Fatigue isn’t new on farms. Everyone knows what it looks like when people are running on big days, big weeks and not enough sleep. You feel it in the cab, you see it in small mistakes and you hear it in shorter tempers. It’s part of why agriculture is a high-risk industry.

And when regulators start talking about new Codes of Practice, plenty of people roll their eyes because it can feel like more red tape from outside the industry telling you how to run your business. That reaction is understandable.

What’s shifting now isn’t the idea that fatigue is dangerous — it’s the expectation around it. Regulators are treating fatigue like any other hazard, which means if something goes wrong, you may be asked a simple question: can you show what you did to manage it?

NSW has adopted a new Code of Practice: Managing fatigue at work, effective 1 July 2026. In real terms, this means SafeWork will expect business owners and managers to be able to demonstrate how fatigue is being identified and managed — not just “we look after our people”.

A Code of Practice doesn’t replace the WHS Act, but it sets a clear benchmark for what SafeWork considers “reasonably practicable”. If you don’t use the Code as your guide, you’ll need to be able to show SafeWork what you do instead — and that it manages fatigue at least as well as the Code does.

Fatigue is also broader than most people think. It can be:

• physical (your body is spent)
• mental (reduced focus, slower decisions)
• emotional (irritable, stressed, running on empty)

And it directly impacts alertness and decision-making around vehicles, machinery and higher-risk tasks.

Three practical tools you can apply now:

Identify your fatigue risk triggers
On cotton operations, common triggers include:

• long shifts and multiple big days in a row
• short turnarounds between shifts (late finish, early start)
• heat, dehydration and poor nutrition
• long drives, including driving home late at night
• workers asked to operate equipment or vehicles without enough support or supervision
• new or international seasonal workers where English isn’t their first language (higher risk if instructions aren’t clearly understood)
• distraction and reduced attention, including mobile phone use around machinery and vehicles
• monotonous work (hours in a cab) reducing alertness

If these are present, fatigue is present — whether people call it that or not.

Put simple controls in place
Practical controls that work on farm include:

• setting maximum shift lengths during peak periods (even a rule of thumb)
• non-negotiable breaks and a team culture that backs them in
• adequate time between shifts, especially after long days
• rotating higher-risk tasks (road runs, night driving, maintenance work)
• clear supervision for new workers and anyone doing unfamiliar tasks
• simple inductions and check-backs (“show me how you’ll do it”) to confirm understanding
• expectations around phone use near vehicles and machinery — and enforcing them
• water accessible in vehicles and proper meals, not just snacks and caffeine
• clear “stop rules” — if someone isn’t safe to operate, they stop, no questions asked

Just as important is giving people permission to speak up early. You want a workplace where someone can say, “I’m buggered” without being laughed off or labelled as weak. If people don’t feel safe to call it out, they’ll push through — and that’s when mistakes and incidents happen.

Document the basics so you can prove it
From 1 July, this is the part that matters. It doesn’t need to be paperwork overload, but you do need evidence. Keep it simple:

• start and finish times (basic timesheets or shift notes)
• breaks taken
• any fatigue call-outs and what you did about it (swap drivers, pause work, reschedule)
• a short toolbox note during peak periods confirming expectations around breaks and speaking up

A question worth asking is this: if there was a serious incident tomorrow, could you show the steps you took to manage fatigue in the lead-up?

If you’re outside NSW, this still matters. Codes and guidance differ by state, but fatigue expectations are tightening everywhere. 

WHS Support

Full Cotton Australia levy payers are entitled to a Free On-Farm Safety Review with Ingham & Co (travel costs apply). Get in touch here