Safety & compliance Guide
Fatigue management on mine sites: the code of practice
Fatigue management on SA mines runs on a mandatory code of practice written to guideline DMR 16/3/2/4-B2. What it requires, roster risks, a checklist.
Contents 9 sections
On South African mines, fatigue is managed through a mandatory code of practice written to the Chief Inspector of Mines’ guideline DMR 16/3/2/4-B2 (Government Gazette 38339, 19 December 2014). Regulation 8.10.9 also requires a fatigue procedure for operators of trackless mobile machines. The guideline adds up fatigue from the roster, the work environment and personal factors, and asks each mine for a programme run by a committee and reviewed at least every two years.
What the law requires for fatigue management
Three instruments apply to a surface mine.
The mandatory code of practice. Section 9(2) of the Mine Health and Safety Act (MHSA) requires the employer to prepare and implement a code of practice when the Chief Inspector of Mines requires it. Section 9(3) says it “must comply with guidelines issued by the Chief Inspector of Mines”. The fatigue guideline was issued as Government Notice R. 1025 (GG 38339, 19 Dec 2014, read 25 Sep 2026). Its title block gives reference DMR 16/3/2/4-B2, last revised 28 July 2014, effective 30 November 2014. The guideline is blunt: “Failure by the employer to prepare or implement a COP in compliance with this guideline is a breach of the MHSA” (guideline text, MHSC copy, read 25 Sep 2026).
Regulation 8.10.9. Under the trackless mobile machinery regulations, the employer must take reasonably practicable measures so that persons are not injured “as a result of fatigue of operators. Such measures must include a fatigue management procedure for operators” (MHSC consolidated regulations, read 25 Sep 2026). The regulations define a trackless mobile machine as any self-propelled machine used for mining, transport or associated operations at a mine, so on an open pit this covers haul trucks, loaders, dozers, graders and light vehicles. The trackless mobile machines guideline adds that the mine’s code must describe, per machine type, “safety devices to negate unexpected incapacitation of the operator or fatigue management procedures” (DMR 16/3/2/2-B2, clause 8.11.1, read 25 Sep 2026).
Road transport. The road and rail safety management guideline DMPR 16/3/2/2-B4, effective 1 October 2025, covers vehicles “owned by a mine or … contracted to a mine” that carry employees, and the transport of minerals to and from the mine. The mine’s code must include “a fatigue management awareness programme” with “measures to encourage rest periods amongst the drivers” and places of rest along the routes (GG 52814, 6 Jun 2025, read 25 Sep 2026).
The guideline “covers all employees at a mine”, and the Act defines an employee as “any person who is employed or working at a mine”. Contractor staff are inside the mine’s fatigue code from their first shift.
How the guideline defines fatigue
The guideline defines fatigue as “reduced mental and physical functioning caused by sleep deprivation and/or being awake during normal sleep hours”. It splits the causes into three groups and adds them up.
FT = FSS + FEW + FPF
- FT: total fatigue
- FSS: fatigue caused by the shift system and work time arrangements
- FEW: fatigue caused by poor ergonomics, environmental and work factors
- FPF: fatigue caused by personal factors such as insufficient or poor sleep, health, nutrition and lifestyle
The equation is a way of thinking, with no units. Its point for a contractor is that a good roster does not cancel out a two-hour bus ride or a hot, noisy cab.
The guideline calls fatigue management “a responsibility that must be shared between employer and employee”. It also puts one duty on the worker. “It is the responsibility of employees to inform the employers of any health condition or medication they are on.”
Fatigue risk factors in a roster
Annexure A and Table 1.1 of the guideline list the roster features that raise fatigue risk. They are written as risk factors and questions for the mine’s risk assessment, and they set no hard limit.
| Factor | What the guideline flags |
|---|---|
| Consecutive nights | “More than four consecutive 12-hour night shifts”; “more than five consecutive 8-hour night shifts” |
| Sleep opportunity | Rosters that do not allow “continuous sleep of seven to eight hours in each 24-hour period” |
| Recovery after nights | “Less than 36 hours off after a period of night shift work” |
| Start times | “Early morning shift start times (before 6:00)”; shifts that start or finish between midnight and 06:00 |
| Rotation | “Backward rotating rosters (day to night to afternoon)”; irregular or unpredictable patterns |
| Shift length | One shift of more than 12 hours in a day including call-outs; the guideline adds that long hours “includes travel time, especially to remote sites” |
| Weekly hours | Active work, including overtime, above “50 hours in any seven days” |
| Gap between shifts | A break shorter than 10 hours |
| Task on long shifts | 12-hour shifts with “critical monitoring tasks, heavy physical work” or exposure to harmful substances |
Two more factors matter on open pits. Table 1.2 names “repetitive or monotonous work, e.g. haul truck driving”, along with heat, noise and whole-body vibration. Table 1.3 asks whether “significant travel to and from work” cuts into sleep, and whether “long-distance commutes” are needed at the start of a work cycle. The guideline also points investigators to “the latter half of shifts and night work, particularly between 2:00 and 6:00”. The MHSC’s 2024 worker guide lists “commuting fatigue” beside extended hours and shift work as a cause of injury risk (MHSC, Sleep Well, Work Well, read 25 Sep 2026).
What a fatigue management programme includes
The guideline sets out seven elements for a fatigue management programme. They run from senior management commitment and a fatigue management committee, through policy and the management of fatigue itself, to communication, education, and monitoring and review.
The committee. The mine “should establish a Fatigue Management Committee (FMC)”, with action plans tracked at its meetings. The body that oversees the programme should be a cross section of managers and union representatives, preferably health and safety representatives.
The policy. It sets goals, roles and accountabilities, and “policies regarding employee alertness and fatigue, including possible disciplinary action for failure to maintain satisfactory levels of alertness on the job”.
The five steps. Hazard identification, risk assessment, risk control, monitoring and evaluation, and a documented plan. Hazard identification uses rosters, worker consultation, audits and incident reports.
The controls. The guideline applies the hierarchy of controls, so its first option is to remove the cause, “for example, the elimination of night shifts and extended working hours”. Its other options include roster changes “using the Bio-roster concept” that “shall have the support of employees”, longer breaks within a shift, and better lighting and ventilation. It also lists night-shift meals designed “to reduce drowsiness” and performance monitoring for safety-critical workers. For contractors, the key item is “regular medical examination and certification of fitness of employees and contractors in safety critical positions”.
The plan. It must be specific to the site, developed through consultation, on display, and repeated in inductions and safety talks. The guideline also asks for “opportunities for family members to be included”.
Review. At least every two years. Suggested leading indicators include “the number of individuals who self-report fatigue when at work” and people treated for sleep disorders. Outcome measures include near misses, equipment damage and absenteeism.
The Inspectorate is watching this area. In its 2024/2025 annual report, the North West (Rustenburg) region lists “Enforce fatigue management” and “Monitoring working hours and annual leave” among its strategies (MHSI Annual Report 2024/2025, read 25 Sep 2026).
Shift roster design basics
Check a proposed roster against the flags before it goes to the mine’s committee. The example below shows how the commute changes the answer.
Fatigue detection technology
The guideline asks for “suitable systems to monitor the performance of workers in safety-critical positions (e.g. drivers and operators) during the course of the shift and, where appropriate, suitable technology to monitor performance during the shift”. It does not name, rank or require any particular technology. The trackless mobile machines guideline asks for devices “to negate unexpected incapacitation of the operator” or fatigue procedures.
The guideline’s text points to two moments for checks:
- At shift start. Its hazard worksheet lists unchecked fitness for duty as a warning sign, “especially the amount of sleep someone has had before starting a shift”.
- During the shift. Performance monitoring of drivers and operators, with technology “where appropriate”.
Pay Dirt has not tested fatigue monitoring products and makes no claim about how well any of them work. Monitoring sits alongside the roster and the committee in the guideline’s list of controls. Before any system goes onto a contractor’s machines, agree in writing who receives each alert and what the operator and supervisor must do when it fires. Agree too how false alarms are logged and who may see the recordings of your people.
Checklist: a contractor’s fatigue arrangements on a mine
Common questions
Is a fatigue management code of practice mandatory on South African mines?
Yes. The Chief Inspector of Mines issued guideline DMR 16/3/2/4-B2 in Government Gazette 38339 of 19 December 2014. Under section 9(2) and 9(3) of the Mine Health and Safety Act, the employer must prepare and implement a code of practice that complies with it. The guideline states that failing to do so is a breach of the Act.
Does the law set a maximum shift length on mines?
The fatigue guideline sets no hard maximum. It lists roster features for the mine’s risk assessment to consider, such as more than four consecutive 12-hour night shifts and starts before 06:00. Others are fewer than 36 hours off after a run of nights and more than 50 hours of active work in any seven days. Hours of work and overtime are also governed by employment law, which this article does not cover.
Do the mine’s fatigue rules apply to contractors?
Yes. The guideline covers all employees at a mine, and the Act defines an employee as any person employed or working at a mine, which includes a contractor’s staff. The guideline also names contractors in safety-critical positions when it calls for regular medical examination and certification of fitness.
Sources
- Government Gazette 38339, No. R. 1025, 19 Dec 2014, Department of Mineral Resources, read 25 Sep 2026.
- Guideline for the compilation of a mandatory code of practice for risk-based fatigue management at mines, DMR 16/3/2/4-B2, Mine Health and Safety Council copy, read 25 Sep 2026.
- Mine Health and Safety Act 29 of 1996 and Regulations, consolidated booklet, Mine Health and Safety Council, printed 2018, read 25 Sep 2026.
- Guideline for a mandatory code of practice for trackless mobile machines, DMR 16/3/2/2-B2, GG 39228, Department of Mineral Resources, 25 Sep 2015, read 25 Sep 2026.
- Guideline for a mandatory code of practice for road and rail safety management, DMPR 16/3/2/2-B4, GG 52814, Department of Mineral and Petroleum Resources, 6 Jun 2025, read 25 Sep 2026.
- Sleep Well, Work Well: A guide to fatigue management at work, Mine Health and Safety Council, December 2024, read 25 Sep 2026.
- Mine Health and Safety Inspectorate Annual Report 2024/2025, Department of Mineral and Petroleum Resources, read 25 Sep 2026.
