New Fatigue Framework Targets Overnight Shifts, Long Hours on Job Sites
A four-letter framework for managing one of the least-discussed hazards on job sites just got a formal push from a Toronto-based safety group, Safety+Health Magazine reports. The Infrastructure Health and Safety Association (IHSA) released a hazard alert calling fatigue a hazard that “creates serious safety risks” and urging employers to adopt a structured process called RACE: Recognize, Assess, Control, Evaluate.
Background
According to Safety+Health Magazine’s coverage of the IHSA alert, the association defines fatigue broadly as “a state of feeling exhausted or worn out, either in your body, your mind or both.” The group notes that nearly every worker will experience it at some point, meaning “every workplace faces some level of risk.”
IHSA lists early warning signs employers and crews should watch for: decreased alertness and strength, yawning, slurred speech, difficulty making decisions, and mood changes. The alert points to specific triggers common in field work, including long shifts, extended stretches without a day off, skipped breaks, frequent night or on-call rotations, and long commutes.
To control the risk, IHSA recommends limiting shift work, particularly overnight shifts, to only essential tasks, scheduling lower-risk work during high-fatigue periods, rotating workers through different tasks to avoid mental burnout, and adopting written fatigue-management policies covering work hours, break schedules, and a process for reporting fatigue. The association also calls for regular review of those controls, including checking whether changes to the work environment have undercut existing safeguards, and soliciting direct feedback from workers.
On the individual side, IHSA’s guidance to workers includes keeping a consistent sleep schedule, taking adequate time between shifts to rest and commute, staying hydrated, and eating balanced meals during the workday.
Analysis
Fatigue guidance like this tends to get filed under “common sense” and ignored, but the RACE structure matters because it forces fatigue into the same risk-management process companies already use for chemical exposure, fall hazards, or confined space entry. That’s a meaningful shift. Most field service companies handle fatigue informally, a supervisor sends someone home early, or a crew self-polices who takes the fatigued worker off a ladder. IHSA’s alert is effectively telling employers that informal handling isn’t enough. Fatigue needs a documented policy, a reporting mechanism, and periodic review, the same paper trail OSHA or provincial regulators expect for other hazards.
For subcontractors running crews on rotating shifts, night work, or long commutes, which describes a large share of pipeline, HDD, and remote infrastructure work, this is a preview of where enforcement conversations are headed. Fatigue-related incidents are notoriously hard to litigate after the fact because there’s no bright-line exposure limit like there is for noise or heat. A documented fatigue policy gives a contractor something to point to if an incident review asks what the company was doing to manage the risk.
The overnight shift guidance is particularly relevant for field operators. IHSA specifically calls out limiting overnight work “to essential tasks,” which is a harder standard than most crews currently apply. Night shifts are often scheduled around production needs, not fatigue exposure, especially in oilfield services and remote construction where crews work around the clock to keep projects moving. Reworking that scheduling logic, even partially, has real cost and staffing implications for smaller subcontractors who don’t have the bench depth to rotate crews easily.
The emphasis on worker feedback in the evaluation step also stands out. It suggests IHSA expects employers to treat fatigue controls as a living process, not a one-time policy rollout. That means checking in after schedule changes, equipment changes, or new project phases to see whether fatigue risk has shifted, not just writing a policy once and filing it away.
What It Means for Subcontractors
- Crews running overnight, on-call, or extended shift rotations (common in pipeline, HDD, and remote infrastructure work) should review current scheduling against IHSA’s guidance to limit overnight work to essential tasks only.
- Field supervisors should be trained to recognize the specific warning signs IHSA lists (yawning, slurred speech, decreased alertness, mood changes) as a formal part of daily safety checks, not just informal observation.
- Companies without a written fatigue-management policy covering work hours, breaks, and a reporting process should draft one now, before an incident forces the issue during a claims or regulatory review.
- After any change to shift structure, commute logistics, or task assignments, supervisors should solicit direct worker feedback on fatigue levels, per IHSA’s recommendation to evaluate and review controls on an ongoing basis rather than a one-time policy.
- Scheduling low-risk tasks during predictable high-fatigue windows, such as late-night hours or the tail end of long shifts, is a low-cost control crews can implement immediately without new equipment or budget.
