If I could, I'll phrase that slightly differently. They would need to take this into account in their safety management system. They would need to take it into account in their work/rest rules scheduling. They would have to look at any risks created by how they address that issue, and then they would have to look at how they mitigate those risks. It's a matter of taking those principles and turning them into specifics, which is a bit complex, but you're generally correct.
On April 23rd, 2015. See this statement in context.