Fatigue may be considered as a “hidden enemy” with the potential to impact the effectiveness of our operations, at best it impairs performance at worst it could be a precursor to a serious event or worse!
What do we mean when we say move from a compliance based system to a performance based system?
Step 1 must be to have a common agreed understanding and to de-mystify the terminology we are using.
So when we talk about a Compliance Based System we are essentially talking about a prescriptive “rules based” environment. Whereas when we talk about a Performance Based System we are (on a continuous basis) measuring not only any perceived exposures but also to measure the effectiveness of what we are doing. ‘Pivotal in this process is the need to establish “indicators” also known as Key Performance Indicators KPI’s.
What does the Fatigue Risk Management System “need to do”?
To be able to assess potential exposures to Fatigue Risk, to assess and develop mitigations (this is considered proactive behaviour) means to act based on assessment of exposure rather than after an event.
Any Challenges ?
Sure there are always challenges!
Cultural issues within the organisation and perceptions of management objectives versus the “worker” reality.
The ability to gather and process data related to FRMS exposures
The ability as part of the Flight Operations Audit system to “independently” audit the effectiveness of the FRMS
The Regulations Require
FAA Code of Federal Regulations CFR 14-117.7 Fatigue risk management system requires the following:-
(a) No certificate holder may exceed any provision of this part unless approved by the FAA under a Fatigue Risk Management System that provides at least an equivalent level of safety against fatigue-related accidents or incidents as the other provisions of this part.
(b) The Fatigue Risk Management System must include:
(1) A fatigue risk management policy.
(2) An education and awareness training program.
(3) A fatigue reporting system.
(4) A system for monitoring flightcrew fatigue.
(5) An incident reporting process.
(6) A performance evaluation.
EASA ORO.FTL.120 Fatigue Risk Management (FRM)
(a) When FRM is required by this Subpart or an applicable certification specification, the operator shall establish, implement and maintain a FRM as an integral part of its management system. The FRM shall ensure compliance with the essential requirements in points 7.f, 7.g and 8.f of Annex IV to Regulation (EC) No. 216/2008.
The FRM shall be described in the operations manual.
(b) The FRM established, implemented and maintained shall provide for continuous improvement to the overall performance of the FRM and shall include:
(1) a description of the philosophy and principles of the operator with regard to FRM, referred to as the FRM policy;
(2) documentation of the FRM processes, including a process for making personnel aware of their responsibilities and the procedure for amending this documentation;
(3) scientific principles and knowledge;
(4) a hazard identification and risk assessment process that allows managing the operational risk(s) of the operator arising from crew member fatigue on a continuous basis;
(5) a risk mitigation process that provides for remedial actions to be implemented promptly, which are necessary to effectively mitigate the operator’s risk(s) arising from crew member fatigue and for continuous monitoring and regular assessment of the mitigation of fatigue risks achieved by such actions;
(6) FRM safety assurance processes;
(7) FRM promotion processes.
(c) The FRM shall correspond to the flight time specification scheme, the size of the operator and the nature and complexity of its activities, taking into account the hazards and associated risks inherent in those activities and the applicable flight time specification scheme.
(d) The operator shall take mitigating actions when the FRM safety assurance process shows that the required safety performance is not maintained.
Sofema Aviation Services offers Aviation Fatigue Risk Management Training. For details please see here. For additional information please see www.sassofia.com or email: office@sassofia.com
