This document discusses shift rostering and outlines several key points: 1. Over 3.5 million people in the UK work shifts across many industries. Employers must consider worker health and safety when designing shifts. 2. There are special rules for night workers to limit average hours to 8 per 24 hours. Employers must provide health assessments for night workers. 3. Poorly designed shifts can increase fatigue, accidents, and illness. A compromise must be found between organizational needs, employee wishes, and health recommendations when reviewing shift patterns.

1. SHIFT ROSTERING
Unite (T&GWU)
May 2008
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2. INTRODUCTION
There are currently over 3.5 million people in the UK employed as shift workers in industries
including the emergency services, healthcare, security, transport, entertainment, the hotel industry,
utilities, manufacturing and the retail sector.
Employers have a general duty to take reasonable steps to ensure the health and safety of
employees at work. The Working Time Regulations 1998 place statutory restrictions on the number
of hours worked and stipulate minimum rest periods etc. A worker’s right to minimum rest periods
under the Regulations can be modified in the case of shift workers. Where this is the case, the
employer is obliged, to allow the worker to take an equivalent period of compensatory rest.
There are special rules, however, which apply to night workers. A shift worker is included in the
definition of a ‘night worker’ for the purposes of the Working Time Regulations if he or she works
rotating shifts which involve at least 3 hours of night time work in one week out of every three. In
order to protect the health and safety of such workers an employer is required to take all reasonable
steps to ensure that they do not work more than an average of eight hours in a 24 hour period.
An employer must also offer all night workers a free health assessment before they are assigned to
night work and on a regular basis thereafter. Records must be kept for two years to show that night
workers have not exceeded the working time limit and that the rules on health assessments have
been complied with.
Poorly designed shift-working arrangements, particularly when combined with long working hours,
can put shift workers at risk of fatigue, accidents, injuries and ill health. Those who work night time
and early morning shifts are particularly vulnerable. As well as laying the employer open to a
possible claim, employee fatigue can also affect productivity.
The HSE guidance
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3. SHIFT ROSTER REVIEW
"A tailor-made shift system should be a compromise between the employer's goals, the wishes of the
employees, and ergonomic recommendations for the design of shift systems." (Changing Schedules:
Shiftwork by P. Knauth, Chronobiology International, Volume 14, Issue 2 1997)
It may be worth reminding Management of the well established Employee Relations
protocols within the MoD:
Policy
The MoD is committed to providing staff with an opportunity to balance their commitments at
work and outside work. This means working with all staff, regardless of age, gender or
personal circumstances, to find solutions to juggling busy life schedules. We do this in a
number of ways, mainly through the generous leave package (which includes special paid and
unpaid leave as well as annual leave), through a range of alternative working patterns, the
provision of childcare facilities and holiday play schemes. The MOD is also committed to
moving staff to support their development needs and to suit their personal circumstances and
to help individuals returning after being away from MOD. The process is supported by the
Job Search Update which gives staff visibility of current vacancies. Some moves may
require a change of location for which there is a package of financial assistance. Guidance for
TLB Business Units on planning and implementing a Bulk Move and the implications for
Line Managers and Employees.
1.1 What is Employee Relations?
It is the general term to describe the relationship between employer,
employees and the TUs which represent employees.
The Corporate Employee Relations (ER) Team forms part of DGCP HR
Operations. It is responsible for developing, setting and communicating the
Department’s ER policy and for supporting its implementation throughout the
organisation. The team provides advice and guidance and encourages
management to apply consistent good practice in relations with staff and their
representatives. If you have a query about ER, please seek advice from your
HLB or TLB ER focal point.
The MoD Council of Civil Service Unions (CCSU) is funded by DGCP HR
Ops. The Chair of the CCSU is elected by the recognised NI TUs annually.
The other posts, detailed below, are established posts, open to TU members
only through Departmental selection procedures.
• Secretary – B2.
• Deputy Secretary – C1.
• Assistant Secretary – C2.
There is dedicated administrative support at E1 level.
TLB/TFs may also fund established posts to act as the focal point for TLB ER
matters.
1.2 The Role of Top Level Budget Holders, Trading Funds and Agency Chief
Executives and Managers
Senior managers are responsible for promoting good employee relations
within their areas of responsibility, and for consulting staff and their
representatives, including recognised TUs, on all matters likely to affect
civilian personnel. All managers must have an awareness of ER policy.
They must make sure that the right consultation procedures are followed
when considering changes in the workplace.
1.3 Departmental Policy on Employee Relations
A clearly defined framework for consultation and negotiation between
managers and staff must be in place for an ER system to work well. The
Department’s policy is to seek to maintain good employee relations through
the Whitley system (See Chapter 2 Section 2). This covers both formal and
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4. informal contacts between management and the TUs. Central to that policy
is the principle that management and TUs meet with a genuine desire to
reach agreement.
1.4 Consultation
The requirement to consult the TUs is embodied in law and ACAS Codes of
Practice. It is reinforced by the MoD’s commitment to the Whitley system and
the formal consultation procedures agreed with the TUs. (See Chapter 2
Section 3)
There are three main ways of communicating with the TUs about changes in
the workplace which affect civilian staff.
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Section 1
Basics
• Informing – Telling the TUs about an issue, such as the draft terms of
reference for a study.
• Consulting – Giving the TUs an opportunity to represent the views of their
members on any matter affecting civilian staff before final decisions are
taken, with a view to seeking agreement.
• Negotiating – Holding a discussion with the TUs aimed at reaching an
agreement, such as the process for changing pay or conditions of service.
Section 2 The Whitley System
2.1 Introduction
The Whitley system aims to bring about co-operation and agreement
between the Civil Service – as employer – and its staff. Its objectives are to:
• seek co-operation between employer and employees to increase
efficiency and ensure the well-being of staff;
• provide mechanisms for dealing with grievances which are not of a
personal nature; and
• provide a forum for discussion, where differing views can be expressed
and a range of experience can be drawn upon.
Three important principles underlie the system.
• The desired outcome is to secure agreement.
• The success depends on the good will of management and the TUs and
a willingness to consider each other’s point of view.
• It exists to support managers in ER matters, not to replace them.
2.2 Departmental Policy
The Department’s policy is to maintain good ER relations through the Whitley
system. MoD’s ER policy is based on full co-operation, at all levels, between
management and staff. Consultation and negotiation, with a view to reaching
agreement between the Department and the TUs is the cornerstone of this
policy.
The Whitley system is the formal means of consultation and negotiation for
industrial and non-industrial staff in the MoD. The interests of staff must be
properly taken into account before decisions are taken and consulting TUs is
one way that helps to bring about change with the minimum delay and
disturbance.
The Whitley system is conducted on several levels. If there is no Whitley at a
particular management level then the issue is referred to the next higher
level.
2.3 National Level
Non-Industrial. The National Whitley Council is the principal forum for
consulting on matters affecting non-industrial staff across the Civil Service. It
is chaired by the Head of the Home Civil Service and Secretary of the
Cabinet. The Permanent Secretaries of the major Departments are the
Management Representatives.
Industrial. There is no parallel body for industrial staff.
2.4 Departmental Level
Non-Industrial. The principal body for consultation between the Department
and its non-industrial staff is the Defence Whitley Council (DWC). It is chaired
by PUS, and meets twice a year.
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5. Shift Rostering Review
It has been long realised that there is no ideal shift system which is going to fully meet an
organisations needs and the individual health, social and family needs of each and every
employee. Balancing the Strategic and Operational demands with those of the Employee is
extremely complex. Tweaking or modifying shift patterns for the wrong reasons can be
counterproductive and have adverse affects on the health and well being of your employees
as well as major financial implications for the Employer (save a penny to lose a pound)
 increase stress,
 impact on social and domestic activities
 put unnecessary pressure on families,
 reduce earnings,
 increase fatigue,
 Increase absence due to sickness.
 Increase travel costs.
 Reduced Rest, Meal Breaks
 Constraints on Holiday entitlements
 Contractual implications etc.
There are many different shift work-schedules and each schedule has different features. This
sheer diversity of work and workplaces means that there is no single optimal shift system that
suits everyone. However, a planned and systematic approach to assessing and managing the
risks of shift work can improve the health and safety of workers.
There are a number of key risk factors in shift schedule design, which must be considered
when assessing and managing the risks of shift work. These are the workload, the work
activity, shift timing and duration, direction of rotation and the number and length of breaks
during and between shifts. Other features of the workplace environment such as the physical
environment, management issues and employee welfare can also contribute to the risks
associated with shift work.
As far as Unarmed Guarding is concerned the Strategic goal is to deploy the available and
limited resources as efficiently as possible so as to provide a 24/7 guarding service that meets
the needs of our customers and which will be responsive to emerging needs i.e. upsurges in
protestor activity or emergencies. In order to achieve the strategic goals managers need to
balance the Operational imperatives with the needs and well being of those who are
employed to carry out these tasks.
The first question that should be asked is; what kind of organisation do we need, is it one that
is based on the commercial sector, where deployment of assets are site specific or do we in
the MGS have a part to play in the overall strategic planning and deployment of assets. E.g.
during the Gulf war MGS Officers from Scotland were deployed to Marchwood at very short
notice, at not inconsiderable inconvenience to themselves and their families as did those who
had to make do with the short fall in manning. This would be very difficult if not impossible
under a fixed shift pattern.
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6. A one shift pattern to fit all is impracticable and inefficient. The Commercial sectors on the
whole operate a fixed shift pattern although this does vary from assignments the need for
strategic flexibility is not generally required. Where there is a need or demand for flexibility
it can be achieved through overtime which does not carry a premium.
The MGS management and to a greater degree the MDP Senior Officers have long argued the
need for flexibility in order to meet the demands of the UK Defence Strategy and Emergency
Response, e.g. MGS Officers are being tasked to assist with the distribution of Potassium
Iodine Tablets (P.I.Ts) to the vulnerable civilian population near to HMNB Clyde as part of
the MoD Nuclear accident response. In the commercial sector extra tasking equals extra
payment.
Legal advice and Contractual agreements ACAS
A contract of employment is an agreement between employer and employee and is the
basis of the employment relationship. A contract is made when an offer of employment
is accepted. A number of rights and duties, enforceable through the courts, arise as soon
as this happens.
Most employment contracts do not need to be in writing to be legally valid, but writing down
the terms of the contract will cut down on disagreements later on. The Employment Rights
Act 1996 requires employers to provide most employees with a written statement of the main
terms within two calendar months of starting work.
Not all terms are always explicitly agreed in writing (express terms). The courts have
established that all employment contracts have the following terms included, whether express
or implied:
 to maintain trust and confidence through co-operation
 to act in good faith towards each other
 to take reasonable care to ensure health and safety in the workplace
Some implied terms can become part of the contract because of the employer and employee's
behaviour, through custom and practice over time, or through a firm's rules (particularly if the
employee has been made aware of them and given access to them).
If you suffer a measurable financial loss because your employer has not followed the
agreed terms of your contract you can seek damages by making a breach of contract claim.
Normally this must be made to a county or other civil court but if the employment has
ended, it may be made to an employment tribunal.
Employers who suffer a measurable financial loss because an employee has departed from
the agreed terms of the contract of employment can also seek damages in the same way – as a
breach of contract claim or, if the employee has already claimed breach of contract to the
tribunal, as a counter-claim.
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7. The Information and Consultation of Employees (ICE) Regulations were introduced on 6
April 2005 and apply to businesses with 100 or more employees. From 6 April 2008, they
will apply to businesses with 50 or more employees. They give you the right to be:
 informed about the business's economic situation
 informed and consulted about employment prospects
 informed and consulted about decisions likely to lead to substantial changes in work
organisation or contractual relations, including redundancies and transfers
Consultation with employees must be carried out on matters to do with their health and
safety at work, including: any change which may substantially affect their health and
safety at work, for example in procedures, equipment or ways of working; the
employer’s arrangements for getting competent people to help him or her satisfy health
and safety laws; the information that employees must be given on the likely risks and
dangers arising from their work, measures to reduce or get rid of these risks and what
they should do if they have to deal with a risk or danger; the planning of health and
safety training; and the health and safety consequences of introducing new technology.
Changes to shift patterns would fall into this category and therefore must be fully
assessed.
Pattern of work; Working Time Regulations
8. Where the pattern according to which an employer organizes work is such as to put the
health and safety of a worker employed by him at risk, in particular because the work is
monotonous or the work-rate is predetermined, the employer shall ensure that the worker is
given adequate rest breaks. Shortages in manning levels and line managers and supervisors
reluctance to assist or to ensure rest breaks and meal breaks (mandatory JSP375) are
taken add to the problem. The incidence of Lone working has also increased.
Shift Design
Having established when and what the demand is, the next stage is to design a shift pattern
which best matches resources to demand by putting the right number of officers on duty, in
the right place and at the right time.
When designing or choosing a shift system there are a number of variable parameters to be
considered. These include whether fixed or rotating shifts, direction and speed of shifts,
lengths of shifts and starting times of shifts.
There are also various constraints to consider such as the Working Time Regulations and
Health and Safety Regulations. There are also legal requirements to consult with the
workforce on any changes being made to existing Systems of work i.e. Safety Reps and
Safety Committees, Occupational Health and Contractual obligations.
Extensive research into shift work and the effect it has on the health of shift workers has
resulted in a set of ergonomic recommendations which should also be taken into account
when devising shift patterns. These recommendations include:
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8.  minimise permanent nights;
 minimise sequence of nights: only 2-4 night shifts in succession should be worked;
 consider shorter night shifts;
 avoid quick change-over’s;
 plan rotas with some free weekends;
 avoid overlong work sequences;
 Rotate forward (i.e. clockwise rotation morning/ evenings/ nights);
 Avoid early starts.
(Guidelines For Shift workers, Ed. by A. Wedderburn, Bulletin of European Studies on Time,
1991).
Information and consultation
The tone of recent information provided by management has been perceived by many as
threatening and ‘Bullying’ this has been strongly denied by management, however JSP 763
may offer some insight;
‘ the conduct complained of must have the purpose or effect of violating the recipient’s dignity,
or of creating an intimidating, hostile, degrading, humiliating or offensive environment for them.
It makes no difference whether the conduct was intended to have either of these effects’.
‘Though most people will agree on extreme cases of bullying, behaviour that is considered
bullying by one person may be viewed as, for example, ‘firm management’ or ‘robust leadership’
by another. Such perceptions should, however, be treated sceptically and strongly discouraged, in
case they are being used as a pretext or euphemism for bullying’.
It cannot be denied that the effect of the information being disseminated is creating a Hostile
environment with fear for the future being uppermost in the minds of MGS Officers. Pushing
through with cost cutting measures on the pretext that it is a ‘test’ without stating clearly what the
criteria for success or failure is or in deed if a mechanism is in place to re-establish the status quo.
This is manifestly impacting on moral which in turn will impact on operational effectiveness.
Hazards associated with Shift working; Fatigue and sleep deficit.
In the UK, there is no specific health & safety legislation on shift working. Nevertheless
employers have general health & safety responsibilities (e.g. a duty of care in law) for their
employees and others. This duty includes removing or controlling the health risks (which
includes mental health) associated with shift working by properly organising and planning
shift-working arrangements. Their broader responsibility for the health and safety of others
(e.g. the public) that might be affected by their work activities e.g. fatigue.
Fixed shifts cause the least disruption to circadian rhythms, provided that the workers
maintain the same sleep/wake cycle on their rest days as on their work days. However, most
night workers revert to a normal day/night cycle on their days off to participate in
family/social life, thus negating any adjustment in circadian rhythms. Fixed shifts are popular
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9. with Employees as they have the advantage of forward planning. The disadvantages are that
management does not have the same flexibility e.g. during surges in demand.
Slowly rotating shifts allow greater time for circadian rhythms to adjust to each new shift.
However, this type of shift system can result in sleep debt and fatigue due to more
consecutive periods of day sleep. Studies on shift workers have shown it takes about 21
consecutive days for circadian rhythms to fully adjust to nightshift. Again, workers tend to
revert to a normal day/night cycle on their rest days during this period, thus negating any
adjustment which has begun.
Weekly rotating shifts have been shown to provide insufficient time for the circadian
rhythms to adjust completely and enough time for a sizeable 'sleep debt' to build up. Working
4 to 7 night shifts in a row is now widely condemned by experts. Many Police Forces which
adopted the 'Ottowa' shift pattern in the early 1990 (which included 7 consecutive nights) are
now looking at VSA's (Variable Shift Arrangements) which minimise consecutive nights.
Rapid rotating shifts have the advantage that (i) the circadian rhythms remain day orientated
since not enough time elapses for them to adjust to the new routine;(ii) there is less
accumulation of sleep debt; and (iii) there are free evenings every week for social/ family
contact. The disadvantage is that when on the 2 to 4 nights of work, the worker will be out of
sync and alertness may be affected.
Direction of Rotation: Forward rotation (early/late/nights) is recommended from a circadian
perspective because the internal body clock naturally tends to run slow (i.e. every 25 hrs). It
is easier then, to delay sleep than it is to advance it. Consider 'jet lag' - people experience less
jet lag going from east to west than from west to east. The same principle is at work.
However some workers prefer a backward rotation (nights/late/early) because it affords more
time to recover lost sleep and prepare for the next night shift.
Early starts to the morning shift should be avoided. Early starts reduce sleep as, by choice
or by family circumstances, most workers go to bed around their normal time. Reduced sleep
leads to fatigue which increases the risk of errors and accidents on the morning shift.
There is no optimum starting time - but 0700hrs is better than 0600hrs which is better than
0500hrs.
Consider shorter night shifts. As mental alertness and physical performance deteriorate
during the night, it is argued that night shift should be restricted to 7 or 8 hours to minimise
the risk of errors and accidents. VSA's enable the Early or Late shifts to be extended
accordingly.
Minimise sequence of nights. Minimising the sequence of nights worked minimises the
degree of adaption (or disruption) of the circadian rhythms from their normal day orientation.
Academic recommendations vary between a maximum of 2 and 4 consecutive nights.
Combination, Floating Shifts. Has the advantage of the rapidly rotating shift pattern with a
period flexibility that allows management the capacity to increase manning during periods of
foreseeable demand. It also allows an element of choice and can tailored to meet the needs of
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10. both the employee and management, i.e. those that prefer day or night working family or
social purposes can be accommodated and shorter but more shifts can be used by
management to give them the flexibility they require.
Recent research within the Police service on this subject was conducted by Sgt Carl Masson,
Merseyside Police. His publication 'Healthy Nights' published by the Home Office Police
Research Group goes into this in greater detail .
For a summary of the research, see the recent article 'The Killer Shift', published in the Police
Federation magazine 'Police' in November 2000.
Rest days. Sleep debt does not have to be paid back "in full" on rest days as recovery sleep is
deeper than normal sleep. However, 2 nights of unrestricted sleep after a sequence of night
shifts is recommended to recover from sleep loss.
Designing Shift Schedules. The design of shift systems is a complex task which is not easily
done by hand. However, there are commercial computer shift scheduling packages available
which might assist shift designers in their task. There are also a number of academic experts
in this field which managers should consider consulting. The following examples of shift
working patterns employed by various Police forces around the country are to a greater extent
based on the manning requirements of the particular force.
.
The starting times depend on how the 'Force day' is defined - 0600hrs to 0600hrs or 0700hrs
to 0700hrs, which in itself would be a factor to take into account.
Further schedules will be added as they become known, to highlight the development of
police shift schedules away from the traditional Regulation Shift Pattern.
Traditional Police Regulation shift pattern
Week M T W T F S S
1 N N N N N N N
2 - - L L L L L
3 L L - - E E E
4 E E E E - - -
N=2300hrs to 0700hrs
L=1500hrs to 2300hrs
E=0700hrs to 1500hrs
The problem with the 'traditional' shift pattern is that over the 4 week cycle 168 hours are
worked, which equates to an average of 42 hours per week. This is in excess of the average
working week for police officers in the UK of 40 hours per week. This means that for each
cycle of the shift pattern each officer is owed 8 hours.
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11. 'Ottawa'shift pattern (Early 1990's)
Week M T W T F S S
1 N N N N - - -
2 - - - L+ L+ L+ L
3 - - E E E - -
4 L L L - - E E
5 E E - - N+ N N
E = 0700hrs to 1700hrs
L = 1400hrs to 2400hrs, L+ = 1700hrs to 0300hrs
N = 2230hrs to 0700hrs, N+ = 2300hrs to 0700hrs
The 'Ottawa' shift pattern involves working extended shift lengths in order to increase the
number of days off, but still includes 7 night shifts in a row.
Variable Shift Arrangement (Late 1990's) - Merseyside Police
Week M T W T F S S
1 N N N N - - -
2 E E E - - L+ L
3 L L - - N N N
4 - - - E E+ E+ E
5 - - L L L+ - -
E = 0700hrs to 1600hrs (9 hours) , E+ = 0700hrs to 1700hrs (10 hours)
L = 1400hrs to 2400hrs (10 hours), L+ = 1600hrs to 0300hrs (11 hours)
N = 2200hrs to 0700hrs (9 hours)
Variable Shift Arrangement(Late 1990's) - Thames Valley Police
Week M T W T F S S
1 N1 N1 L2 L2 - - -
2 E E E - - L1 L2
3 L2 L2 - - N3 N3 N2
4 - - TIA E+ E+ E+ E+
5 - - N1 N2 L1 - -
E = 0700hrs to 1500hrs (8 hours), E+ = 0700hrs to1700hrs (10 hours)
L1 = 1630hrs to 0230hrs (10 hours), L2= 1400hrs to 2230hrs (8 1/2 hours)
N1 = 2200hrs to 0700hrs (9 hours), N2 = 2130hrs to 0700hrs (9 1/2 hours)
N3 = 2100hrs to 0700hrs (10 hours) TIA = Team in Action/Training (8 hours)
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12. Variable Shift Arrangement (Early 2000's) - Grampian Police
Week M T W T F S S
1 - D TR L N N N
2 - - E E E - -
3 L L L - - E E
4 E E - - L+ L+ L
5 N N N N - - -
TR = Training/ Pro-active policing day (8 hours)
E = 0600hrs to 1500hrs (9hours)
D = Report Writing / Training day (8 hours)
L = 1400hrs to 2300hrs (9 hours) L+ = 1400hrs to 2400hrs (10 hours)
N = 2200hrs to 0600hrs (8 hours)
Variable Shift Arrangements with Sub Groups (2000 onwards)
Traditionally, police officers have been organised into teams or Units comprising fixed
numbers of officers. Officers within the same Unit commence and finish a tour of duty
together. Being 'part of a team' encouraged comradeship, loyalty and trust. In striving to
better match limited resources to peaks and troughs in demand, however, Police managers (in
the UK) are now challenging the rigidity of those Units. As a result they now talk about
having a 'Core Shift Pattern' around which sub-groups of each Unit work.
Any of the above shift schedules can be used as a 'Core Shift Pattern'. The core Units are then
sub-divided into 2 or 3 (or more)sub-groups. Each Sub-group is then scheduled around the
'Core shift'times to better match resources to demand:
Week M T W T F S S
1A N N N N - - -
1B N* N* N* N*
2A E E E - - L+ L
2B
3A L L - - N N N
3B
4A - - - E E+ E+ E
4B E* E*
5A - - L L L+ - -
5B
E= 0700hrs to 1600hrs (9 hours), E+ = 0700hrs to 1700hrs (10 hours)
L = 1400hrs to 2400hrs (10 hours), L+ = 1600hrs to 0300hrs (11 hours)
N = 2200hrs to 0700hrs (9 hours)
N* = 1800hrs to 0300hrs (9hours) E* = 1000hrs to 2000hrs (10 hours)
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13. The above is an example of a 5 Unit / 2 Sub-Group shift schedule.
In Week 1, sub-group 1A works nightshift Monday to Thursday. However, as analysis of
local demand shows a greater need for officers in the early evening, sub-group 1B falls back
to augment the Late shift.
In Week 4, sub-group 4A works the extended Early shift on Friday and Saturday. However,
as analysis shows that a whole Unit is required for Night shift on those days,it is necessary
for sub-group 4B to move forward from the Early shift to augment the Late shift.
On all other days (in this example) sub-group B works the same Core shift as sub- group A,
to form a whole Unit. After 5 weeks the sub-groups swap roles. Thus over a 10 week period a
subgroup would follow the shift pattern sequence:
1A,2A,3A,4A,5A,1B,2B,3B,4B,5B
Obviously, the more subgroups a core Unit is divided into, the closer police managers believe
they can 'fit' resources to demand. Sub-Groups themselves do not have to be rigid, or even of
equal size; in the example above, subgroup 1B might be 1/3, 1/4 etc of the Unit size. The
Unit is seen as a 'pool' from which officers are drawn to create the required sub-group. Over
the period of a year proper resource management is meant to ensure that officers are drawn
from the 'pool' equally.
In Scotland, Strathclyde Police work a variation of a 4 Unit / 3 Sub Group shift schedule,
whilst Grampian Police works a variation of a 5 Unit / 3 Sub Group shift schedule.
The logical projection of continually sub-dividing the core Units into sub-groups, in order to
fit resources to demand, is to eventually arrive at individualised shift patterns for each
police officer. This has already been done in Finland for some industrial workers.
There must, however, be a downside to this managerial trend away from the traditional
Units; firstly, in terms of the esprit de corp which Units cultivate within themselves and
within the police service as a whole and, secondly, in terms of the possible increase in stress
on officers associated with working irregular and unpredictable rosters and the effects that
has on an officer's family and social life.
2x2x2 or '6 on, 4 off' Shift Pattern
This shift pattern is also known as the Leicestershire 2x2x2 shift pattern and can be
interpreted in two different ways:
Firstly, it can be operated as a Five Unit shift system with a shift cycle of 10 weeks. Over the
10 week cycle there will always be an Early, Late and Night shift on duty each day.
Alternatively, it could be operated by dividing the 5 Units each into 2 sub groups. However
the sub groups of the same Unit would not share the same days off, so the sub groups would
effectively become smaller Units.
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14. This shift pattern meets all the criteria for the design of a good shift pattern. However, over a
6 day block officers can work up to 58 hours which can cause problems with Working Time
compliance if officers are already at the 48 maximum average weekly limit.
Week M T W T F S S
1 E E L L1 N N -
2 - - - E1 E L2 L1
3 N N - - - - E1
4 E L L N N - -
5 - - E1 E1 L2 L2 N
6 N - - - - E E1
7 L L N N - - -
8 - E E1 L1 L2 N N
9 - - - - E E L1
10 L N N - - - -
E = 0700hrs to 1700hrs E1 = 0700hrs to 1600hrs
L = 1400hrs to 0000hrs L1 = 1500hrs to 0100hrs L2 = 1700hrs to 0300hrs
N = 2200hrs to 0700hrs
Variable Shift Arrangement ( 2002 ) - Bedfordshire
As more and more Forces realise that they have a duty of care to minimise the risks of
shiftwork on their staff, they are rightly beginning to consult experts on shiftwork.
The following shift pattern was devised in consultation with Shiftwork experts to reduce the
adverse effects of shiftwork on staff. It may not meet individual officer's personal
preferences, but its design seeks to fulfill the employer's obligation under Health and Safety
Legislation. It is Working Time compliant unless night work is identified as involving special
hazards by a risk assessment conducted by the employer or by a Workforce Agreement
between the Employer and staff association.
Week M T W T F S S
1 N N N N+ - - -
2 L1 L L - - E+ E
3 E+ E - - N+ N+ N
4 - - - L+ L+ L+ L
5 - - E E+ E+ - -
E = 0700hrs to 1500hrs E+ = 0700hrs to 1700hrs
L = 1400hrs to 2400hrs, L+ = 1700hrs to 0300hrs, L1 = 1230hrs to 2230hrs
N = 2200hrs to 0700hrs, N+ = 2100hrs to 0700hrs
Although this is a backward rotating shift pattern, the social and domestic advantages to staff
were considered to outweigh the medical advantages of the forward rotating version. The
14

15. pattern ensures that no more than 3 or 4 Nights are worked in a row and that there are 3 rest
days after each blocks of nightshift to recuperate.
The extended Early shift and overlapping Late shift on Mondays is to facilitate 4 hours of
training for the Late shift before change over. However those overlapping hours can be
dispersed elsewhere in the shift pattern according to need.
MGS HMNB Clyde
Sun Mon Tues Wed Thurs Fri Sat Sun Mon Tues
Week 1 -8 D D N N R R R R D D
Week 9 N R R D D R R R R R
Week 10 D D D N N R R
D = 0700-1900
N=1900-0700
R= Rest day
Note; the MGS are conditioned to work 42 hours pw
During the 14 day Floating period combinations of differing lengths of shift up to 84 hours
could be incorporated to meet surges in demand. However at present this is not done and 7
twelve hour shifts are worked either Days or Nights or a mixture of both.
The cost savings that will be made by the proposed shift pattern (removing the floating shift)
will be reduced by the increased weekend premiums.
The health benefits from having a break in the fixed / core pattern cannot be over stressed,
allowing the circadian rhythms adjust and compensate for any sleep dept during the Fixed
period of the roster pattern.
At present the Float also provides a period where training can be planned.
Working Time Regulations
There is a danger when considering preventative measures in isolation i.e. the non sequitur
‘long working hours cause ill health’ therefore reducing hours will make employees healthier
is often used as a reason for reducing hours. What we do, how we do it and the environment in
which we work during a shift have greater impact on the well being of individuals. Long hours would
not in its self constitute a high risk to health particularly where the overtime in question is voluntary
(Volenti non fit injuria). Any vicarious responsibility would only be considered as a contributory factor
if the overtime was compulsory. Occupational health advice to have a maximum 32 hours
overtime/ maximum average 48 hour working week in a rolling reference period of 17 weeks,
15

16. should in most cases, be as suggested, advice or more appropriately, used as part of an overall
strategy and flexible tool in dealing with health issues associated with shift working. Its
impact on operational imperatives must also be considered, there are a number of options open for
consideration.
Regulation 21 (41) of the Working Time Regulations allows the reference period for the
measurement of working time to be increased to 26 week (Reg 4), this would allow much greater
flexibility when calculating Maxima, by the simple expedient, that it would to a greater extent
encompass leave periods (excluded days), i.e. times when manning levels are under the highest
pressures. extending the reference period by the amount of leave taken and importantly the rest
days immediately before and after the period of leave which are not excluded days:
For the purposes of this regulation, a worker's average working time for each seven days
during a reference period shall be determined according to the formula -
A+B
C
Where -
A is the aggregate number of hours comprised in the worker's working time during
the course of the reference period;
B is the aggregate number of hours comprised in his working time during the course
of the period beginning immediately after the end of the reference period and ending
when the number of days in that subsequent period on which he has worked equals
the number of excluded days during the reference period; and
C is the in the reference period.
(7) In paragraph (6), "excluded days" means days comprised in -
(a) any period of annual leave taken by the worker in exercise of his entitlement
under regulation 13;
(b) any period of sick leave taken by the worker;
(c) any period of maternity leave taken by the worker; and
(d) any period in respect of which the limit specified in paragraph (1) did not
apply in relation to the worker by virtue of regulation 5.
Moreover, Regulation 18. Excluded sectors apply to the majority of the MDPGA.
Excluded sectors
18. Regulations 4(1) and (2), 6(1), (2) and (7), 7(1), and (6), 8, 10(1), 11(1) and
(2), 12(1), 13 and 16 do not apply -
to the following sectors of activity -
16

17. air, rail, road, sea, inland waterway and lake transport;
(ii) sea fishing;
(iii) other work at sea; or
to the activities of doctors in training, or
(c) where characteristics peculiar to certain specific[a] services such as the armed
forces or the police, or to certain specific activities in the civil protection services,
inevitably conflict with the provisions of these Regulations.
Compensatory rest
24. Where the application of any provision of these Regulations is excluded by
regulation 21 or 22, or is modified or excluded by means of a collective agreement or
a workforce agreement under regulation 23(a), and a worker is accordingly required
by his employer to work during a period which would otherwise be a rest period or
rest break -
his employer shall wherever possible allow him to take an equivalent period of
compensatory rest, and
(b) in exceptional cases in which it is not possible, for objective reasons, to grant such
a period of rest, his employer shall afford him such protection as may be appropriate
in order to safeguard the worker's health and safety.
Remedies
30. - (1) A worker may present a complaint to an employment tribunal that his
employer -
has refused to permit him to exercise any right he has under -
regulation 10(1) or (2), 11(1), (2) or (3), 12(1) or (4) or 13(1);
(ii) regulation 24, in so far as it applies where regulation 10(1), 11(1) or (2) or 12(1) is
modified or excluded; or
(iii) regulation 25(3) or 27(2); or
has failed to pay him the whole or any part of any amount due to him under regulation
14(2) or 16(1).
(2) An employment tribunal shall not consider a complaint under this regulation
unless it is presented -
before the end of the period of three months (or, in a case to which regulation 38(2)
applies, six months) beginning with the date on which it is alleged that the exercise of
the right should have been permitted (or in the case of a rest period or leave extending
over more than one day, the date on which it should have been permitted to begin) or,
as the case may be, the payment should have been made;
17

18. (b) within such further period as the tribunal considers reasonable in a case where it is
satisfied that it was not reasonably practicable for the complaint to be presented
before the end of that period of three or, as the case may be, six months.
(3) Where an employment tribunal finds a complaint under paragraph (1)(a) well-
founded, the tribunal -
shall make a declaration to that effect, and
(b) may make an award of compensation to be paid by the employer to the worker.
(4) The amount of the compensation shall be such as the tribunal considers just and
equitable in all the circumstances having regard to -
the employer's default in refusing to permit the worker to exercise his right, and
(b) any loss sustained by the worker which is attributable to the matters complained
of.
(5) Where on a complaint under paragraph (1)(b) an employment tribunal finds that
an employer has failed to pay a worker in accordance with regulation 14(2) or 16(1),
it shall order the employer to pay to the worker the amount which it finds to be due to
him.
Right not to suffer detriment
31. - (1) After section 45 of the 1996 Act there shall be inserted -
" Working time cases.
45A. - (1) A worker has the right not to be subjected to any detriment by any act,
or any deliberate failure to act, by his employer done on the ground that the worker -
refused (or proposed to refuse) to comply with a requirement which the employer
imposed (or proposed to impose) in contravention of the Working Time Regulations
1998,
(b) refused (or proposed to refuse) to forgo a right conferred on him by those
Regulations,
(c) failed to sign a workforce agreement for the purposes of those Regulations, or to
enter into, or agree to vary or extend, any other agreement with his employer which is
provided for in those Regulations,
(d) being -
a representative of members of the workforce for the purposes of Schedule 1 to those
Regulations, or
(ii) a candidate in an election in which any person elected will, on being elected, be
such a representative,
18

19. performed (or proposed to perform) any functions or activities as such a
representative or candidate,
(e) brought proceedings against the employer to enforce a right conferred on him by
those Regulations, or
(f) alleged that the employer had infringed such a right.
(2) It is immaterial for the purposes of subsection (1)(e) or (f) -
whether or not the worker has the right, or
(b) whether or not the right has been infringed,
but, for those provisions to apply, the claim to the right and that it has been infringed
must be made in good faith.
(3) It is sufficient for subsection (1)(f) to apply that the worker, without specifying
the right, made it reasonably clear to the employer what the right claimed to have
been infringed was.
(4) This section does not apply where a worker is an employee and the detriment in
question amounts to dismissal within the meaning of Part X, unless the dismissal is in
circumstances in which, by virtue of section 197, Part X does not apply."
(2) After section 48(1) of the 1996 Act there shall be inserted the following
subsection -
" (1ZA) A worker may present a complaint to an employment tribunal that he has
been subjected to a detriment in contravention of section 45A."
(3) In section 49 of the 1996 Act[18] (remedies) -
in subsection (2), for "subsection (6)" there shall be substituted "subsections (5A) and
(6)", and
(b) after subsection (5), there shall be inserted -
" (5A) Where -
the complaint is made under section 48 (1ZA),
(b) the detriment to which the worker is subjected is the termination of his worker's
contract, and
(c) that contract is not a contract of employment,
any compensation must not exceed the compensation that would be payable under
Chapter II of Part X if the worker had been an employee and had been dismissed for
the reason specified in section 101A."
19

20. (4) In section 192(2) of the 1996 Act (provisions applicable in relation to service in
the armed forces), after paragraph (a) there shall be inserted -
" (aa) in Part V, section 45A, and sections 48 and 49 so far as relating to that
section,".
(5) In sections 194(2)(c), 195(2)(c) and 202(2)(b) of the 1996 Act, for "sections 44
and 47"there shall be substituted "sections 44, 45A and 47".
(6) In section 200(1) of the 1996 Act (which lists provisions of the Act which do
not apply to employment in police service), after "45," there shall be inserted "45A,".
(7) In section 205 of the 1996 Act (remedy for infringement of certain rights), after
subsection (1) there shall be inserted the following subsection -
" (1ZA) In relation to the right conferred by section 45A, the reference in subsection
(1) to an employee has effect as a reference to a worker."
Unfair dismissal
32. - (1) After section 101 of the 1996 Act there shall be inserted the following
section -
" Working time cases.
101A. An employee who is dismissed shall be regarded for the purposes of this
Part as unfairly dismissed if the reason (or, if more than one, the principal reason) for
the dismissal is that the employee -
refused (or proposed to refuse) to comply with a requirement which the employer
imposed (or proposed to impose) in contravention of the Working Time Regulations
1998,
(b) refused (or proposed to refuse) to forgo a right conferred on him by those
Regulations,
(c) failed to sign a workforce agreement for the purposes of those Regulations, or to
enter into, or agree to vary or extend, any other agreement with his employer which is
provided for in those Regulations, or
(d) being -
a representative of members of the workforce for the purposes of Schedule 1 to those
Regulations, or
(ii) a candidate in an election in which any person elected will, on being elected, be
such a representative,
performed (or proposed to perform) any functions or activities as such a
representative or candidate."
(2) In section 104 of the 1996 Act (right of employees not to be unfairly dismissed for
asserting particular rights) in subsection (4) -
20

21. at the end of paragraph (b), the word "and" shall be omitted, and
(b) after paragraph (c), there shall be inserted the words -
" and
(d) the rights conferred by the Working Time Regulations 1998."
(3) In section 105 of the 1996 Act (redundancy as unfair dismissal), after subsection
(4) there shall be inserted the following subsection -
" (4A) This subsection applies if the reason (or, if more than one, the principal reason)
for which the employee was selected for dismissal was one of those specified in
section 101A."
(4) In sections 108(3) and 109(2) of the 1996 Act, after paragraph (d) there shall be
inserted -
" (dd) section 101A applies,".
(5) In sections 117(4)(b), 118(3), 120(1), 122(3), 128(1)(b) and 129(1) of the 1996
Act, after "100(1)(a) and (b)," there shall be inserted "101A(d),".
(6) In section 202(2) (cases where disclosure of information is restricted on ground
of national security) -
in paragraph (g)(i), after "100" there shall be inserted ", 101A(d)", and
(b) in paragraph (g)(ii), after "of that section," there shall be inserted "or by reason of
the application of subsection (4A) in so far as it applies where the reason (or, if more
than one, the principal reason) for which an employee was selected for dismissal was
that specified in section 101A(d)".
(7) In section 209(2) of the 1996 Act (which lists provisions excluded from the scope
of the power to amend the Act by order), after "101," in paragraph (e) there shall be
inserted "101A,".
(8) In sections 237(1A) and 238(2A) of the Trade Union and Labour Relations
(Consolidation) Act 1992[19] (cases where employee can complain of unfair
dismissal notwithstanding industrial action at time of dismissal), after "100" there
shall be inserted ", 101A(d)".
(9) In section 10(5)(a) of the Employment Tribunals Act 1996[20] (cases where
Minister's certificate is not conclusive evidence that action was taken to safeguard
national security), after "100" there shall be inserted ", 101A(d)".
21

22. The need to reduce costs as a result of illness is, in every ones interest and as an organisation
to be ‘match fit’ is crucial. Training and information is recognised as an important tool and
we seem to be making very positive steps in areas of e.g. Customer care and training for first
and second line managers in recognising stress in others etc. However in order to be match fit
as an organisation, individuals have to be match fit. Recognising the causes as well as the
symptoms of ill health would take us that much closer to developing a fitter organisation.
Many variables and stressors have been identified that possibly contribute toward intolerance
of shift work and subsequent negative health effects. Costa (1996 et al) gives a
comprehensive list of factors which can impinge on an individual’s ability to adapt to shift
work. These factors have negative or positive effects on individual tolerance to shift work
according to different circumstances i.e. an individual’s need for sleep can be dependent on
different social/domestic factors such as number and age of children. Intolerance to shift
working has been postulated to follow a developmental process that exhibits four main
phases: adaptation, sensitisation, accumulation and manifestation (Haider 1981 et al). There
is no single solution to the problems encountered (Monk and Folkard, 1992).
Developments 2003 - 2007
If managers have conducted proper risk assessments, and have identified particular activities
as involving significant risk, then the choice of shift patterns for those employees who are
classed as night workers, when engaged in those activities, is further reduced by the
restriction on the length of the night shift to 8 hours.
When considering new Shift patterns or modifying existing ones the WTR allows flexibility
in so far as the standard 17 week monitoring period can be extended to 26 weeks
On 1 July 1998 the Police (Health and Safety) Act 1997 came into force, formally
recognising police officers as 'employees' for the purposes of regulations made under Part 1
of the Health and Safety at Work Act 1974.
On 14 April 1999 the Police (Health and Safety) Regulations 1999 came into force,
formally recognising that police officers were now fully covered by the health and safety
legislation.
Part 1 of the 1974 Act places a 'duty of care' on employers to ensure, so far as is reasonably
practicable, the health, safety and welfare at work of all their employees. This duty extends to
the provision of systems of work, which is interpreted as including hours of work and, in
particular, shift work. (Section 1).
Under the same legislation an employee has a general 'duty of care' while at work to take
reasonable care for the health and safety of himself and of any other persons who may be
affected by his acts or omissions at work (Section 7).
Since the European Council Directive No.93/104/EC of 23 November 1993 concerning
certain aspects of the organisation of working time, Member States have been under an
22

23. obligation to ensure that employers who intend to organise work according to a certain
pattern take account of the general principle of adapting work to the worker.
As a response to that directive the Working Time Regulations 1998 were introduced in the
UK. These regulations lay down statutory requirements on employers to restrict and monitor
their employee's working time, and give employee's certain rights with regard maximum
working hours, rest breaks and rest periods.
The Working Time Regulations 1998 came into force on 1st October 1998 and apply
specifically to the Police Service by virtue of Regulation 41.
The consequences of the Health and Safety at Work Act 1974 and the Working Time
Regulations 1998 on the Police Service are that:
 Police managers are now legally bound to produce shift patterns which seek to
minimize the adverse effects of shift work upon their staff; and
 Staff have an obligation to be aware of the consequences of shift work on their
health and safety and that of their colleagues.
Guidance on how the Working Time Regulations should be interpreted and applied is
provided by the Department of Trade and Industry.
"Select a shiftwork schedule that would have the least harmful
effect on the employee's health, family and personal life - consult
employees and specialists in shift scheduling." (International Hazard
Data Sheet on Occupation for Police/Law Enforcement Officer, International Labour
Organisation, 1999)
The International Labour Organisation ( www.ilo.org ) recognises shiftwork as an
'ergonomic, psychological and organisational' hazard related to the job, and states, as the
preventative measure:
" Select a shiftwork schedule that would have the least harmful effect on the employee's
health, family and personal life - consult employees and specialists in shift scheduling."
The Health and Safety Executive ( www.hse.gov.uk), in their book "Reducing Error and
Influencing Behaviour" (HSE 1999) recommend a 'best practice' management approach
towards minimising the impact of shift work, which will go beyond what is required by the
health and safety legislation and will include:
 careful planning of shift rostering taking into account knowledge of the effects
of biological rhythms;
 education of shift workers on sleep routines, nutrition, effects on family and
social life, exercise;
 environmental design changes, especially those aspects which can improve
alertness such as temperature, lighting and comfort levels;
 providing medical advice for shift workers, especially for those with existing
medical conditions.
23

24. Recommending a 'best practice' management approach to minimising the impact of
shiftwork, and specifying preventative and control measures, suggests that the HSE also
recognises shiftwork per se as an occupational health and safety hazard.
If shiftwork is an OHS hazard, then employers are required, by virtue of Regulation 3 of the
Management of Health and Safety at Work Regulations 1999, to assess the risks of
shiftwork in the same way as any other OHS hazard using, for example, the HSE's '5-Steps to
Risk Assessment' approach, namely:
1. Identify the hazards.
2. Decide who may be harmed and how.
3. Evaluate the risks and decide the control measures necessary.
4. Record the findings.
5. Review the assessment from time to time and revise it if necessary.
The adverse effects associated with shiftwork and irregular working hours include:
 increased risk of accidents and injuries caused by sleep debt and fatigue.
 increased risk to physical health caused by disruption to biological rhythms
and disturbed eating patterns.
 increased risk to mental health caused by disruption to biological rhythms and
working unsociable/extended hours.
 increased exposure to other occupational hazards such as chemicals, heat,
noise, poor lighting, manual handling and violence.
In Australia, the National Occupational Health and Safety Commission and the Australian
Council of Trade Unions both recognise shiftwork as an OHS hazard and have published
guidance for employers on assessing and managing the risks associated with shiftwork.
The first and foremost control measure is to eliminate, or reduce as far as possible, the need
for shiftwork.
The second control measure is to adopt shift schedules that are based on ergonomic and
medical recommendations.
In order to demonstrate their general duty of care under the health and safety legislation,
Police Forces in the UK need to consider appointing or consulting a 'competent person', as
described under Regulation 7 of the MHSWR 1999, who "has sufficient training and
experience or knowledge and other qualities to enable him to assist" them in devising
suitable shift schedules.
Police Forces also need to review their traditional organisation of work and working practices
in the light of the Working Time Regulations and health and safety legislation to ensure that
officers do not work excessive hours, and that they are given the opportunity to take the rest
breaks and rest periods to which they are entitled.
How do you Risk Assess Shift Schedules?
The Health and Safety Executive have published a report "Validation and development of a
method for assessing the risks arising from mental fatigue", Contract Research Report
24

25. 254/1999, which involves the calculation of a Fatigue Index to help assess the risks arising
from the impact of shift schedules on mental fatigue in safety critical work.
The Fatigue Index requires the calculation of 5 factors, namely shift start time (F1), shift
duration (F2), rest period between shifts (F3), breaks during shifts (F4) and cumulative
fatigue (F5), which are added together to give an overall index for the shift schedule.
The Fatigue Index provides a straightforward way of comparing the features of two working
patterns in terms of their relative contributions to fatigue. It does not provide an absolute
measure of fatigue.
The calculations involved are not complicated although they can be time consuming. The
HSE suggests that they could be incorporated into a spreadsheet for automatic calculation.
The Fatigue Index has been presented to a wide range of industries and the feedback
suggests that it may be a useful tool for providing employers with an initial risk assessment of
the levels of fatigue associated with a particular shift schedule.
The MDPGA should perhaps consider using the Fatigue Index as an initial means of
assessing their own shift schedules.
Night Work
In 1990 the General Conference of the International Labour Organisation convened in
Geneva and considered certain proposals with regard to night work. The Conference
determined that some of those proposals should be adopted and should take the form of an
international Convention (the Night Work Convention 1990) whilst other proposals should
be adopted and should take the form of a Recommendation (the Night Work
Recommendation 1990), supplementing those in the Night Work Convention 1990.
Paragraph 3(1) of the Recommendation states that the provisions of the Recommendation
may be implemented by laws or regulations, collective agreements, arbitration awards or
court decisions, a combination of these means or in any other manner appropriate to national
conditions and practice.
Paragraph 4(1) states that the normal hours of work for night workers should not exceed eight
in any 24 hour period in which they perform night work, except in the case of work which
includes substantial periods of mere attendance or stand-by.
Paragraph 4(2) further states that the normal hours of night workers should generally be less
on average than and, in any case, not exceed on average those workers performing the same
work to the same requirement by day in the branch of activity or the undertaking concerned.
Paragraph 11 states in determining the content of the tasks assigned to night workers, account
should be taken of the nature of night work and of the effects of environmental factors and
forms of work organisation. Special attention should be paid to factors such as toxic
substances, noise and vibration, lighting levels and to forms of work organisation involving
heavy physical or mental strain or monotonous. Cumulative effects from such factors and
forms of work organisation should be avoided or reduced.
25

26. The European Council Directive No.93/104/EC of 23 November 1993 concerning certain
aspects of the organisation of working time does not go as far as the Night Work
Recommendation 1990 in limiting the hours of night workers. Article 8(1) states that the
normal hours of work for night workers must not exceed an average of eight hours in any 24
hour period (over the reference period) and qualifies this in Article 8(2) by further stating that
only night workers whose work involves special hazards or heavy physical or mental strain
must not work more than eight hours in any period of 24 hours during which they perform
night work.
For the purposes of Article 8, work involving special hazards or heavy physical or mental
strain shall be defined by national legislation and/or practice or by collective agreements or
agreements concluded between the two sides of industry, taking account of the specific
effects and hazards of night work. In other words the EC Directive avoided being as
prescriptive as the Night Work Recommendation 1990 in defining such effects and hazards
itself.
The provisions of the Working Time Regulations 1998 with regard night work follow those
of the EC Directive. Regulation 6(1) reiterates the provisions of Article 8(1) whilst
Regulation 6(7) reiterates the provisions of Article 8(2):
However, in addition Regulation 6(8) states that the work of a night worker shall be regarded
as involving special hazards or heavy physical or mental strain if (a) it is identified as such in
(i) a collective agreement, or (ii) a workforce agreement, which takes account of the specific
effects and hazards of night work, or (b) it is recognised in a risk assessment made by the
employer under Regulation 3 of the Management of Health and Safety at Work Regulations
1992 as involving a significant risk to the health or safety of workers employed by him.
It is worth noting that Regulation 6(1) only mentions 'normal hours of work'. It makes no
mention of hours of work engaged in on 'night work'. So, as long as during the reference
period a night worker does not exceed the average limit on 'normal hours' determined by the
formula in 6(5) there would appear to be no problem with him/her working more than 8 hours
on nightshifts. It seems a pointless formula to include, as basically a worker would have to
exceed the maximum average 48 hour weekly limit over the reference period before he was
in any danger of exceeding the night work limit.
It should also be noted that when Regulation 6(7) makes special provision for work that
"involves special hazards or heavy physical or mental strain" it does not say that that
work is only carried out at night. It says that if someone, who has been classed as a night
worker under the Regulations, undertakes work that has been recognised as involving special
hazards or heavy physical or mental strain (at any time of the day) then he should not work
for any more than 8 hours in any 24 hour period during which he is specifically performing
night work.
So, the question is NOT whether 'night work' in the police service involves special hazards or
heavy physical or mental strain. It is whether night workers in the police are undertaking
work which, when performed at any time of the day, involves special hazards or heavy
physical or mental strain. If they are, then their working hours should be restricted to eight
hours in any 24 hours during which they perform night work. There is a subtle difference!
26

27. In applying Regulation 6(8) to the Police service, it would appear that it is at the discretion of
each Chief Constable whether or not to agree, with his staff associations, that police duties
involve 'special hazards or heavy physical or mental strain'. The Home Office Manual on
Police Health and Safety, Volume Two, states that "By its very nature policing has always
been a hazardous occupation". To argue that this statement is an acknowledgement that
police work involves special hazards or heavy physical or mental strain is perhaps as equally
erroneous as to argue that it doesn't. Risk assessments are task specific and therefore, each
activity or duty needs to be properly assessed to determine the level of risk associated with it.
Volume Three of the Manual, A Guide on Risk Assessment (
www.homeoffice.gov.uk/docs/phsint.html ), is intended to assist police managers to conduct
risk assessments of various police activities. Generic risk assessments are provided as
templates only, and it is not sufficient for Force's to adopt them as their actual risk
assessments
POLICE FEDERATION
‘In conducting their own risk assessments, Forces may determine that some police activities
involve 'Medium' or 'High' risk. It has been accepted at ACPO level that where this is the
case, then that activity involves a 'significant risk'. Where such an activity is recognised as
involving 'significant risk' then by virtue of Regulation 6(8)(b) it is regarded as involving
'special hazards or heavy physical or mental strain', for the purposes of the Working Time
Regulations. Therefore such a risk assessment would determine whether or not those officers
who are classed as night workers and who carry out that activity, should work for any more
than 8 hours in any 24 hour period during which they perform night work. This would, in
turn, determine the type of shift pattern that is appropriate for those officers and, in particular,
the length of their night shift duty’.
‘It would be helpful, and perhaps appropriate and in spirit with the provisions of the Night
Work Recommendations and the EC Directive, for a national agreement to be reached
between the Official Side and Staff Side, as to which policing activities involve significant
risk and which do not, in order to promote uniformity in the application of this Regulation
within the Police Service’.
The determinant factors here are OPERATIONAL IMPERATIVES because one force does it
a certain way and saves some monies does not mean that it may be suitable for other forces
with different geographic and or demographic considerations.
Question: What is the difference between Jet-lag and Shift-lag?
Answer: Jet-lag is the transient sleep-related symptoms experienced when travelling across
different time zones, whereas shift-lag is the cumulative effect of persistent disruption to
circadian rhythms caused by working rotating shifts.
A recent study of Olympic gymnasts travelling across several time zones showed that even 11
days after flying they were still experiencing disruption to their blood pressure and heart rate
patterns, and changes in blood concentrations of the stress hormone cortisol and melatonin - a
hormone important for sleep - a fortnight afterwards. Remember that the next time you go
abroad !
27

28. Question: What is melatonin?
Answer: Melatonin is a hormone which is released by the pineal gland in the brain and is
thought to help regulate the circadian rhythms and the sleep wake cycle. Melatonin
production normally peaks during the night. Sunlight inhibits production.
Studies have shown that in permanent night shift workers the production of melatonin can be
so affected that it disrupts the body clock and causes sleeping problems. In such cases studies
have shown Melatonin taken in supplement form to be of benefit.
Those working rotating shifts, however, do not suffer the same disruption in melatonin
production and do not appear to benefit from this treatment.
Melatonin should never be taken without first consulting your doctor.
A break in the Fixed Roster System such as having a floating shift breaks the damaging
cycle of shifts.
Cost benefit Analysis Risk Assessments
There are two types of risk assessment matrices commonly used in carrying out more
complex assessments, i.e. shift working. These are referred to as qualitative and semi-
quantitative. The first uses qualitative measures of probability and consequences, the second
uses attributable risk as quantitative measure of probability, whilst using qualitative measures
of consequence.
There are two points to be considered.
 The Hazard assessment matrix which uses qualitative terms for probability, may be
more suited to ranking occupational health risks after carrying out site surveys.
 The Hazard assessment matrix which uses attributable risk as quantitative measure of
probability may a more useful tool to determine occupational health priorities from
existing epidemiological data.
Conceptualisation of risk
Care should be taken that the individual carrying out assessments maintains a high degree of
objectivity as studies have shown that biases and predisposition towards precautionary
measures is strongest where knowledge of risk is substantially accurate, perceived severity,
susceptibility and perceived benefits are high, and where the costs of compliance are low.
Also of relevance, and linked to the notion of vulnerability, is a widely reported bias relating
to the tendency of individuals to consider themselves personally immune or that their
personal opinions or beliefs are right. The apparent predisposition towards ‘unrealistic
optimism’ (Weinstein, 1980, 1984)
28

29. The following extract from a health and safety Executive Contract Research Report using
shift workers from Lothian and Borders Police Force as its study sample;
An intervention using a self-help guide to improve the coping behaviour of
nightshift workers and its evaluation Professor Zander Wedderburn PhD,
FBPsS David Rankin MA (Hons)
Background
There has been a multitude of research published on shiftworkers and the effects of
shiftworking, although little information exists for the lay person to have access to in
the UK. Guidelines or booklets containing information on techniques to combat the
effects of shiftwork across a range of lifestyle issues have been in existence for many
years (e.g. Community Health Network 1984; Monk 1988b; Monk, and Folkard 1992).
Although comprehensive and complete these guides are relatively few in numbers and
were not widely distributed (De Haan and Jansen, 1989).
Even though guidelines for shiftworkers have been available for some time, Tepas
(1993) states that he was unable to find a single objective study with suitable
experimental controls which demonstrates the effectiveness of educational booklets to
aid adjustment to shiftworking. A literature search fails to identify any studies that
examine the use of educational booklets, used alone as a pure measure of self-help in a
shiftworking population. Studies have been conducted examining educational
programmes that utilise coping strategies (e.g. Popkin, 1994; Smith-Coggins et al.,
1997), but none on the use of an educational booklet alone. The current study used
“The Shiftworkers’ Guide” (Wedderburn and King, 1996) in an intervention that seeks
to distribute information, collated from years of research, in the form of a self-help
booklet, in an attempt to educate shiftworkers in coping strategies to combat the
negative effects of shiftwork.
The study examines a sample of shiftworking police officers using data collected via
self-report survey questionnaires. All measures required problems to be self-reported
and objective measures (e.g. polysomnographic data) are unavailable. All measures are
collected from a sample of shiftworkers so no comparisons can be made with day
working controls.
At the end of a previous study of providing three counselling sessions for shiftworkers
to help them improve their health-oriented behaviours (Quinn et al. 1995), the company
asked for a booklet to be written, for the benefit of other employees who had not been
included in the study. This resulted in “The Shiftworkers’ Guide” by A.A.I.
Wedderburn and Catherine King, a short 22 page pamphlet, illustrated with company
photographs, and designed to fit easily in a pocket (8¼” x 4”).
Its contents essentially provide the mainstream distilled wisdom of researchers on
practical ideas for three-shiftworkers. After an introduction about biological rhythms,
there are sections on:
 Sleeping
 Eating
 Family life
 Social life
 Stress and anxiety, and
 Exercise.
29

30. There is also a brief diary included, to allow shiftworkers to keep a record of their sleep
duration and sleep difficulties, eating and drinking, so that they can work out for
themselves what is going wrong, and therefore what solutions they might be best to try.
The guide deliberately avoids more controversial areas, such as the use of bright light.
There is little doubt that bright light, applied at the trough of the main rhythms, can
speed up adaptation to night shift (Czeisler et al., 1986). It can achieve this even when
applied to the blood stream by light at the back of the knee. The practical problem is
that it has not yet been proved to be of use in the field: for example, the original study
required attention to the bright light for 5 minutes in every 10; and applying the light at
the wrong time can drive the rhythms in the opposite direction.
The potential usefulness of a guide like this depends on three arguments:
1. There is no publicly available guide like this for shiftworkers in the United
Kingdom.
2. There is evidence from several studies that many shiftworkers use patently bad
eating and sleeping practices.
3. A self-help guide like this might help them.
1.2 Variables that affect shiftwork tolerance
Many variables and stressors have been identified that possibly contribute toward
intolerance of shiftwork and subsequent negative health effects. Costa (1996) gives a
comprehensive list of factors which can impinge on an individual’s ability to adapt to
shiftwork (see Table 1.1). These factors have negative or positive effects on individual
tolerance to shiftwork according to different circumstances i.e. an individual’s need for
sleep can be dependent on different social/domestic factors such as number and age of
children.
Intolerance to shiftworking has been postulated to follow a developmental process that
exhibits four main phases: adaptation, sensitisation, accumulation and manifestation
(Haider et al., 1981).
1. ‘Adaptation’ during years 1-5 to shiftworking involves an individual beginning the
process of adapting to alterations in hours of work. Work life and social/domestic
circumstances are the main influences on health.
2. ‘Sensitisation’ (years 6-15) involves changing priorities. Individuals seek to
become more financially secure and obtain satisfaction at work (pay and
conditions) and at home (material gain).
3. Health is affected during ‘accumulation’ (years 20+) as ageing and exposure to
shiftworking become more salient. Risky behaviours such as poor diet and
smoking are related to health in this phase.
4. ‘Manifestation’ (years 40+) is the point when health effects are most obvious e.g.
gastrointestinal complaints may be at their highest.
This process of adjustment to shiftwork is postulated to proceed at different rates for
different individuals (Haider et al., 1981), and, when coupled with the large range of
factors seen in table 1.1, can produce a high level of inter-individual variation in
problem development (Costa, 1996).
3
Table 1.1 Factors influencing tolerance to shiftwork (from Costa, 1996).
A Individual Characteristics
- age
- sex
- health status
- length of shiftwork status
- phase in life cycle
30

31. - behavioural characteristics and personality traits (morningness – eveningness, introversion –
extraversion, neuroticism)
- eating and sleeping habits
- circadian structure
B Family Circumstances
- marital status
- number and age of children
- socio-economic level
- Consort’s (shift) work
- housing
- family attitudes
C Work Situation
- work sector
- work environment and work load
- job characteristics
- income level
- qualifications
- job satisfaction and career opportunities
- human relations
- canteen and medical facilities
D Shiftwork Schedule
- continuous, semicontinuous
- rotating or permanent
- length of the cycle
- number of consecutive nights
- number of nights per year
- direction and speed of rotation
- free weekends per cycle
- working hours
- hours of start and end of the shifts
- number of crews
E Socio-environmental conditions
- labour market
- local shiftwork traditions
- leisure activities
- social support
- community size and attitude
- commuting times and transport
4
1.3 Factors affecting adjustment to shiftworking
The diurnal pattern of most humans follows a circadian rhythm that revolves around
daylight hours and recurs every 24 hours. Most human functions (including behaviours
and biological processes) are regulated according to this 24-hour pattern.
Behaviourally these include the sleep-wake cycle, which usually follows a diurnal
pattern with sleep occurring at night, and working and taking leisure during the
day/evening hours. Biological functions are also regulated by circadian rhythms,
including deep body temperature, blood pressure and heart rate (Minors and
Waterhouse, 1990).
Most circadian rhythms reach their peak values during the daytime. A night shift worker
assumes a nocturnal environment, with work conducted at night and sleep/leisure taken
31

32. during the day/afternoon and/or evening. The displacement of time for shiftworkers
affects the sleep-wake cycle (Kleitman, 1963) and the functions of the gastrointestinal
system (Vener et al., 1989). These displacements are probably the largest factors that
can produce the objective and subjective health problems associated with working
shifts.
The relative intransigence of circadian rhythms to adjust to phase shifts in time has
important implications for the well-being of shiftworkers. Shiftworkers who work
nights and sleep during the day have many of their biological rhythms only beginning
to shift in phase after a few days and even then only very gradually. As rhythms adjust
slowly, shiftworkers who work night shift have diurnally orientated temperature
rhythms which are out of synchronisation with the sleep-wake cycle meaning that
temperature is rising as they attempt to sleep. With consecutive night shifts the
temperature rhythms begin to adjust but only very slowly. This has effects on fatigue
and alertness (Folkard et al., 1995) and also produces negative health effects, reduces
productivity and has implications for safety (Rosa, 1990).
There is also an increasing literature that demonstrates that shiftwork does have
generally detrimental effects for health in the long run (Costa, 1999). The most vivid
effects are on gastro-intestinal function, but there are also reports on increased risk of
heart disease. There is also a sizeable literature which shows that shiftwork can affect
mental health.
Lastly, in spite of a massive decline in traditional shiftworking industries, like coal,
steel and shipbuilding, there has been a rapid expansion of shiftwork in the service
sector, such as call centres. Shiftwork has not been abolished, and the problems it
creates for those who work it are still a challenge to researchers and managers.
1.4 Reviews of self-help literature
Shiftwork is a multifaceted problem that requires multifaceted solutions (Monk and
Folkard, 1992). A range of solutions have been advocated which include the following
recommendations taken from Costa (1999):
 Reduce shiftwork (especially night shift) as much as possible.
 Design the shift system according to ergonomic criteria (Knauth, 1993).
 Try countermeasures against sleep problems, problems with appetite and digestion,
social problems, deficits in training and education.
 Learn to adopt an adequate coping behaviour.
 Reduce negative working conditions e.g. night work plus noise or unfavourable
climatic conditions.
 Carry out regular medical surveillance and counselling.
 Improve laws e.g. The Working Time Directive.
 On-Shift strategies (bright light, napping).
 Selection strategies to remove the most vulnerable.
Solutions aimed at alleviating the problems experienced by shiftworkers have tended to
focus on one domain whereas there is no single solution to the problems encountered
(Monk and Folkard, 1992). Singular approaches aimed at providing solutions include
the use of napping (e.g. Bonnet, 1991), optimal shift systems (Knauth, 1993), exercise
regimes (Harma et al., 1988a; 1988b) or as part of a more widespread approach
targeting behavioural change through interventions such as counselling, educational
materials and educational programmes. Optimal solutions have been recommended to
include a range of measures described by Knauth above, bringing together managers
32

33. and employers in a more comprehensive systems based approach (Tepas and Monk,
1987).
A review of models of shiftwork and health by Taylor et al. (1997) identifies that
transactional models of shiftwork and health provide alternative interventions to aid
shiftworkers where responsibility for ill-health is transferred at least in part from shift
systems to the transaction between individuals and work schedules. This has lead to
the development of a wide range of coping strategies that aim to improve sleep, diet,
and social/domestic life behaviours (e.g. Monk, 1988a) delivered through educational
material using a variety of techniques such as self-help, counselling and educational
programmes.
Educational self-help booklets or material (e.g. audio tapes or audio-visual tapes) are a
widely distributed means of delivering information on a range of topics that aim to
produce a change in knowledge, attitudes and behaviours in the field of health
education. Self help materials are available for a range of problems including fear
reduction (Gould et al., 1990); smoking cessation (Glynn et al., 1990); insomnia
(Morawetz, 1989); and diet and exercise (Hagen, 1974, cited in Gould and Clum,
1993). These educational materials have been used to reduce the cost of treatment and
provide behavioural change services to many people who do not currently have access
to them (Morawetz, 1989).
The prevalence of health problems in shiftworking populations and the range of
diseases, which are at least partly attributable to shiftworking, suggest that some form
of widespread remedial action should be taken. There is no ideal shift system to relieve
all health-related complaints (Folkard, 1992) which has lead to the development of
interventions that deliver and enhance coping skills in shiftworkers. Educational
booklets are one method in which a range of behavioural coping strategies can be
delivered en masse to all current and prospective shiftworkers with the aim that these
coping strategies should lead to changes in behaviour and attitudes, easing adjustment
to shiftworking.
Educational booklets for shiftworking personnel have been in existence for over twenty
years, providing a variety of behavioural coping strategies that a worker can use to aid
adjustment to shiftwork. According to Tepas (1993) educational booklets used in
shiftworking populations first appeared in Sweden. Ostberg distributed an undated
pamphlet that is probably over 25 years old. Following this a range of books, booklets
and pamphlets have been produced by both academics and consultants (with some
overlap) which appear in the following chronological order:
 Community Health Network (1984) ‘Shiftwork: How to Cope’. This publication
used pictorial guides with easy-to-read text in sections devoted to sleep, eating and
stress/family matters.
 Campbell and Singer (1987) included a chapter on adaptation to shiftworking in a
book entitled ‘How to take care of yourself’.
 Corlett, Quinnec and Paoli (1988) ‘Adapting shiftwork arrangements’.
 Moore-Ede (1988) ‘The Clocks that Time Us’.
 Monk (1988b) ‘How to make shiftwork safe and productive’.
 Wallace (1991) ‘How to survive shiftwork’.
 Wedderburn (1991) edited an edition of BEST (Bulletin of European Shiftwork
 Topics, now known as Bulletin of European Studies of Time) comprising 86
guidelines for shiftworkers and management devised by six European researchers.
 Monk and Folkard, (1992) ‘Making Shiftwork Tolerable’.
33

34.  SynchroTech (1993) ‘The Shift worker’s Handbook’.
 Wedderburn and King (1996) ‘The Shiftworkers’ Guide’.
There are other pamphlets that the author is aware of that are not discussed here and a
huge range of information is also available for shiftworkers on the internet using the
World Wide Web. There are a prodigious number of websites devoted to shiftwork and
shiftwork problems and these have been devised by business, http://shiftworker.com/
and individuals, http://www.members.tripod.com/~shiftworker/effects.html
incorporating advice and links to other sites. The reader is referred to the current guide
(available from the authors) as an example of the nature of the content as the various
pieces of literature described cover much of the same ground in advising shiftworkers
of health changing behaviours through the dissemination of coping strategies.
As yet there are few interventions with suitable experimental controls which
demonstrate that any of these documents, used alone, promote adjustment to shiftwork
(Tepas, 1993). Two studies have been conducted that examine aspects of coping
strategies used in self-help materials for shiftworkers although neither of these
represents a systematic evaluation of a guide used alone to produce changes in health.
Koen and Lindsay (1986) conducted a very basic evaluation of a booklet using a
pre/post design on one group of shiftworkers (n = 49). The pre/post measures used
structured interviews before and one month after distribution of the guide. Findings
were minimal with 54% of workers saying their knowledge about the effects of
shiftwork had improved, whilst 70% reported they had learned something new from the
booklet. Changes in behaviour were reported by 51% of the sample although it was not
specified what amount of the population had changed behaviour in each particular area.
The major areas where change was reported occurred for sleep, eating habits, caffeine
and alcohol consumption.
Wedderburn (1991) edited the contributions of six European researchers to produce the
Bulletin of European Shiftwork Topics 3 (BEST 3) “Guidelines for Shiftworkers”.
This contained 86 separate guidelines for shiftworkers broken into six sections and
described as follows:
 14 rules for a good shift system.
 36 steps to try for good sleep on shiftwork.
 12 guidelines for eating on shiftwork.
 6 rules for physical fitness.
 11 rules for staying a happy social person.
 7 rules for managers and other top people.
The guidelines were compiled from a range of different research sources and although
some are contentious they were prepared in a manner that favoured one argument over
another. The provision of counter arguments and sources was given alongside each
strategy to allow shiftworkers and their managers to make informed choices
(Wedderburn, 1991). Wedderburn and Scholarios (1993) assessed 24 guidelines taken
from the BEST publication in a survey of mixed sex industrial 3 shiftworkers (n = 120)
from two different factories. The 24 personally oriented guidelines were extracted and
mixed with sixteen buffer items and put into a questionnaire that asked respondents to
‘Choose the answer which is closest to what you normally do’, with response
alternatives of ‘Yes’, ‘Sometimes’, ‘No’ and ‘Don’t Know’.
Six guidelines were found to be supported by a majority (‘Yes’ > 50% support) which
included advice to avoid sleeping pills; using a reliable alarm; planning time off;
avoiding alcohol before sleep; having a short sleep (2-4hrs) after last night shift; and
maintaining a comfortable temperature in the bedroom. Six guidelines were opposed
34

35. by a majority (‘No’ > 50% support) and twelve guidelines were neither supported nor
opposed by a majority (‘Yes’ < 50% > ‘No’).
Wedderburn argues that some of the guidelines may be viewed as extreme and this
could account for their rejection (e.g. ‘Use earplugs in bed’). Resistance to other
sleeping guidelines may have arisen because they were contingent upon a need for
silence. The requirement for other members of family to maintain silence may not
apply to all day sleeping shiftworkers. Resistance to eating guidelines varies and may
be due to differing effects of fatty foods, an unwillingness to interrupt sleep and
differential effects of caffeine on individuals. Wedderburn and Scholarios note that
resistance to the advice may imply that social pressures and immediate pleasures may
overcome an adherence to a strict routine of sleep hygiene.
Therefore although a range of booklets containing coping strategies exist there has been
no investigation into their effects upon health-related attitudes and behaviours.
Wedderburn and Scholarios conclude that the framework of the guidelines examined in
their study invite further self testing and recommend a formal evaluated attempt at
intervention to refine and determine their effects.
An evaluation into the effects of the large range of booklets and pamphlets in existence
for shiftworkers is necessary because no such study has previously been performed
(Penn and Bootzin, 1990; Tepas, 1993; Taylor et al., 1997). This lack of evaluation is
problematic as without examining guidelines as a form of intervention there is no basis
for refining and improving the strategies used to promote health behaviour. After
evaluating 24 guidelines taken from BEST 3, Wedderburn states that:
“Guidelines…invite self testing and experimentation, and it is appropriate to conclude
that this process, together with some more formal evaluations and interventions, will
one day result in better founded and more acceptable guidelines”. (Wedderburn and
Scholarios, 1993, p216).
These booklets provide and expose shiftworkers to health-relevant messages yet none
have been evaluated to determine their applicability and efficacy within a target
population of shiftworking personnel. This may represent a danger to those at whom
guides are aimed as individual differences may require that different coping strategies
be targeted at different people. The proliferation of booklets in existence also
represents a danger to research as Wedderburn says:
“There does seem to be a real need to carry out controlled intervention studies, to test
out guidelines thoroughly, because without this, one set of guidelines tends to echo
previous ones, with the danger that proposals come to be accepted by sheer repetition,
rather than by careful testing” (Wedderburn, 1993, p.242).
35

36.  Sensible risk management is about:
 Ensuring that workers and the public are properly protected
 Providing overall benefit to society by balancing benefits and risks, with a focus on
reducing real risks – both those which arise more often and those with serious
consequences
 Enabling innovation and learning not stifling them
 Ensuring that those who create risks manage them responsibly and understand that
failure to manage real risks responsibly is likely to lead to robust action
 Enabling individuals to understand that as well as the right to protection, they also
have to exercise responsibility
 Sensible risk management is not about:
 Creating a totally risk free society
 Generating useless paperwork mountains
 Scaring people by exaggerating or publicising trivial risks
 Stopping important recreational and learning activities for individuals where the risks
are managed
 Reducing protection of people from risks that cause real harm and suffering
The principles were launched by Bill Callaghan, Chair of the Health and Safety Commission in August
RISK MANAGEMENT
The principles of risk management apply equally to organisational risk management as they
do to safety risk management. The heuristic approach taken by management with regards to
the implementation of the Shift Roster Review proposals is just one of the fundamental flaws
identified in the process. There has been little or no interest shown by management as to the
health risks or compliance risks or the consequences of such risks being realised Fig 2, The
attendance issue cannot be ascribed to the current shift pattern without epidemiological
evidence, it may in fact be as a result of management’s inability to organise the shift pattern
or a combination of the ascribed risks mentioned.
There is no clear evidence to support management’s assertions that the proposed changes
will save the organisation the amounts claimed. Nor is there compelling evidence that the
poor work ethic is a consequence of the current shift pattern (No 8 ref 015). There seems to
be a less than high degree of understanding or conceptualisation of Risk, or of the
consequences of the Risks involved nor indeed the probabilities of the consequences being
realised and becoming issues or opportunities. Furthermore, the consequences that arise
may themselves present new Risks and likewise consequences.
Identifying current managerial issues and presenting them as potential risks is to miss the
point, and paves the way for the counter accusation that management are preoccupied with
a ‘blame culture’.
Risk management should not be seen simply as a management construct as would seem to
be the case, cherry picking the ascribed risks and ignoring other more fundamental risks, nor
should it be used as a platform from which to launch a wholly subjective and vitriolic diatribe.
The much vilified (by management) culture within the MGS, ‘the set of beliefs, norms,
attitudes, social and technical practices’ .are those by which the MGS has been managed
since its inception and has continued through the amalgamation.
If there is to be a culture change it is clear by managements own admissions that it must first
come from the top. Putting in place more of the same counterproductive bullying and de-
motivational practices reinforces the belief that the management suffer from ‘paradigm
36

37. blindness’ i.e. all the above. A cultural change needs to be built on trust and credibility with
the work force through communication and consultation. Then we can work towards
developing a coherent strategy that will deliver quality and reliability together as a team.
JSP 525 does not contain all the answers but it does give you the recipe.
 Aim, To ensure that risk management is consistently good across the Agency and
accords with best practice.
 Policy. The Agency’s policy is not risk avoidance but risk management.
 Aim of Risk Management. The aim of Agency risk management is to control threats
and to exploit opportunities.
 Attitude of Mind. To control threats and exploit opportunities requires an agility of
mind. To control threats, we need to be protective and cautious. To exploit
opportunities, we need to understand our intent, be looking for advantage, decisive
and quick. To do both, we need to be forward-looking, imaginative, well-informed and
ruthlessly realistic.
Risk; Risk is "A future uncertain event that could influence the achievement of objectives."
Risk can be threat or opportunity. ‘Threat’ is the threat of not achieving planned objectives.
‘Opportunity’ is the opportunity to achieve planned objectives or benefits earlier than planned
or to achieve unplanned benefits.
Likely areas of threat to achievement of objectives
a. lack of expertise in the area of risk;
b. ineffective quality control;
c. ill-defined responsibilities, tasks and work;
d. work in new or unfamiliar areas;
e. inaccurate or unrealistic, including over-optimistic, assessments or estimates;
f. insufficient resources of staff, time or funding.
Issue; whereas a risk is a potential problem, or opportunity that has not yet materialised, an
issue is an actual problem that has materialised. The better the risk management, the fewer
issues have to be dealt with.
Risk Owner; the risk owner is the person best placed to manage the risk, through their
responsibility, authority and resources. The risk owner should understand the effects of the
risk materialising for both the delivery, and for the benefits, of the work. The risk owner can
delegate the authority for assessment and mitigation to a risk manager, who may have more
expertise in that area of risk, but they cannot delegate the responsibility. Each risk is to have
a nominated ‘owner’.
Risk Assessment; Risk is assessed in terms of the likelihood of its occurrence and of its
impact, or consequences, if it occurs.
Mitigation Action; Mitigation action is measures taken to reduce the likelihood and impact
of a threat or to increase the likelihood and impact of an opportunity. There are 4 main ways
(‘The 4 T’s’) to mitigate a risk:
 Tolerate. ‘Can the risk be accept
 Terminate. ‘Can action be taken to avoid the risk being possible?’
 Transfer. ‘Can another person manage the risk better?’
 Treat. ‘Can action be taken to reduce (for a threat) or increase (for an opportunity)
the likelihood or impact of the risk occurring?’ For many risks, mitigation action will be
37

38. a combination of 2 or more of the 4 T’s. It may be possible to treat a risk to the point
where it can be either tolerated or better managed by another party.
Contingency Action; This is reserve measures in case mitigation action fails or will be too
late. The conditions to trigger contingency action should be defined. Contingency action is
usually a combination of additional funding, staff or timed?’
Fig.1 Extract from JSP525
IDENTIFY THE RISKS The consequence/impact ADDRESS THE RISK
Objective-driven: relate risks Control Measure(s);-
to the impact they will have on Consequences: political, Transfer: passing the risk on
the Agency’s outputs. financial, societal, operational, to someone else, usually
legal, environmental,
outside the Agency.
Risk: something that may have reputational.
an impact on the achievement
Tolerate: watch the risk to
of targets and objectives. It Risk rating: the classification
includes risk as an opportunity as of each risk, based on its ensure that its likelihood or
well as a threat. likelihood and potential impact. impact do not change.
Risk types: Uncertainty: some risks will Treat: plan a series of
compliance, have an uncertain impact and mitigation actions to bring the
external, likelihood. Seek help with risk down to an acceptable
financial, these to refine as much as level.
foresight, possible.
operation, Terminate: take quick,
project,
decisive action to remove the
reputation,
new ways of working, risk.
and strategic.
Countermeasures: the
Gathering intelligence: current measures you have in
through horizon scanning (forward- place to contain a risk at an
looking research identifying acceptable level or to reduce
tomorrow’s risks and getting better the threat.
prepared), surveillance and
An extract from FASLANE (Region 1) Risk Register Ref 015
stakeholders Contingency: an action or
arrangement that can be put
in place to minimise the
impact of a risk when it has
gone wrong.
The MGS are viewed as a problematic organisation with long outstanding cultural
issues, including;
1. low productivity,
2. a salary structure which does not reward the more competent and which does
not incentivise performance, promotion or rotation of staff,
3. high incidence of discipline and dismissal due to conduct of staff,
4. high frequency of grievances and claims of harassment,
5. incestuous relationships which prevent teamwork,
6. inadequate resources including poor organisational structure,
38

39. 7. poor staff performance,
8. poor work ethic due to shift pattern,
9. lack of responsibility and accountability,
10. high sick absence,
11. poor planning,
12. Unreliable management information and poor quality control.
13. The culture does not lend itself to efficiency or value for money. The
organisation is likely to be exposed to competition, judging also whether the
perceived cultural baggage should be transferred to the private sector.
Fig 2, Reducing unit costs by removing allowances and removing the floating shift may lead to;
IDENTIFY THE RISKS The consequence/impact ADDRESS THE RISK
:
1. Increased occupational health 1. Breaching European Court of
Risks of the new shift working Justice Ruling that Health,
pattern Safety and welfare should not
2. Risk of non compliance with be subordinated to financial
Working Time Regulations. considerations. Increased Stress
3. Risk of Industrial action related illness, Litigation, loss
4. Risk to Operations; de-motivation of reputation and costs
of staff increased risk of 2. Breach of Working Time
absenteeism Regulations by use of NST
5. Risk to Strategic operations by payments Increase working
reducing available resources hours, loss of Breaks and
greater reliance on OT non
: compliance breach litigation
loss of reputation and costs
: 3. De-motivation of staff affected
increased stress related illness
, increased absenteeism reduction
. of employee commitment,
failure to meet customer needs
security implications, breach of
health and safety at work act,
litigation, and costs
4. Reduction of available
manpower impact on customer
needs Reduction in quality of
service failure to meet
operational objectives
5. Reduction in training
opportunities failure to
meet strategic objectives
39

40. Summary
Backwards Steps!
At the time of writing it appears that the MGS are contemplating going back a Fixed shift
pattern! The reasoning behind this is that the Flexible Roster Allowance paid to workers is
perceived by Management as an unnecessary cost and giving officers too many rest days
compared with fixed shift pattern. This seems to be a retrograde step as management
campaigned for Variable Shift Arrangements in the first place! With not the slightest regards
on the impact this had on families. The Allowance being seen as a small but necessary
compensation for the disruption to family and social well being of the workers affected.
The proposal suggests that smaller units and establishments are being exempted and are
keeping the flexible roster allowance. Strange as the smaller units are closer in nature to the
commercial sector which operate fixed (site specific) rosters. Larger Units such as HMNB
Clyde are often asked to supply volunteers to fill short falls in manning at smaller
establishments Increases in Management, support staff and training are all pushing up unit
costs, justification for this it has been claimed is that reductions in operational grades mean
that there is no overall increase in cost. This is patently absurd; the cost, in particular to
operational grades is that CSO5 grades are being bullied into missing comfort breaks, meal
breaks and increased periods of lone working, all the traits associated with the worse
commercial security companies.
It is clear that there are no simple solutions to cost savings, in the case of the current
proposals it is evident that the small if any savings made are disproportionate to the damage
being inflicted on MGS Officers. Pay and conditions are not the only casualties the health
benefits gained from having a floating shift are being ignored on the altar of closing the gap.
Pay is a very emotive subject it can also be an effective way of undermining motivation, at
every level in the MGS. At a time when there are increased costs due to inflation a 4% cut in
pensionable pay is a very bitter pill to take and will indubitably cause stress and hardship to
already tight family budgets.
There is within the MoD and in particular the MGS a baffling range of Pay Scales,
allowances and a bonus scheme, that has been on and off for a number of years for no
apparent reason, other than management are failing to manage it.
In short there are no benefits to be gained by any of the Grades affected by the proposed shift
rostering. However there are many aspects of these changes that will have a negative impact
and manifest themselves over the coming years to the detriment of all.
The bottom line is that operational grades are being asked to take a pay cut and work more
weekends. The fear and anxiety amongst the operational grades is palpable. Caused by
uncertainties and a belief that the Testing of the new arrangements is a cover and plans are
well under way to role out the new rosters around the country.
Management should be aware that every pay packet sends a message,
– And employees are sensitive to its nuances. Quid pro quo
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41. 1. When the floating shift was introduced it had one major, albeit serendipitous consequence
in that it provides a recuperative period during the non flexible shift cycle. It has long been
understood by safety professionals that shift working is damaging to health and that there is
no simple solution to this problem, academic studies have shown that the ill health effects of
shift working are far greater than anticipated and there is a growing tendency towards a
more flexible approach when organising working time and shift patterns. The Health and
Safety Executive have announced that they will be introducing new guidelines in the near
future.
2. Notwithstanding the contractual obligations that the MoD has to its employees the New
Shift pattern if rolled out may have unforeseen consequences for the organisation. If not
prudently risk managed may expose the MoD to litigation;
The European Court of Justice (ECJ) referred to the definition in the Constitution of the
World Health Organisation (WHO), to which all the EU Member States belong, which
defines health as a state of complete physical, mental and social well-being that does not
consist only in the absence of illness or infirmity (United Kingdom of Great Britain and
Northern Ireland v Council of the European Union, Case C-84/94, [1996] ECR I-5755). "the
fifth recital in the preamble to Directive 93/104 states that the improvement of workers'
safety, hygiene and health at work is an objective which should not be subordinated to purely
economic considerations" (paragraph 44), a point repeated in the judgment of the Court
(paragraph 67).
Walker v Northumberland County Council [1995] IRLR 35 may also be relevant;
Stress, ‘Breach of its duty of care in failing to take reasonable steps to avoid exposing the
employee to a health endangering workload.’
Established the precedent that an employer can be held liable for mental injury to an
employee caused by work-related stress.
3. It can be clearly demonstrated that the proposed change in working patterns may impact on
the health and safety and welfare of the work force affected. It is incumbent on the
Management under the Management of Health and Safety at Work Regulations and The
Consultations with Employees Regulations to consult their employees on these matters and
to take due regards of their concerns.
I would strongly suggest that a moratorium be imposed and the status quo be maintained until such
time that a proper evaluation of the risks can be made by competent health and safety
professionals.
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42. 4. Given the MGS Management have reminded us that we now come under the Working Time
Regulations, how do they reconcile the advice that MGS Officers should retain part of their
annual leave allowance ‘for unforeseen circumstances’ when the WTR clearly states;
Reg 13 (9) Leave to which a worker is entitled under this regulation may be taken in
instalments, but -
(a) it may only be taken in the leave year in respect of which it is due, et al
5. The subject of NST was raised as an appropriate measure in the event that a CSO 5
was unable to be provided with a rest break i.a.w the WTR, NST in these
circumstances would have the effect of adding Measurable Time onto a shift and
would if added to a 12 hour shift take it over the limit for the maximum working day
and infringe the workers right to an 11 hour undisturbed daily rest period. As the DTI
are the lead organisation for policy and interpretation of the WTR can clarification be
sought?
6. Also on the subject of breaks are management aware that; The European Court of
Justice (ECJ) has ruled that DTI guidance on rest entitlement was incompatible with
the Working Time Directive specifically the text in italics.
Employers must make sure that workers can take their rest, but are not required to make sure
they do take their rest. In other words it is incumbent on management to ensure that breaks
are taken, furthermore JSP 375 specifically states that as a minimum a half hour break is
mandatory.
Has this been taken into consideration? As CSO5s at HMNB Clyde regularly miss meal break will
CSO5s be guaranteed 1.5 hours meal break i.a.w their terms and conditions?
7. An alternative and possibly more acceptable compromise may be possible; around 4%
saving can be achieved by reducing the supposed 1.5 hr meal break to 1 hr and
adjusting relieving margins and manning requirements as necessary. This would not
have the same damaging impact as the removal of the 4% shift allowance. And if
acceptable could be rolled out very quickly.
8. The Test Case Edweida Vs British Airways Plc has been cited as a president for a ‘lottery
draw’ as the fairest way to select employees that are to be moved to day working. At which
court was this case heard and who was the judge, as the only reference to a Edweida Vs BA
Plc is one in which a Ms Edweida failed in a her bit to wear a religious symbol on public view
whilst working as a baggage handler for BA.
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43. END
This is a Draft Copy
There are at present no Appendix, References or Index been added.
If you have any questions or queries regarding any of the contents please
do not hesitate to contact me. Also you are free to edit or add anything that
you think is necessary or that I have overlooked that will help your cause.
Jim
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