Published: 19/11/2025

Managing Fatigue in Aquatic Facilities: Translating the New Safe Work Australia Code of Practice into Practice

INTRODUCTION

Aquatic facilities across Australia commonly operate for long hours, often from early morning until late evening, seven days per week. During periods of hot weather, high patronage, programmed activities or staffing shortages, facilities often rely on staff to perform double shifts, split shifts or overtime to maintain safe operations. In regional and remote areas, where facilities may be staffed by only one or two people, extended working hours and reduced opportunities for rest can be even more likely.

In safety-critical roles, such as lifeguarding, technical operations and duty management, fatigue presents a significant risk. Fatigue diminishes alertness, concentration, decision-making and physical coordination — all essential to safe supervision, rapid emergency response and the effective operation of plant and equipment. Royal Life Saving Australia guidance, including content from the Lifeguarding Manual – 6th Edition and the Guidelines for Safe Pool Operations, recognises dehydration, fatigue and reduced concentration as factors that may compromise effective supervision and safe work practices.

Safe Work Australia’s new Managing the Risk of Fatigue at Work Model Code of Practice (2025) provides a legally enforceable yet practical framework for identifying, assessing and controlling fatigue risks at all Australian workplaces. This article interprets that guidance for aquatic facility contexts, outlining common fatigue-exposed tasks, relevant WHS expectations and practical strategies facilities may consider in order to meet their WHS duties.

THE LEGAL STATUS OF THE MODEL CODE OF PRACTICE

The Model Code of Practice provides Persons Controlling a Business or Undertaking (PCBUs) with practical guidance on how to meet WHS duties regarding fatigue management. Although Codes of Practice are not in and of themselves regulations:

• Courts may refer to the Code when determining what is reasonably practicable.
• WHS inspectors may draw upon the Code when shaping compliance expectations.
• PCBUs may adopt alternative approaches provided they achieve an equivalent or higher standard of risk control.

Aquatic facility operators may therefore treat the Code as an authoritative reference when designing their WHS management system and associated operational arrangements such as supervision planning, rostering, daily and weekly task assignments and maintenance activities.

UNDERSTANDING FATIGUE IN AQUATIC FACILITY CONTEXTS

Fatigue is defined by Safe Work Australia as a physical, mental or emotional impairment that reduces a worker’s ability to function safely. It may arise from:

• Work hours and scheduling, including long or inconsistent shifts, or hours of work between midnight and 6am
• Task demands, such as sustained vigilance or complex technical work
• Environmental factors, such as heat, humidity, noise or poor lighting

In aquatic settings, these factors commonly interact across lifeguarding, technical operations, customer service and supervisory roles.

FATIGUE RISKS ACROSS ROLES IN AQUATIC FACILITIES

1. Lifeguards and Supervision Roles

Lifeguards are required to maintain continuous vigilance, situational awareness and rapid response capability. Royal Life Saving Australia’s recommendations highlight the importance of hydration, rest, personal wellbeing and cognitive readiness for effective supervision.

Common fatigue risks may include:

• Reduced scanning effectiveness
• Slower recognition of patrons in difficulty
• Difficulty multitasking or maintaining situational awareness
• Increased fatigue during hot or humid periods

2. Chemical Handling and Dosing

Operational staff may be required to handle or dose chlorine, acids, CO₂ systems, or other pool chemicals. Fatigue can increase the risk of:

• Miscalculations in dosing
• Handling incompatible chemicals
• Overlooking signs of leaks, spills or alarm conditions
• Inconsistent application of PPE and safe work procedures

Possible controls may include:

• Scheduling chemical tasks so they are least likely to be impacted by fatigue considerations
• Two-person procedures during late shifts or hot weather
• Ensuring adequate plant-room ventilation and staff hydration
• Supervisory check-ins, daily toolbox meetings or sign-off for complex tasks during periods of high workload or fatigue risk

3. Water Treatment Plant Operations

Tasks commonly include: operating filtration and disinfection systems, conducting backwashes, troubleshooting mechanical alarms and managing contamination events.

Fatigue-exposed risks may include:

• Incorrect lock-out/tag-out sequences
• Missed signs of mechanical failure
• Slower recognition of abnormal pressures or flow patterns
• Increased slips, trips and strains in confined or hot plant rooms

Control measures may include:

• Adequate lighting for all plant areas
• Task rotation across operators
• Automation, sensors and alarms to reduce manual checking
• Limiting lone-worker exposure where practicable

4. Grounds and Mechanical Maintenance

Technical staff may undertake mowing, trimming, pressure cleaning, small repairs and equipment operation.

Fatigue-related risks may include:

• Coordination or grip issues when using power tools
• Heightened exposure to heat stress
• Procedural mistakes during maintenance tasks

Potential controls may include:

• Scheduling outdoor work during cooler parts of the day (or week)
• Reinforcing hydration practices
• Task rotation to manage workload
• Avoiding powered equipment at the end of extended shifts

5. Duty Managers and Operations Leaders

Duty Managers may be responsible for incident response, behaviour management, coordinating multiple work teams, overseeing plant and chemical alarms, and managing after-hours call-outs.

Fatigue risks may include:

• Reduced capacity to prioritise tasks
• Slower decision-making during emergencies
• Missed hazards during walkthroughs

Controls may include:

• Predictable roster cycles
• Uninterrupted break periods
• Additional supervisory support during high-demand periods
• Digital systems, such as drowning detection systems or automatic monitoring, to reduce cognitive load

6. After-Hours Call-Outs

After-hours work may include responding to alarms, pump failures or urgent maintenance issues.

Fatigue risks may include:

• Driving while fatigued
• Reduced cognition during night-time circadian lows
• Impaired troubleshooting during urgent plant issues

Possible controls:

• Rotating on-call and/or call-out duties
• Mandatory rest periods following night call-outs
• Remote monitoring tools to reduce unnecessary attendance

APPLYING THE CODE OF PRACTICE IN AQUATIC FACILITIES

It’s critical that owners and operators of aquatic facilities interpret and apply this code of practice to their operations.

To assist with this, Royal Life Saving Australia has previously developed an e-learning course on Fatigue Management, accessible here: Fatigue Management E-Learning

Further to the training module, below are listed some common hazards and some suggested activities or controls for consideration by owners and operators of aquatic facilities.

1. Identifying Fatigue Hazards

Facilities may consider reviewing:

• Rosters and break structures
• Heat-exposure environments
• Task profiles for supervision, chemicals and plant work
• Consultation feedback and incident trends

2. Assessing the Risks

Risk assessments may examine:

• Frequency and duration of fatigue exposures
• Consequences of fatigue-related errors
• Workers’ insights and experience

3. Controlling the Risks

Controls may include:

• Roster design
• 12 hours between shifts (including from other workplaces)
• No more than five consecutive days of work

Breaks

• At least 30 minutes every five hours
• Additional rest breaks during hot weather or peak periods
• Ensuring breaks are uninterrupted
• For lifeguards - ensuring more frequent supervision breaks, such as conducting pool tests or cleaning while another lifeguard qualified staff member provides coverage

Environmental and task controls

• Adequate lighting
• Hydration strategies
• Task rotation across high-demand duties

4. Reviewing and Improving

Facilities may periodically review:

• Incident and near-miss data
• Overtime and call-out patterns
• Seasonal fatigue risks
• Staff feedback

SUMMARY TABLE

CONCLUSION

Fatigue is a recognised WHS hazard that may affect lifeguards, technical operators, duty managers and maintenance staff. Aquatic facilities commonly experience operational pressures that can increase exposure to fatigue-related risks. By drawing on Safe Work Australia’s Code of Practice and Royal Life Saving Australia guidance, including content from the Lifeguarding Manual – 6th Edition and the Guidelines for Safe Pool Operations, facility operators may strengthen their approach to fatigue risk management.

Access the Code of Practice here:

Safe Work Australia Code of Practice - Managing Fatigue

Access the Lifeguard Manual here:

RLSSA Lifeguarding - 6th Edition

Access the module on Fatigue Management here:

E-learning Module on Fatigue Management

REFERENCES

• Royal Life Saving Society – Australia. (2025). Lifeguarding manual (6th ed.).
• Safe Work Australia. (2025). Managing the risk of fatigue at work: Model code of practice.
• Royal Life Saving Society – Australia (2025). Guidelines for Safe Pool Operations.