API 755-2-2016 Frequently Asked Questions (FAQ) Document for ANSI API RP 755 Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries (FIRST EDITI.pdf

1、Frequently Asked Questions (FAQ) Document for ANSI/API RP 755, Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical IndustriesAPI 755-2FIRST EDITION, APRIL 2016Special NotesAPI publications necessarily address problems of a general nature. With respect to particular circum

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8、o 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 themanufacture, sale, or use of any method, apparatus, or product covered by letters patent. Neither should anythingcontained in the pu

9、blication be construed as insuring anyone against liability for infringement of letters patent.Per APIs 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 standar

10、d.Should: As used in a standard or recommended practice, “should” denotes a recommendation or that which isadvised 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 representinga cross secti

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12、PI Publishing Services, 1220 L Street, NW, Washington, DC 20005.Copyright 2016 American Petroleum InstituteForewordNothing contained in any API publication is to be construed as granting any right, by implication or otherwise, for themanufacture, sale, or use of any method, apparatus, or product cov

13、ered by letters patent. Neither should anythingcontained 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-3Fre

14、quently Asked Questions (FAQ) Document for ANSI/API RP 755, Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries0 Foreword0.1 Are the “shall” statements in regards to work sets and shift duration truly mandatory, or can owner/operatorsmodify these values as they

15、 see fit based on risk analysis? As noted above, the use of API publications is voluntary (or non-mandatory). For API publications, thefollowing definitions apply.Shall: As used in a recommended practice, “shall” denotes a minimum requirement in order to conform to theRP.Should: As used in a recomme

16、nded practice, “should” denotes a recommendation or that which is advisedbut not required in order to conform to the RP.1ScopeFor 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 prov

17、ided housing adjacent to the facility where theywork?No. RP 755 scope says: This document is intended to apply to a workforce that is commuting daily to a joblocation. The intent is for the document to address employees who commute from home to work.3 Terms and Definitions3.0.1 Is mandatory training

18、 considered a shift?A shift is considered as 4 or more hours worked, regardless of whether the time worked is for training orperforming the regular job.3.0.2 Is a work set only regular scheduled shifts (i.e. 5 8 for maintenance, 12-hour rotating for operations)?No. A work set is defined as consecuti

19、ve shifts with a minimum of 36 hours off (or 48 hours off for night shiftsand 84-hour work sets) before starting another work set. Work sets are dynamic, meaning they are acombination of regular scheduled shifts and overtime shifts an employee works, so the number of shifts canvary from work set to

20、work set. Consecutive shifts are shifts worked without the minimum hours off needed toend the work set.3.0.3 Are the same definitions for holdover and extended shifts applicable when the time occurs prior to the regularscheduled shift?Yes. The definitions for extended shifts and holdovers are linked

21、 to the number of consecutive hours workedregardless of whether the additional hours occur before or after the regular scheduled shift.-23.0.4 API RP 755, Section 4.8.1.3, states that “extended shifts (longer than 14 hours) shall occur only whennecessary to avoid an unplanned open safety-critical po

22、sition 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 forother reasons, but an

23、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 2 additional hours on training-related activities wit

24、hout an exception; employees on 8- and 10-hour shifts could also work up to 14 hours fortraining purposes.3.0.6 How is “sleep debt” described? In TR 755-1, sleep debt is described as accumulated sleep deprivation.3.1 Call Out3.1.1 Does a call out count as “hours worked”?Yes. Options on how to record

25、 hours worked include attaching those hours to the closest shift prior to or afterthe 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 giv

26、en tocall out practices to ensure adequate rest prior to returning to work.” “Returning to work” includes either thecall out or returning to the next regular shift. In these cases, additional fatigue risk mitigation steps should beconsidered. Refer to TR-755, Section 4.8.4, for additional informatio

27、n on call outs.3.4 Holdovers3.4.1 Is a holdover of up to 2 hours for training, safety meetings, or any other purpose other than the personsregular work or covering someone elses regular work exempted from being defined as an extended shift andpossible need for following the exception process?Holdove

28、rs are considered extended shifts but do not require the exception process unless the holdover resultsin a shift duration that exceeds the Hours of Service limits. Extended shifts are defined as time an employee isassigned to work that extends outside their regularly scheduled shift hours. A holdove

29、r is defined as aperiodic, occasional extended shift where employees are at work beyond their regular shift to participate intraining, safety meetings, and the like. This does not include time needed for normal shift handoff. RP 755does not require use of the exception process for shifts up to 14 ho

30、urs. 3.7 Outages3.7.1 Who will determine when an outage is occurring?RP 755 does not define who determines when an outage occurs. Each facility/company should decide theprocess and approval(s) for declaring an outage and include that in their site specific FRMS.-13.7.2 In the event of an outage, who

31、 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 activit

32、ies, especially inabnormal situations, which is why additional flexibility is allowed in an outage. Outages take place for limitedperiods of time and generally are not routine operations. Employees usually work fixed shifts during outagesand minimize their non-work family and social commitments, and

33、 thus have more opportunity to adapt theirsleep schedules. (See TR 775-1 for further information.)3.9 Work Sets3.9.1 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 workset. Therefore, if one works a single shift pr

34、ior to 36 consecutive hours off, the work set is one shift.4.1 Roles and Responsibilities4.1.1 Why are employees responsible for being aware of their own fatigue since research indicates the individual isthe least likely to recognize fatigue?API RP 755 states that, “everyone has a role in recognizin

35、g the importance of workplace fatigue risk mitigationand actively working to support the goals of the FRMS.” Companies provide training to employees to helpthem proactively manage fatigue and, through the Hours of Service guidelines, provides the opportunity foradequate sleep. However, only the empl

36、oyee knows whether the rest obtained during the time away from theworkplace was adequate. To supplement self-awareness of fatigue, the FRMS also provides for the training ofsupervisors to recognize the signs and mitigate the fatigue risk. However, the employee is ultimatelyresponsible for securing a

37、dequate 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 acase by case basis to determine the appropriate course of act

38、ion. For example, supervisors may addressfatigue by recommending actions to enhance alertness, sending an employee home, or referring an employeeto medical services. Persistent patterns of fatigue may be addressed through performance management and/or referral to resources that can assist the employ

39、ee address the root causes.4.2 Positions Covered by the Fatigue Risk Management System4.2.1 RP 755 mentions that the guidelines are intended for “employees working night shifts, rotating shifts, extendedhours/days, or call outs involved in process safety sensitive actions.” Do the guidelines apply t

40、o straight dayshift employees?0According to RP 755, straight day shift employees are not subject to night shifts or shift rotations that increasethe likelihood of fatigue, so the hours of service limits do not apply unless they are subject to extended hoursor call outs. However, site-specific FRMS p

41、lans may choose to include limits such as applying the outagehours of service limits to such employees, particularly if they are engaged in process safety-sensitivepositions.4.2.2 How are individuals that work both covered and uncovered positions addressed under the standard?If an individual works b

42、oth covered and uncovered positions during their work set, all hours/days workedduring the current work set and the work limitations will apply at the time they are working in a coveredposition. For example, if an individual works as instrument mechanic (covered position) and then he isstepped up to

43、 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-coveredposition. If the individual moves back to a covered position and has exceeded the consecutive d

44、ay limitations,then he would require a rest period before returning to the covered position.4.3 StaffWorkload Balance4.3.1 Is an initial staffworkload balance assessment a requirement of the RP?While there is no specific “shall” statement in RP 755 regarding an initial staffworkload balance assessme

45、nt,the document does state, “the FRMS includes an initial and periodic assessment of the staffing levels andworkload balance, such that the implementation of the hours of service guidelines discussed below arefeasible and that fatigue risk is adequately managed.”4.3.2 The FRMS includes an initial as

46、sessment of staffing levels. What are some guidelines on how to conduct thisassessment 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 S

47、tatement; FatigueRisk Management in the Workplace, and the International Petroleum Industry Environmental ConservationAssociation (IPIECA)/International Association of Oil and Gas Producers (OGP) Performance Indicators forFatigue Risk Management Systems provide further information.4.4 Safety Promoti

48、on: Training, Education ,and Communication4.4.1 Does training time count as “hours worked”?Yes. 4.8 Hours of Service Limits4.8.0.1 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

49、 fatigue. It was determined that acomprehensive FRMS that includes limits on consecutive hours worked per shift and consecutive shifts in awork set was the best approach for managing fatigue within our industry. 14.8.0.2 How is transitioning to or from an Outage work schedule to or from Normal Operations handled in terms ofapplying Hours of Service Guidelines?When transitioning to an Outage condition, the current work set for affected Covered Individuals should startwith the individuals last rest period (the start of the current work set following the individuals last time offper