Refers to: Ship Owners / Managers/ Operators, PHRS Representatives/ Surveyors             

Action Date: N/A

The American Waterways Operators (AWO) is working with the US Coast Guard to prevent and manage fatigue risks in the US tugboat, towboat and barge industry since the ‘90s. Towing vessel’ crew members are regularly exposed to the risk of fatigue, among other risks. Managing and mitigating these risks is important to reduce the likelihood of fatigue-related accidents.

With the goal of taking a proactive approach to fatigue prevention and management and reducing this risk of fatigue-related accidents, AWO’s Fatigue Risk Management Working Group developed and recently published the guide, 'Developing a Fatigue Risk Management Plan: A Guide for Towing Vessel Operators', to help member companies develop a fatigue risk management plan to incorporate into their existing safety management systems (SMS).

Fatigue risk management plans take a comprehensive, customized approach to addressing fatigue within a company, including policies and practices to address a wide range of fatigue risk factors and mitigation measures. This guide is tailored to the unique operational and environmental challenges of the towing industry. However, because towing vessel operations and design vary widely across the industry, the guide is not intended as a “one-size-fits-all” approach.

That means the companies have to carefully study the guide, assess their policies and procedures that are already in place to mitigate the fatigue-related risks of their crew members and identify how it is possible to link and possible improve their existing fatigue mitigation measures into a comprehensive fatigue risk management plan.

Companies can also use the guide to identify and implement additional practices, controls and other tools to close gaps or expand their current efforts.

The Fatigue Risk Management Working Group intends the guide to be a toolbox in which every AWO member company can find useful tools to address their specific fatigue challenges, enhancing safety of our shared waterways.

The Fatigue Risk Management Working Group has identified four core elements that it considers to be most important in a fatigue risk management plan:

• Education: Towing vessel crew members must understand the effects of poor sleep on their alertness, performance and safety, as well as know how fatigue mitigation strategies can improve sleep quality and duration. 

• Environment: Various environmental factors may inhibit the ability of towing vessel crew members for quality sleep. Simple engineering solutions and behavior modifications to improve the sleep and vessel environments can improve crew members’ sleep quality. 

• Work Readiness and Fatigue Reporting: Towing vessel crew members have a shared responsibility to report ready for duty, and of a company to allow adequate opportunity for crew members to rest and provide a process for reporting when they have not been able to obtain sufficient rest and/or feel fatigued.

• Performance Measurement: Companies should implement a process to regularly monitor and evaluate their fatigue management practices. This will allow them to assess whether and how these practices are being implemented, evaluate whether they are working and determine whether modifications are needed. 

The Fatigue Risk Management Working Group has also identified some other elements that may affect the effectiveness of a fatigue risk management plan, such as:

• Wellness Program: companies should use wellness initiatives to educate crew members about the importance of having good sleep and it’s positive impact on health. In addition, companies must encourage healthy behaviors and provide access to physical and mental health care, as practicable.

• Commuting: Daily commuting can both impact sleep and be impacted by sleep. A fatigue risk management plan of Companies operating live-aboard vessels should evaluate the commute times and practices of crew-members, identify risks and implement feasible risk mitigation measures.

• Sustainability: Sustainability involves the integration of fatigue risk management into the safety culture of the company, and buy-in for fatigue mitigation measures from shore-side management, captains and crew members. 

The guide 'Developing a Fatigue Risk Management Plan: A Guide for Towing Vessel Operators' can be found here.

Do not hesitate to contact us for any clarifications you may need on the above.

February 14th, 2019 - PHRS Head Office