Policy - Fatigue and Hours of Work

Format. Adopt as a department policy. The impairment and fitness-for-duty clauses (5.6) may be adopted as the department’s own policy or may point to a municipal corporate policy where one exists and meets this standard; record which.

Drafting conventions. Shall means mandatory. Should means expected unless a documented reason exists. May means permitted. Placeholders in double curly braces, such as {{Department}}, are completed by the department. Drafting notes sit in callouts and are removed before adoption.

Keep intact. Fatigue self-report without penalty (5.3), post-incident rest (5.2), the driving rules (5.4), the fitness-for-duty approach with support before discipline for disclosure (5.6), and the four house principles. Adapt. The hour limits in 5.1 to the collective agreement and the department’s shift pattern; the volunteer provisions in 5.5 to local practice; the role titles.

1.1 To manage fatigue as a hazard: to set limits on hours and consecutive work, require rest after long incidents, make it safe and expected to report fatigue, keep fatigued members out of the driver’s seat, address the particular fatigue of volunteers who respond at night and work by day, and manage impairment from any cause under a fitness-for-duty approach that supports disclosure.

1.2 Fatigue raises injury, collision and cardiac risk; obstructive sleep apnea and insomnia are common among firefighters; and sleep-disorder screening programs have been reported to reduce injuries and disability (NIOSH, n.d.-c). Fatigue and welfare on protracted incidents are a recurring finding in Canadian regulator reports (see 05 Design Principles and Lessons Learned). A fatigue risk management system is the recognized way to manage it (AFAC, 2022).

2.1 Applies to every member, career and volunteer, on duty, on call, responding, at an incident, at training, and driving on department business.

2.2 Applies to shift schedules, overtime, call-backs, consecutive shifts, protracted incidents and deployments (wildland, mutual aid, disasters), training exercises, and to the hours a volunteer works for another employer before responding.

2.3 Does not override the collective agreement’s hours, overtime and call-back provisions; where a limit in this policy is stricter than the agreement, the department applies it as a safety control under the employer’s general duty and records the basis (J02 Duties of Employers, Supervisors, Workers and Contractors).

Consecutive hours. Hours of duty, including overtime and call-backs, without a rest period of at least the length in 5.1.3.

Fatigue. A state of reduced physical or mental capability from sleep loss, extended wakefulness, circadian disruption or workload, that impairs alertness and performance.

Fatigue risk management system. The set of controls, data and review that treats fatigue as a hazard: hours limits, rest rules, self-report, screening, driver rules and monitoring (AFAC, 2022).

Fitness for duty. Being physically, mentally and emotionally able to perform assigned duties safely, without impairment from any cause.

Impairment. Any condition, from fatigue, illness, injury, alcohol, drugs, medication, cannabis or psychological distress, that reduces a member’s ability to perform duties safely (CSA Z1008:21).

Post-incident rest. A period free of duty after a protracted or arduous incident, before the member returns to duty or drives.

Protracted incident. An incident or deployment in which a member works beyond the threshold in 5.2.1.

Rest period. Time off duty of sufficient length to allow sleep, as set in 5.1.3.

Safety-sensitive position. Every operational position in the department, and every position that drives department vehicles.

1. People are the solution we build around, not the problem to fix. Fatigue is a predictable human state, not a character flaw; the department designs schedules and rules so tired people are not asked to do dangerous things.

2. Procedures describe work as done, written with the people who do it. The limits in this policy were set with members and will be adjusted from what the members report.

3. Learning comes before blame, and learning information is never used for discipline. A fatigue report, a disclosure of a sleep problem, or a disclosure of a substance concern made in good faith is treated as information the department needs, not as grounds for discipline.

4. Psychological safety is a condition of safety, so speaking up is expected and protected. “I am too tired to drive” is a sentence every officer wants to hear before the crash, not after.

5. Fitness for duty, not detection. The department’s interest is whether a member can work safely today; the approach is support, assessment and accommodation first, and discipline only for conduct, never for disclosure.

6. Volunteers carry two jobs. A volunteer who answered three calls last night and starts a day job at seven is a fatigue case the department created and must manage.

5.1.1 No member shall work more than {{Maximum consecutive hours}} consecutive hours of duty including overtime and call-backs (default 24 hours on a 24-hour shift pattern; 16 hours on a 10/14 or 12-hour pattern) without the rest period in 5.1.3, except at an active incident under 5.2 where relief is not yet available. Accountable: {{Deputy Chief}}; each platoon or district chief for the roster.

5.1.2 No member shall work more than {{Maximum hours in seven days}} hours of duty in any seven-day period (default 72 hours, including overtime), and no member shall be scheduled for more than {{Maximum consecutive shifts}} consecutive 24-hour shifts (default two) without a rest period of at least 24 hours. Accountable: {{Deputy Chief}}.

5.1.3 A rest period is at least {{Minimum rest hours}} consecutive hours off duty (default 10 hours, of which eight are available for sleep) between the end of one duty period and the start of the next. Accountable: {{Deputy Chief}}.

5.1.4 Overtime and call-backs shall be tracked per member and reported monthly; a member who exceeds a limit shall be relieved, not disciplined, and the exceedance reviewed as a scheduling hazard. Accountable: {{Deputy Chief}}; {{Health and Safety Officer}} for the report.

5.1.5 On the night tour of a 24-hour shift, members may sleep when not on a call or assigned duty; the department shall provide sleeping quarters that allow it, and shall not schedule routine duties between {{Night rest window}} (default 2200 to 0600) except for calls. Accountable: station officers; facilities.

5.1.6 Stations whose night call volume routinely prevents sleep shall be identified from dispatch data and relieved by rotation, additional staffing or dispatch assignment changes, reviewed annually in the Health, Wellness and Rehab appraisal. Accountable: {{Deputy Chief}}.

5.2.1 A member who has worked {{Protracted incident threshold}} (default: more than four hours of arduous work at an incident, or any incident or training lasting beyond 12 hours, or any deployment overnight) is on a protracted incident. Accountable: each incident commander to track.

5.2.2 After a protracted incident, the member shall be relieved of duty for at least {{Post-incident rest}} (default: eight hours, or the balance of the shift if longer) before returning to duty, and shall not drive a department vehicle until rested under 5.4. Accountable: the incident commander; the platoon or district chief for relief.

5.2.3 Rehabilitation at the incident under Firefighter Rehabilitation Program (rest, rehydration, cooling or warming, medical monitoring, and return-to-work criteria) is a fatigue control and shall be provided at every incident that meets its triggers (NFPA 1580, 2025). Accountable: the incident commander.

5.2.4 On multi-day deployments (wildland, disaster, mutual aid), the department shall set a work-rest cycle before departure (default: no more than 16 hours of duty in 24, no more than 14 consecutive days without two days off), name a deployment officer accountable for it, and log hours per member daily. Accountable: {{Deputy Chief}}.

5.3.1 Any member who believes they are too fatigued to perform a task safely, or to drive, shall say so to their officer, in person or on Form - Fatigue Self-Report and Officer Response. Accountable: each member.

5.3.2 The officer shall acknowledge the report, remove the member from the task or the driver’s seat, arrange relief or rest, and record the report and the response on the form. No member shall be disciplined, lose pay for the shift, lose a volunteer point or credit, or face any adverse consequence for a good-faith fatigue report. Accountable: each officer; {{Fire Chief}} for the no-penalty rule.

5.3.3 Any member may report that another member appears fatigued; the officer assesses and responds the same way. Accountable: each officer.

5.3.4 Fatigue reports shall be collated monthly, without names, by station, shift and time of day, and reviewed as a leading indicator by the Health, Wellness and Rehab team and the JOHSC. Accountable: {{Health and Safety Officer}}.

5.4.1 No member shall drive a department vehicle, or a personal vehicle on department business, when they have been awake for more than {{Awake limit}} (default 18 hours), or after a protracted incident until rested under 5.2.2, or when they report fatigue under 5.3. Accountable: each member; each officer who assigns the driver.

5.4.2 After a night of calls, the officer shall assign the most rested qualified driver for the return to station and for any non-emergency driving, and may hold a crew at a scene or station for rest before driving. Accountable: each officer.

5.4.3 Where no rested driver is available for a non-emergency move, the apparatus waits. Where an emergency response is unavoidable, the officer records the decision and the controls used (second member awake in the cab, reduced speed, shortest route). Accountable: each officer.

5.4.4 Vehicle incidents shall be reviewed for fatigue as a contributing factor in every case, with hours awake and hours on duty recorded in the incident report (see Apparatus, Driving and Roadway Operations Program). Accountable: {{Health and Safety Officer}}.

5.5.1 Volunteer and paid-on-call members shall not be expected to respond when they are fatigued, and the department shall say so in writing at recruitment and annually. Accountable: {{Fire Chief}}.

5.5.2 A volunteer who has responded to calls totalling more than {{Volunteer night threshold}} (default four hours between 2200 and 0600) should not respond to further non-life-threatening calls before {{Volunteer rest end}} (default 0800 the next day) and should assess their fitness to drive to their day job. The department shall tell members this is expected, not a failure. Accountable: volunteer officers.

5.5.3 Volunteers may set pager-silence windows (for example on nights before early shifts) without any effect on their standing, participation record or presumptive coverage calculation beyond the calls they did not attend. Accountable: {{Fire Chief}}.

5.5.4 Before responding in a personal vehicle, a volunteer shall self-assess for fatigue; a volunteer who is fatigued does not respond by vehicle, and may attend the station or stand down (see SWP - Personal Vehicle Response (Volunteers)). Accountable: each volunteer member.

5.5.5 The department shall track volunteer night-call load per member and raise it with any member whose load suggests risk, as a wellness conversation and not a performance one. Accountable: volunteer officers; the Volunteer Operations program manager.

5.5.6 Volunteer fatigue after night calls is a hazard the department created and shall be entered in the risk register with the controls in this section (see Policy - Volunteer Members). Accountable: {{Division Chief, Safety}}.

5.6.1 Every member shall report for duty, and remain, fit for duty: not impaired by alcohol, drugs, cannabis, medication, fatigue, illness, injury or psychological distress to a degree that affects safe performance. Accountable: each member.

5.6.2 The department manages impairment under a fitness-for-duty approach consistent with the national standard for the management of impairment in the workplace (CSA Z1008:21): prevention and education; a clear statement of expectations; a process to recognize and respond to possible impairment; assessment by a qualified professional; support, treatment and accommodation; return to duty; and review. Accountable: {{Fire Chief}}.

5.6.3 Alcohol: no member shall consume alcohol within {{Alcohol abstinence period}} (default eight hours) before duty, during duty, or during a response, and no member shall respond to a call while under the influence. Volunteers who have consumed alcohol do not respond. Accountable: each member.

5.6.4 Cannabis and other impairing substances: no member shall use cannabis or any impairing drug during duty or within a period before duty sufficient to be unimpaired at the start of duty; the department’s default is {{Cannabis abstinence period}} (default 24 hours before a scheduled duty period, and volunteers do not respond within that period after use), set with the occupational health provider and reviewed with counsel against the collective agreement and human rights law. Accountable: each member.

5.6.5 Medication: a member taking a prescribed or over-the-counter medication that may impair shall tell the officer before duty, without disclosing the condition; the officer assigns duties accordingly and the occupational health provider advises where needed. Accountable: each member; each officer.

5.6.6 Where an officer has reasonable grounds to believe a member is impaired, the officer shall remove the member from safety-sensitive work immediately, ensure the member gets home safely (never driving), record the observations on the fitness-for-duty section of Form - Fatigue Self-Report and Officer Response, and refer the member to the occupational health provider for assessment. Accountable: each officer.

5.6.7 Disclosure first: a member who discloses a substance use concern, a sleep disorder, a medication effect or psychological distress before an incident of impaired performance shall receive support, assessment, treatment and accommodation under Medical, Fitness and Wellness Program and Psychological Health and Safety and Peer Support Program, and shall not be disciplined for the disclosure. The duty to accommodate under the applicable human rights law applies (J33 Return to Work, Accommodation and Hours of Work), as the Supreme Court of Canada set it out (British Columbia (Public Service Employee Relations Commission) v. BCGSEU, 1999). Accountable: {{Fire Chief}}; human resources.

5.6.8 Conduct is different from disclosure. Working while impaired without disclosure, after education and the opportunity to disclose, is a conduct concern under Policy - Internal Responsibility and Accountability section 5.4 and is handled under the collective agreement. Accountable: {{Fire Chief}}.

5.6.9 The department does not conduct random drug or alcohol testing. Post-incident or reasonable-cause testing, if the department adopts it, shall be set out in a separate procedure reviewed with counsel and the bargaining agents and consistent with Canadian arbitral and human rights law. Accountable: {{Fire Chief}}.

5.7.1 The annual medical evaluation shall include screening for obstructive sleep apnea and insomnia, with referral for diagnosis and treatment, under Medical, Fitness and Wellness Program (NFPA 1580, 2025). Accountable: the Health, Wellness and Rehab program manager.

5.7.2 Sleep hygiene, fatigue recognition and the rules in this policy shall be taught at orientation and annually. Accountable: training division.

5.8.1 The department shall measure monthly: hours of duty over the limits in 5.1, by member and station; consecutive-shift events; overtime and call-back hours; fatigue reports and responses; vehicle incidents by hour of day and hours awake; protracted incidents and rest granted; volunteer night-call load distribution; sleep screening completion. Accountable: {{Health and Safety Officer}}.

Only the differences from 01 Roles and Responsibilities are stated here.

6.1 Deputy chief, operations. Owns the roster limits, relief arrangements and deployment work-rest cycles; receives the monthly exceedance report.

6.2 Platoon, district and station officers. Apply the limits; respond to fatigue reports; assign rested drivers; record decisions.

6.3 Incident commanders. Track hours at protracted incidents; order relief; provide rehabilitation.

6.4 Volunteer officers. Carry 5.5; have the wellness conversation about night-call load.

6.5 Occupational health provider. Advises on medication, impairment assessment, sleep disorder referral, return to duty; holds the clinical record.

6.6 Human resources. Accommodation, treatment leave, return-to-work planning under the municipality’s processes and any statutory return-to-work duty (J33 Return to Work, Accommodation and Hours of Work).

6.7 Members. Arrive fit; report fatigue; self-assess before driving.

Medical, Fitness and Wellness Program; Firefighter Rehabilitation Program; Apparatus, Driving and Roadway Operations Program; Psychological Health and Safety and Peer Support Program; SWP - Personal Vehicle Response (Volunteers); SWP - Emergency Vehicle Response and Backing; SWP - Rehabilitation at Incidents; Form - Fatigue Self-Report and Officer Response.

8.1 Records: roster and hours data; fatigue self-reports and officer responses; deployment hour logs; fitness-for-duty observation records; monthly monitoring reports.

8.2 Fatigue self-reports are kept by the officer and the health and safety officer, not in the personnel file, and are reported in aggregate only. Fitness-for-duty observation records are held by the senior officer responsible for health and safety; the clinical assessment stays with the occupational health provider, who reports only fit, unfit or fit with restrictions. Governed by Policy - Records, Privacy and Health Information.

8.3 All records are written for disclosure under municipal freedom-of-information law, identify people by role in any report, and contain no diagnosis.

• The employer’s general duty to take every reasonable precaution, including against hazards no regulation names, and the worker’s duty not to work in a way that endangers others (J02 Duties of Employers, Supervisors, Workers and Contractors). Where no regulation sets fire-service hours of work or fatigue limits, the limits in 5.1 rest on the general duty.
• Hours-of-work and rest rules in labour standards law, which may not apply to firefighters, municipal employees or members covered by a collective agreement, and any statutory return-to-work duty after a compensable injury (J33 Return to Work, Accommodation and Hours of Work).
• Workers’ compensation presumptions for a heart attack within a set time of emergency response, and the participation rules volunteers must meet to be covered, which make post-incident rest (5.2) a compensation control as well as a safety one (J11 Volunteer Firefighters; J32 Workers' Compensation and Firefighter Presumptions).
• The licence class, air brake endorsement and driver medical standard for apparatus drivers, on which the fatigue and medication rules in 5.4 and 5.6 sit (J30 Emergency Vehicles, Drivers and Licensing).
• The management of impairment in the workplace on management-system principles (CSA Z1008:21).
• Fatigue as a psychosocial hazard and an element of psychological health and safety (CSA Z1003-13).
• Hazard identification covering human factors and emergency conditions (ISO 45001:2018, cl. 6.1.2).
• Medical evaluation content including sleep disorder screening, and rehabilitation at incidents (NFPA 1580, 2025).
• The duty to accommodate under the applicable human rights law (J33 Return to Work, Accommodation and Hours of Work) and the bona fide occupational requirement test (British Columbia (Public Service Employee Relations Commission) v. BCGSEU, 1999).
• Fatigue management guidance for emergency response (AFAC, 2022).
• The CPSE/CFAI accreditation path: wellness and fitness program with consequences for non-compliance stated (CPSE, 2019, criterion 11B); initial, regular and rehabilitative medical evaluations (11B.1); the annual appraisal of wellness program effectiveness (11B.6).

12.1 Reviewed 12 months after adoption, then every three years; after any vehicle incident or injury with fatigue as a factor; after any change to the collective agreement’s hours provisions; after any change to the impairment standard or human rights law; and on JOHSC request.

12.2 The limits in 5.1 are reviewed annually against the monitoring data in 5.8 and the members’ reports.

Put the consultation in writing. Record disagreement, adopt what can be adopted, revisit at 12 months.

Closing disclaimer. This model policy is general information prepared by The Human Factor for licensed use by {{Department}}. It is not legal advice. Confirm every statutory reference with counsel before adoption.

This chapter relies on the following legal requirements, which differ by province and territory. Check your jurisdiction’s section on each topic page before adopting it.

British Columbia (Public Service Employee Relations Commission) v. BCGSEU, [1999] 3 S.C.R. 3 (Supreme Court of Canada).

National Institute for Occupational Safety and Health [NIOSH]. (n.d.-c). Firefighters [Topic page, with health and safety resources]. Centers for Disease Control and Prevention. https://www.cdc.gov/niosh/firefighters/index.html