MOST people agree operating heavy machinery while under the influence is dangerous, and potentially deadly.
Well, working while fatigued is equally egregious.
Multiple studies suggest that, after 17 to 19 hours without sleep, job performance slips to a level similar to someone with a blood alcohol content of .05%—which is above the legal limit for commercial truck drivers—greatly reducing their ability to work safely in an industrial setting.
That’s particularly perilous in an oil and gas industry that never goes to bed.
To fight fatigue, Marathon Petroleum Company (MPC) instituted a fatigue management program in 2016, and Doug Swartz, MPC’s process safety manager, shared their experiences with the program at the International Liquid Terminal Association’s 38th Annual International Operating Conference & Trade Show in Houston, Texas, including an overview, implementation and lessons learned.
“MPC recognized the potential impact fatigue can have on employees and committed to proactively monitor and manage the associated risks,” Swartz said. “We chose to follow the American Petroleum Institute (API) Recommended Practice, API 755, as a guideline, but it’s important to remember petroleum risk is a shared responsibility (between employees and the company).”
API’s RP 755 first was published in 2010 in response to the US Chemical and Hazard Investigation Board’s recommendations to develop fatigue prevention guidelines following its scrutiny of the 2005 explosion at the BP Texas City refinery, which MPC purchased in 2013 for $2.5 billion.
According to API, RP 755 “provides guidance to all stakeholders (e.g. employees, managers, supervisors) on understanding, recognizing and managing fatigue in the workplace,” and owners and operators are encouraged to “establish policies and procedures to meet the purpose” of the best practice.
MPC took the recommendation to heart.
Swartz insists the key to developing successful fatigue management guidelines is first understanding the risks associated with workplace fatigue, then recognizing when we’re most susceptible, developing a schedule and, most importantly, proactively protecting ourselves and co-workers.
API’s fatigue risk management system (FRMS) mentions 11 key subjects, including roles and responsibilities; positions covered; workload balance; risk assessment and mitigation; training, education and communication; incident/near miss information; hours-of-service (HOS) limits; and work environment.
Marathon focuses on covered positions, HOS guidelines, outage/abnormal operations, the temporary approval process and providing guidance for understanding, recognizing and managing fatigue.
The company’s goal is to carefully manage many components of daily operations in an effort to minimize the potential for fatigue-related events, including creating sufficiently balanced work schedules, established operating procedures, adequate staffing levels and effective training programs.
“In order to show Marathon is taking proactive measures to manage and monitor the risk of fatigue, various business units within Marathon created their own fatigue risk management standards with specific guidelines for employees to follow so we can stay in front of fatigue,” Swartz said.
Marathon started by targeting safety-sensitive positions that involve the operation, maintenance and/or control of process equipment that may affect facility safety, including technicians, mechanics and their supervisors.
Its FRMS does not apply to personnel covered under component-specific fatigue risk documents, such as employees and contractors responding to emergencies, who are excluded to avoid conflict.
HOS limits are high priority in Marathon’s fatigue risk management plan.
“The objective of the hours-of-service guidelines is to establish those trigger points at which additional risk evaluations will be formed,” Swartz said. “(For example) the maximum number of eight-hour shifts before needing time off is 10. Once you’ve reached that 10-shift limit, you must get at least 36 hours before you return to work.
“If you can’t do that, that’s the trigger point where you stop and have a conversation with your supervisor, and go through that temporary approval process.”
HOS guidelines are less stringent for outages but require declaration and approval by the component environmental health and safety, and operations managers to use the Outage Hours of Service Guidelines.
To complete the process, a supervisor reviews HOS guidelines, and hours worked prior and anticipated after an event, then fills out a Temporary Approval Form, including reason, job task, potential risk and controls in place, and sends it to the next-level manager, who approves or disapproves.
Marathon also provides training to help recognize the types of fatigue, from mild and moderate, where someone might be losing focus, to severe, where individuals are feeling ill or dosing off.
In severe cases, a supervisor must be alerted, then he or she develops an action plan and documents the incident.
“Once an employee or supervisor understands these levels of fatigue, they’re better equipped to monitor them,” Swartz said.
Swartz said Marathon gathers information on any incident where fatigue may have been a “contributing” factor, including those involving human error, maintenance or delayed action, or occurring during an outage.
Marathon introduced its FRMS during the third quarter of 2015, with an instructor leading a class for the initial rollout. The company provides computer-based training as a refresher and for new hires.
The program has pros and cons, Swartz said.
Benefits they’ve seen include a cultural shift toward recognizing and understanding fatigue, and how to proactively manage schedules to avoid it, and their improved ability to use mitigation techniques.
Drawbacks include logistical complications – it’s difficult to make schedules for 24-hour operations – a high administrative burden and a lack of one-size-fits all HOS guidelines for every business model.
“Thankfully, most of our operations are not 24/7, so most of them can follow those hours-of-service guidelines, stagger people, and let them come in later to meet those guidelines,” Swartz said.
“(But) if I’m an operator and we share on-call duties, and I get called out on a Saturday and Sunday for four hours each, by Wednesday I’ve reached my hours-of-service limits for that next week, so I cannot work Thursday and Friday of my normal shift without going through the approval process.”
Monitoring compliance and linking fatigue to incidents also is problematic.
Swartz said Marathon identified 40 incidents in 2017—and fatigue wasn’t listed as a cause for any of them.
Going forward, the company is exploring better ways of collecting data, including using payroll reports to monitor compliance, and reviewing API’s proposed fatigue risk management changes, including second-edition revisions to its HOS guidelines targeted for implementation in 2020.
“All our standards are on a three-year cycle for a management review, so we are … looking at the hours-of-service guidelines revisions,” Swartz said. “We want to see if we can come up with a way that better fits our business model, to minimize paperwork and still minimize potential fatigue.”