Ref: MG/RT/GG24107
27 November 2024
Work Safe Australia
2 Phillip Law Street
CANBERRA ACT 2601
By Email: psychosocialpolicy@swa.gov.au
Dear Sir/Madam
Re: Consultation on the Draft Model Code of Practice – Managing Fatigue Risks at Work
AgForce is a peak organisation representing Queensland’s cane, cattle, grain and sheep, wool & goat producers. The cane, beef, broadacre cropping and sheep, wool & goat industries in Queensland generated around $10.4 billion in on-farm value of production in 2021-22. AgForce is the leading voice for Queensland producers and strives to ensure the long-term growth, viability, competitiveness and profitability of these industries. Over 6,000 farmers, individuals and businesses provide support to AgForce through membership. Our members own and manage around 55 million hectares, or a third of the state’s land area. Queensland producers provide high-quality food and fibre to Australian and overseas consumers, contribute significantly to the social fabric of regional, rural and remote communities, as well as deliver stewardship of the state’s natural environment.
We thank Work Safe Australia for the opportunity to provide feedback to the draft Code of Practice: Managing Fatigue Risks at Work.
AgForce is committed to the elimination of work-related injury and illness in the agricultural industry and has a board endorsed ‘zero harm on farm’1 work, health and safety declaration that helps guide our response to the draft Code of Practice: Managing Fatigue Risks at Work.
Farms are workplaces, but they are also home for generations of farming families. Historically, farming accounts for a small percentage of the total workforce, but there is a disproportionate level of workplace deaths and injuries, some of which can be attributed to fatigue. Both industry collectively and individual farmers understand the imperative need to address the unacceptable statistics related to farm deaths and injuries and managing fatigue plays an important role with reducing incidents.
A Code of Practice (CoP) is a set of guidelines or principles that provide a framework for individuals or organisations to follow to ensure effective behaviour within a field or industry. These CoPs are normally developed by industry, for industry.
The current draft is far too long (54 pages). If you would like the code of practice (CoP) to be easily understood, adapted and implemented across industry, it needs to be more palatable to the end user.
AgForce suggests exploring the development of an agriculture specific fatigue code of practice with consultation of industry, peak farming bodies and FarmSafe Australia.
Agriculture faces unique demands and challenges, compared to other sectors. Whilst the draft code does make mention to some of the challenges, it does not adequately address the realities of operating for primary producers.
AgForce’s Workforce & Safety Committee provides the following recommendations towards an Agriculture specific fatigue code of practice:
1. Physically Demanding Work
- Agricultural work often involves long hours of physical labour, including planting, harvesting, operating machinery, and caring for livestock. These activities can be physically exhausting, leading to fatigue that increases the risk of accidents, injuries and reduced productivity. Unfortunately, many of these tasks cannot be simply ‘left for another day’ and farmers find themselves managing animal welfare needs against fatigue of themselves and workers.
- A dedicated fatigue code can help identify when fatigue is impairing performance, ensuring that workers are aware of the risks and take appropriate breaks or adjustments to their workload.
2. Seasonal Workload Variability
- In agriculture, certain periods (eg, harvest or planting seasons) involve more intense workloads and longer working hours, which can contribute to higher levels of fatigue. Without proper guidelines, workers may be pushed beyond safe limits during peak seasons. One person’s safe limits can differ greatly from the next person. How can we display those variations within a code of practice?
- A fatigue code of practice would address these peaks by recommending practices such as shift rotations, adequate rest periods and support systems to prevent exhaustion during intense work periods.
3. Safety and Risk Management
- Fatigue significantly impairs decision-making, attention and reaction time, all of which are critical in preventing accidents, especially when operating heavy machinery or dealing with livestock.
- A fatigue code would help to mitigate these safety risks by providing practical advice on managing fatigue, ensuring that workers and supervisors understand the importance of rest and the need for regular breaks. FarmSafe Australia already provides great practical guides to managing fatigue on farms.2
4. Health and Well-being of Workers
- Chronic fatigue can lead to long-term physical and mental health issues, such as stress, cardiovascular problems and mental health challenges like anxiety or depression. Agriculture workers and property owners often face additional stressors such as weather dependence, financial pressures, and isolation.
- A fatigue-specific code of practice could promote policies around worker health and well-being, ensuring that employers implement preventative measures and offer support within the scope of relevance. The draft code you have developed is impractical, especially around extreme heat and cold. The nature of our work is outdoors and in the elements and your current draft suggests this is a ‘poor physical work environment’ and is clearly not fit for purpose within an agricultural setting.
5. Improved Productivity and Efficiency
- Fatigued workers pare less productive and more prone to errors. By addressing fatigue, a code of practice can help ensure workers are operating at their best, leading to increased efficiency and better outcomes for agricultural operations.
- Implementing fatigue management practices can lead to better time management, fewer mistakes and reduced downtime due to accidents or health issues.
6. Promoting a Culture of Care and Responsibility
- Establishing a fatigue code in agriculture would promote a culture shared responsibility for the health and safety of people working in industry. It would encourage better management of workloads and stress levels, contributing to a healthier work environment.
- It also fosters the importance of self-care and monitoring fatigue levels among workers themselves, creating a more sustainable and supportive working atmosphere.
7. Remote and Isolated Work Environments
- Many agricultural operations are in remote areas, where workers may be isolated for extended periods, potentially exacerbating fatigue due to limited access to support, social interactions, and resources. The current draft CoP put forward suggestions that are not practical for the reality of operating in isolation.
- A fatigue code of practice can offer specific guidelines for managing fatigue in these environments, including recommendations for communication, support networks and strategies to ensure that workers have the means to address fatigue effectively.
A Fatigue Code of Practice specific to Agriculture would provide tailored, practical guidelines for managing the physical and mental challenges that workers in this sector face, outside of the guidelines you have developed generally. By addressing the unique aspects of agricultural work – such as seasonal peaks, heavy physical labour and safety risks – it would help improve worker health, safety, and productivity, while promoting a culture of care and responsibility within the industry.
The current draft also seems to duplicate many Workplace Health and Safety Acts and Employment Responsibilities that a person conducting a business or undertaking PCBUs already has an obligation to provide. Whilst it is relevant, AgForce would suggest repeating what is already in law.
We look forward to future collaboration with Work Safe Australia. Should you have any questions pertaining to this submission, please contact Ruth Thompson, Grains Policy Director on 0427 472 467 or via email: thompsonr@agforceqld.org.au
Yours faithfully
Mike Guerin
Chief Executive Officer