Fatigue and shift work: a Victorian manufacturer's duties

Does a manufacturer have a legal duty to manage fatigue?

Yes. Fatigue is treated as a workplace hazard like any other under the OHS Act 2004 (Vic), and an employer must, so far as reasonably practicable, identify it, assess the risk it creates, and control it — particularly where shift work, extended hours or night work are part of how the business runs. WorkSafe Victoria defines work-related fatigue as an acute or ongoing state that leads to physical, mental or emotional exhaustion and stops people functioning safely, caused by working long hours, intense effort, or work during the body's natural sleep time (WorkSafe Victoria, Risk management approach to fatigue).

What does WorkSafe Victoria expect the process to look like?

WorkSafe Victoria sets out a four-step risk management approach for fatigue, matching the standard OHS risk process:

1. Identify fatigue-related hazards — using consultation with employees and HSRs, workplace walk-throughs, and a review of hours-of-work records, rosters and incident data.
2. Assess the risks — how likely fatigue is to occur, how severe the consequences could be, and how many employees are affected.
3. Control the risks — applying the hierarchy of control, with work design (scheduling, shift length, rostering) generally the most effective lever, ahead of training or PPE-style controls.
4. Monitor and review — checking controls are actually working and adjusting as rosters, workloads or staffing change.

(WorkSafe Victoria, Risk management approach to fatigue)

What should shift scheduling actually look like?

Safe Work Australia's national guide for managing fatigue at work recommends specific shift design practices, including avoiding keeping workers on permanent night shifts, arranging shifts so day sleep isn't restricted, and giving at least 24 hours' notice before night work where possible (Safe Work Australia, Guide for managing the risk of fatigue at work). For a manufacturer running rotating shifts, that means the roster itself is a risk control, not just an operational scheduling tool — how you rotate shifts, how much notice you give, and how much recovery time sits between shifts all directly affect fatigue risk.

Does fatigue make other hazards on the floor worse?

Yes, and this is where fatigue often gets missed in a standard risk assessment. WorkSafe Victoria's guidance notes that the risk of musculoskeletal injury from manual tasks increases during extended shifts due to cumulative muscle fatigue — injury risk is significantly higher during a 12-hour shift than an 8-hour shift, and injuries tend to cluster towards the end of a shift. Exposure to hazards like noise, heat and chemicals also needs closer attention on extended shifts, because national exposure standards are generally based on a standard 8-hour day, 5-day week, and extended shifts reduce recovery time between exposures (WorkSafe Victoria, Risk management approach to fatigue).

Practically: if your manufacturing floor runs 10 or 12-hour shifts, your manual handling and exposure risk assessments need to account for that shift length specifically, not just assume the standard 8-hour benchmarks still apply.

What's changed recently for Victorian employers?

The Occupational Health and Safety (Psychological Health) Regulations 2025 came into effect on 1 December 2025, requiring employers to identify and control psychosocial hazards and to review and revise those controls in certain circumstances (WorkSafe Victoria, Risk management approach to fatigue). Fatigue sits across both physical and psychosocial risk, so if you haven't reviewed how your fatigue management approach lines up with your broader psychosocial hazard obligations since these regulations commenced, that's worth doing now rather than waiting for an incident to force the conversation.

Do you have to consult employees on rosters and shift changes?

Yes. Consultation with employees and their health and safety representatives is a requirement under the OHS Act 2004 (Vic), and for fatigue specifically, WorkSafe Victoria says this should happen, so far as reasonably practicable, at several points: when fatigue is first identified as a hazard, when you review how it's currently managed, before new work schedules or shift patterns are introduced, and after any relevant incident or near miss (WorkSafe Victoria, Risk management approach to fatigue). Changing a roster without talking to the people working it is a common way well-intentioned fatigue fixes end up creating new problems instead of solving old ones.

Fatigue management is one of those areas where a business can have a policy on paper that doesn't reflect what's actually happening on the roster. That gap is exactly what a proper site assessment is designed to surface — if you'd like a practitioner to look at how your shift patterns and fatigue controls hold up in practice, you can book a site assessment.

FAQ

Is fatigue risk management a legal obligation for Victorian manufacturers? Yes. Fatigue is a recognised workplace hazard under the OHS Act 2004 (Vic), and employers must, so far as reasonably practicable, identify, assess and control it — this applies directly to businesses running shift work, extended hours or night shifts.

Is training workers about fatigue enough, or do rosters need to change? Training alone isn't considered an effective control on its own. WorkSafe Victoria's guidance places work design — shift scheduling, rotation patterns, rest breaks and recovery time — ahead of training in the hierarchy of control, because it addresses the source of the risk rather than relying on individual workers to manage exhaustion themselves.

How do the new psychosocial hazard regulations affect fatigue management? The Occupational Health and Safety (Psychological Health) Regulations 2025, in effect from 1 December 2025, require employers to identify and control psychosocial hazards. Since fatigue has both physical and psychosocial dimensions, it's worth checking your existing fatigue controls against these newer obligations rather than treating them as separate systems.

This article is general information for Victorian manufacturers, not legal advice. Last updated: 10 August 2026.