Indicator 3.9.4

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Indicator 3.9.4

by Contact on 8 October 2026

Requirement

The UoC shall ensure that overtime hours are; a. are voluntary; and b. are not requested regularly; and c. have appropriate safeguards in place to protect the employee’s health and safety.

How Do I Interpret This Requirement?

  • Overtime should not occur regularly but under exceptional circumstances, for example, overtime can be requested:

    • for unexpected peak production times

    • if staff are absent and others must cover their work.

    • The UoC should plan work in such a way to minimise the risk of regularly requesting overtime.

  • If the UoC continues to need the same jobs done in overtime repeatedly, this is an indication that the UoC may need to:

    • review resources

    • plan work differently

    • hire additional employees.

  • Any overtime is voluntary, meaning it can only take place if the employee:

    • consents to work extra hours

    • is not discriminated against or penalised for refusing overtime.

  • Health and safety hazards related to excessive overtime can be avoided by implementing a clear overtime policy that:

    • limits excessive overtime

    • ensures that overtime requirements are announced in advance when possible

    • ensures that overtime is voluntary

    • rotates schedules so that overtime is not always assigned to the same employees

    • ensures that health and safety training shows how to recognise and manage signs of fatigue and stress.

    • The UoC should allow regular rest breaks during overtime shifts.

    • The UoC can maintain open and transparent communication channels with employees to encourage them to provide feedback about their work conditions and overtime hours, and use this input to adjust schedules.

  • 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

  • health and safety risk assessment

  • contracts

  • working hours records.

Auditors Should Confirm

  • employees understand that overtime hours are voluntary;

  • management understand the risks in working long hours and are well prepared to mitigate those risks;

  • regular activities are carried out in regular working hours and that overtime is used for exceptional circumstances.