Establish which employees the regulations apply to, especially those who do not provide a 'continuous service' or are not directly involved in patient care.

Audit employees' hours and work patterns.

Check what needs to be done to comply with the regulations, such as identifying areas where collective agreements are required. Find out what is meant by 'working time', 'night time' 'night worker' and the reference period for calculating the 'average working week', the duration and terms of rest periods and how best to calculate holiday entitlement. The General Whitley Council is expected to have a draft agreement on these issues by the end of the month.

Develop a recording system.

Arrange health assessments for night staff.

Recording hours worked

The amount of record-keeping involved will be onerous. Employers are required to keep 'records which are adequate' in the case of each member of staff to whom they apply (including those who have agreed to work more than 48 hours), to show whether limits are being complied with. In particular,employers need to:

identify each worker who has opted out;

state the terms under which they agree that the restriction should not apply;

specify the number of hours worked by the worker during the reference period.

Records must be

kept for a period of

two years.