Indicator 3.9.3

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Indicator 3.9.3

by Contact on 8 October 2026

Requirement

Indicator applicability: any person aged 18 and above. The UoC shall ensure that working hours do not exceed 8 hours per day and 48 hours in a week (excluding overtime). An exception applies where the operations of the UoC require a different working pattern, in which case the UoC may use averaging of working hours if permitted by applicable legal requirements, calculated over a maximum 17-week reference period. When more than 48 hours are worked in a week as a result of averaging, the UoC shall ensure that the following conditions are met: a. it is in line with applicable legal requirements; and b. it is in line with collective bargaining agreements; and c. terms are clearly set out and agreed to by employees in their contracts; and d. appropriate safeguards are put in place to protect the employee’s health and safety. **

How Do I Interpret This Requirement?

  •  The normal workday is a maximum of 8 hours, excluding breaks, and the normal work week is a maximum of 48 hours.

  • Where collective bargaining agreements, industry standards or national law require a shorter day or week, this applies.

  • The ILO defines shift work as: ‘a method of organisation of working time in which workers succeed one another at the workplace so that the establishment can operate longer than the hours of work of individual workers at different daily and night hours’.

  • Where collective bargaining and national law allows, the UoC can employ people to work in shifts:

    • They may choose to work more than eight hours per day and more than 48 hours in one week, if the number of hours averaged over a period of 17 weeks does not exceed a normal workday and normal work week.

    • Long working hours can mean that employees can get fatigued, which can result in accidents or mistakes.

    • The UoC should recognise that employees could be working two jobs which, whilst outside the scope of the ASC Farm Standard, is still a risk to their health and safety, and consideration should be given to fatigue caused by excessive working hours.

  • Appropriate safeguards in place to protect employees’ health and safety can include:

    • a risk assessment looking specifically at the risk of fatigue

    • adequate or extra rest breaks and places for employees to rest during long shifts

    • enough food and drink available for employees to ensure that they are not hungry

    • avoiding employees who have worked long hours of overtime conducting hazardous work (for example, operating heavy machinery)

    • ensuring that dark areas are well lit

    • ensuring that, where possible, employees are not working alone for long hours.

Evidence of Implementation

  • employee contracts

  • payslips

  • working hours records

  • health and safety risk assessment.

Auditors Should Confirm

  • any different shift patterns have been entered into voluntarily by employees;

  • the UoC understands the risk inherent in long working hours and fatigue and appropriate mitigations are being implemented.