current work set for affected Covered Individuals should start with the individual’s last rest period (the start of the current work set following the individual’s last time off period) When transitioning back to Normal Operations, the work set under the Hours of Service Guidelines for Normal Operations starts after the next minimum rest period For example, a person has worked four 12-hour shifts under Normal Operations when an Outage is declared.The person continues working under an Outage and the shifts already worked are deemed to have been worked under an Outage The person works shifts under the Outage and the unit resumes Normal Operation The person continues to work under the Outage Hours of Service Guidelines until he completes that work set by taking 48 hours off So the person could potentially work up to more shifts (for a total of 14 shifts) under the Outage When he returns after taking time off, he resumes working under Normal Operations 4.8.0.3 RP 755 indicates consistently working up against limits is not sustainable How you measure what is sustainable? An operator could work significant overtime and not generate an exception as defined by the Hours of Service limits For example, an operator could work 12-hour days for days, take 36 hours off, return to work on night shift and work 14-hour nights for days, take 48 hours off, and return to day shift This cycle could be repeated indefinitely and not trigger an exception per the Hours of Service limits defined but may pose a fatigue risk According to RP 755, “consistently working at the limits shown is not sustainable and may lead to chronic sleep debt The overall FRMS shall be designed to prevent employees from frequently working at or near these limits over the long term.” RP 755 sets outer boundaries that are sufficiently non-restrictive to allow for the full range of fatigue risk mitigation strategies to be implemented, but firm enough to prevent abuses of managerial discretion This is meant to convey the concept that while any given work-set may reach the Hours of Service limits, it is not the intent that employees work seven 12-hour shifts followed by days off repeatedly The standard intentionally did not define exactly how that should be achieved However, Section 4.9 identifies relevant factors that can be used to set targets, including “percentage overtime (median, mean—top of 10% of employees), number of open shifts, number of extended shifts, length of work sets, and number of exceptions.” Many of these can be used to assess whether adequate time off is being provided to employees 4.8.0.4 Can the 36-hour minimum time off after a work set be reduced to enable a shift handover of approximately 15 minutes at the end of a shift? Yes, RP 755 envisioned routine brief hand-off periods at the beginning/end of shifts so that a typical 12-hour shift would actually be 12 hours and enough time for a safe handover 4.8.0.5 Based on the 2-hour limit for holdovers, does it mean the minimum time off of 36 hours can be reduced to 34 hours and not require an exception or be considered a non-compliance with the Hours of Service limits? That is a reasonable application of the standard; however, it should be noted that a holdover is a “periodic, occasional extended shift where employees are at work beyond their regular shift to participate in training, safety meetings, and the like.”The intent is not to use them routinely to extend the length of the shift 4.8.0.6 For a 12-hour shift schedule, can a day shift precede consecutive night shifts? Yes, the work set would be shifts total consisting of day shift and consecutive night shifts, which would require a 48-hour rest period 4.8.0.7 A 12-hour shift schedule employee works Friday, Saturday, and Sunday day shifts; is off on Monday; then works Tuesday, Wednesday, and Thursday night shifts Does calling the employee in to work the Monday between the work set (either day or night) generate an RP 755 exception? No In this scenario, the employee would have a work set of consecutive day and night shifts because there is no break greater than 36 hours to reset the work set This falls within the RP 755 limit of consecutive 12hour day or night shifts and does not generate an exception This is assuming the employee’s rest period before the Friday day shift was sufficient to reset the employee and begin a new work set 4.8.0.8 If an employee works consecutive 12-hour day shifts, then has a 36-hour rest period that includes evenings (i.e rest period begins at p.m and employee returns to work 36 hours later at a.m.), is this rest period sufficient to reset the employee and begin a new work set? Yes For 12-hour shifts, RP 755 specifies a 48-hour rest period is required if 1) 84 hours are worked in a day period or 2) the work set includes consecutive night shifts Since neither of these conditions is met, a 36hour rest period is sufficient for a reset 4.8.0.9 If an employee works consecutive 12-hour night shifts and then has a 36-hour rest period (i.e., rest period begins at a.m and employee returns to work 36 hours later at p.m.), is the rest period sufficient to reset the employee and begin a new work set? No For 12-hour shifts, RP 755 specifies a 48-hour rest period is required if 1) 84 hours are worked in a day period or 2) the work set includes consecutive night shifts Since the 48-hour rest period is not met, the work set is not reset The work set that began with consecutive night shifts would continue through the abbreviated rest period and any days worked after the rest period would be included in the work set 4.8.1 Twelve-hour Shifts 4.8.1.1 If I am scheduled to attend a 4-hour training course following my shift, can I work a 16-hour shift prior to the start of the training? No The training would be added to the hours worked in the original shift 4.8.1.2 If an individual works consecutive shifts for a total of 83 hours, what is the minimum time off? The minimum time off is 36 hours if the shifts were day shifts or 48 hours if they were night shifts 4.8.1.3 If an employee works day shifts Monday through Thursday, is the employee eligible to work a day shift on Friday? Yes An employee would be eligible to work an overtime shift after day shifts since the maximum number of consecutive shifts has not been reached 4.8.1.4 How are meals or other allowable work breaks considered for purposes of determining worked shift length? If a person works a 12-hour shift but within that 12-hours is a 30-minute meal break, does that allowable break count toward the 12-hour shift length for applying Hours of Service Guidelines? Does it matter whether the lunch period is paid or if the person is allowed to leave the site? If a person is allowed to leave the site for their meal break but chooses not to, does that matter? Meals that occur after clocking in and prior to clocking out count toward hours worked 4.8.1.1Twelve-hour Shifts—Normal Operations 4.8.1.1.1RP 755 requires a minimum of 36 or 48 hours after a work set depending on days/nights However, there is also a comment that holdover periods should not exceed hours This implies that up to 2-hour holdovers are acceptable Does that mean that the operator has to report to work hours later on their next work set if held over for up to hours at the end of their prior work set to not cause an exception? No However, it should be noted that a holdover is a “periodic, occasional extended shift where employees are at work beyond their regular shift to participate in training, safety meetings, and the like.” The intent is not to use them routinely to extend the length of a shift 4.8.1.3 Twelve-hour Shifts—Extended Shifts 4.8.1.3.1It is not clear that a shift extending longer than 14 hours and less than 16 hours is an exception unless more than shift of longer than 14 hours (and less than 16 hours) occurs in a work set The “no more than shift in a work set” language uses the word “should”—does that make this an exception or a recommendation? Any shift longer than 14 hours is an exception and only shift longer than 14 hours should occur in a work set The fatigue risk increases with the length of the shift thus additional mitigation steps are needed The RP states that the exception process should be followed when the Hours of Service limits are exceeded 4.8.3 Eight-hour Shifts 4.8.3.1 Maintenance staff at a facility is regularly scheduled to work Monday–Friday, hours per shift Staff is occasionally called out after their regularly scheduled hours or on weekends for maintenance activities that cannot wait until the next regularly scheduled shift Assuming the work is involved in process safety sensitive actions, is this a covered position? Is there a frequency of call outs that would or would not require the position to be a covered position? Yes, it is a covered position, and no, there is no set frequency 4.8.5 Exceptions 4.8.5.1 How should exceptions to the Hours of Service guidelines be tracked? For example, if an operator during Normal Operations worked an 8th consecutive day, exceeded a 16-hour shift, and therefore then did not have the required 36 hours off before returning to their next work set, is this exception or exceptions? RP 755 allows flexibility in how organizations that adopt the recommended practice count exceptions Therefore, either “exception” tracking approach noted above is reasonable For periodic review of metrics, there is value in greater granularity in capturing all the exceptions (i.e vs in this case) 4.8.5.2 Are there limits to the number of exceptions that can be made deviating from the Hours of Service Limits? No There are no limitations regarding the number of exceptions to the Hours of Service Limits However, the number of exceptions should be one of the metrics tracked to determine overall effectiveness of managing fatigue risk as well as opportunities for continuous improvement 4.8.5.3 If an employee works consecutive 12-hour night shifts and then reports back to work for additional night shift after 36 hours off, is that an exception? No There was insufficient time off to end the work set; however, since there are fewer than consecutive shifts, it is not an exception Note that the shifts after this 36-hour break are counted towards the day limit on consecutive 12-hour shifts 4.8.5.4 What is meant by “planned mitigation steps”? Longer-term steps to avoid having future exceptions or shortterm mitigations to ensure the operator is not at risk due to potential fatigue related mistakes/actions? In this context, mitigation steps refer to the latter RP 755 contemplates that longer-term steps would also be considered as part of the continuous improvement process 4.8.5.5 For extended shifts that result from short notice (i.e a relief operator not available for shift, abnormal operating conditions, ongoing safety critical activities, etc.), is the exception process expected, including a risk assessment and mitigation plan? Yes It is important to assess whether there are alternatives to an extended shift and what can be done to minimize fatigue and/or the risk associated with fatigue during the extended shift However, if the extended shift is less than 14 hours long, no exception is necessary This gives supervisors hours to take action to avoid an exception (e.g contact another employee to come in and complete the shift) or follow the exception process General Scenarios 5.1 If an individual takes a 1-day vacation, will this start a new work set? A new work set will begin after an individual has had a minimum of 36 hours off The start of a new work set could be triggered by time off including a 1-day vacation 5.2 What practices apply as an individual transitions out of an Outage? How each refinery handles the transition out of an Outage is at their discretion One way to address this situation is that all employees must have a break and revert to normal schedules within the first shifts after the end of the outage or by the end of the 14 consecutive shifts, including those as part of the Outage, whichever comes first 5.3 For Outages, is there any difference between working a day or night schedule? No The same Hours of Service Limits apply whether you are assigned to a day or night schedule during the Outage 5.4 Is an employee working on special projects considered covered under FRMS? What about if the employee is in an office setting Monday–Friday, and then work their weekend out in the field, and then work Monday– Friday again in the office[RC1]? If any portion of their work set was spent performing process safety sensitive work, they are considered covered under FRMS and scheduling guidelines shall apply If their entire work set was spent performing nonprocess safety sensitive work in an office, classroom, etc., then companies may choose to exempt them from coverage under the FRMS 5.5 Why are covered maintenance employees only allowed to work extended shift (14–16 hours) in a work set? To allow adequate time for sleep and to minimize fatigue For further information on this matter, see TR 755-1 Product No K755201