Fatigue is a system issue, and should be managed that way.

At our recent HSE Executive Leaders Forum in Sydney, Qantas pilot Paul Kirby reframed fatigue management for Qantas pilots and flight crews that could be applied to Australian workplaces across all industries. Paul walked through the airline's fatigue risk management system, involving tracking 32,000 data points per flight, EEG headbands and a 30-second wellbeing check embedded into tools the crew already use. More than the sophistication of the technology, what struck me was a single observation that sat quietly underneath it: the data often contradicts what regulators assume, and it has the potential to influence industry-wide innovation. 

That's not a criticism of regulators. Prescriptive fatigue frameworks exist because they've prevented harm, and building them required genuine effort and some hard lessons. The problem is that most of those frameworks were built on assumptions about what drives fatigue that the data is now challenging. The majority of countries, including Australia, still manage fatigue primarily through prescriptive duty and rest period limits, which means the compliance model is built on treating fatigue as a result of hours worked. The evidence increasingly suggests it's more complicated than that. 

What the Data Is Actually Showing 

The most significant shift in fatigue science over the past decade is the growing understanding of the relationship between psychological state and physical fatigue. Worrying about something — financial pressure, a relationship under strain, a difficult conversation coming up at work — is the first thing to affect sleep quality, often before any rest hours are formally lost. Rio Tinto has described this as "the bi-directional relationship between mental health and fatigue" and has explicitly moved toward a multifactor approach that goes beyond roster design. SafeWork NSW The Qantas system tracks stress and worry alongside rest and alertness for the same reason. 

This has a direct regulatory implication. Comcare has formally classified fatigue as a psychosocial hazard under Australia's Managing Psychosocial Hazards at Work Code of Practice 2024. SafeWork SA That's not a semantic shift — it's a signal that the regulatory framework is beginning to catch up with what the evidence shows: that fatigue risk can't be managed in isolation from the psychological and social conditions that drive it. Organisations that are still treating fatigue as a scheduling problem are exposed under obligations they may not have fully registered. 

The Trust Problem Nobody Talks About 

The harder challenge in fatigue management isn't the technology or even the regulatory framework. It's trust. The Qantas system only works because crew believe their data will be used to improve their experience — not to flag them for review, not to build a performance case, not to satisfy a regulator. That trust was built slowly, through demonstrated responsiveness: changes made on the basis of what workers reported, communicated back to them clearly. 

Most organisations skip this step. They introduce monitoring tools, frame them as safety investments, and then use the data primarily for compliance reporting. Workers notice. And when they do, the quality of the data degrades — people report what they think they're supposed to report, not what's actually happening. The system that was supposed to surface leading indicators becomes another source of lagging data. 

This is the pattern I see most often when fatigue management comes up in the hiring conversations we have at The Safe Step. Organisations are investing in better tools but not in the cultural conditions that make those tools useful. The capability demand is shifting — fatigue risk management expertise is increasingly sought after in mining, transport, and healthcare — but the organisations attracting that capability tend to be the ones that have already made the cultural investment, not those hoping the technology will do the work for them. 

What Better Practice Looks Like 

As Safe Work NSW reports, mining operations like those at Rio Tinto are moving toward biomathematical modelling to design roster schedules that maximise alertness rather than simply comply with minimum rest requirements – the same approach that's standard in aviation and rail. The underlying principle is the same one the Qantas fatigue system demonstrates: collect data through tools people are already using, integrate psychological and physical indicators, and be willing to let the data challenge existing assumptions. 

The organisations making real progress are also thinking about fatigue across their supply chains, from direct employees, to contractors, logistics partners, and shift workers whose fatigue exposure is often higher and whose frameworks are often weaker. That's a more ambitious scope, but it reflects where the regulatory and reputational risk increasingly sits. 

Fatigue management has been a compliance function in most Australian organisations for a long time. The evidence, the regulation, and the technology are all pointing in the same direction now. The question is whether organisations are ready to tackle it systemically and proactively. 

Aaron Neilson is CEO of The Next Group, which includes The Safe Step, Australia's leading specialist HSE recruitment and capability development firm. 

The HSE Executive Leaders Forum connects top safety leaders in organisations around Australia, who collaborate to share research and innovation, and influence safety governance and technology innovation across Australian industries.