Are you managing Fatigue as Part of your EASA Part 145 SMS?SasSofia

July 27, 2022

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EASA Part 145 Fatigue Management Considerations
Addressing Fatigue within an EASA Part 145 Production Planning Environment

Sofema Aviation Services (SAS) considers the challenge of fatigue management within an Aircraft Maintenance Organisation (AMO).

EASA Part 145 SMS – Fatigue Risk Management System

The purpose of the Fatigue Risk Management System (FRMS) is to promote a reduction, as far as practicably reasonable, workplace fatigue and its associated risks, to ensure a safe and error-free work environment for employees, contractors, and clients.
FRMS should ideally be a component of your SMS Part 145, commitment from senior and line management together with clear consultation and effective communication with all employees should be ensured to provide a positive safety culture.
An essential obligation affecting all parties is the recognition of the shared responsibility between the Organisation and the individual employee, together with the need for effective oversight by the regulatory authority.

145.A.47 Production Planning

AMC1 145.A.47(b) Production planning (consideration of fatigue in the planning of maintenance).

(a) The way and the extent to which the organisation should consider the threat of fatigue in the planning of tasks and organizing of shifts will vary from one organisation to another and from one maintenance event to another, depending on what maintenance is to be carried out, how, where, when and by whom.

(b) Fatigue is one example of human factors issues which should be taken into account by the management system, particularly for the planning activity. In this respect, where the organisation activity is prone to fatigue issues, the organisation should:

(1) ensure that the safety policy required by point 145.A.200(a) gives due consideration to the aspects of fatigue;
(2) ensure that the internal safety reporting scheme required by point 145.A.202 enables the collection of fatigue issues;
(3) ensure that the threat of fatigue is adequately taken into account by the management system’s key processes (e.g. assessment, management, monitoring);
(4) provide safety promotion material and adapt safety training accordingly.

The resulting shift schedule should be shared with the maintenance staff sufficiently in advance so they can plan adequate rest.
The established shift durations should not be exceeded merely for management convenience even when staff is willing to work extended hours.

(d) The organisation should have a procedure (including mitigations) to address cases where the working hours are to be significantly increased, or when the shift pattern is to be significantly modified, such as for urgent operational reasons. In cases not covered by that procedure, the organisation should perform a specific risk assessment and define additional mitigation actions, as applicable.

Basic mitigations may include:

(1) additional supervision and independent inspection;
(2) limitation of maintenance tasks to non-critical tasks;
(3) use of additional rest breaks.

GM1 145.A.47(b) (Production planning consideration of fatigue in the planning of maintenance).

(a) Fatigue may be induced by:

(i) the environment and conditions (e.g. noise, humidity, temperature, closed section, working overhead) in which the work is carried out;
(ii) excessive hours of duty and shift working, particularly with multiple shift periods or patterns, additional overtime, or night work;
(iii) travel to the maintenance location (e.g. jetlag, duration) Fatigue is one of the factors that may contribute towards maintenance errors when it is not properly considered as part of planning activities.

(b) Taking into account the threat of fatigue in the planning of maintenance tasks and organising of shifts refers to setting up the maintenance and the shifts in a way that enables the maintenance staff to remain sufficiently free from fatigue so they can perform the planned maintenance safely, including:

Providing rest periods of sufficient time to overcome the effects of the previous shift and to be rested by the start of the following shift;
Avoiding shift patterns that cause a serious disruption of an established sleep/work pattern, such as alternating day/night duties;
Planning recurrent extended rest periods and notifying staff sufficiently in advance.

(c) As part of the management system, the planning of maintenance tasks, and the organising of shifts, shall take into account human performance limitations, including the risk of fatigue for maintenance personnel.

(d) When it is required to hand over the continuation or completion of maintenance tasks for reasons of a shift or personnel changeover, the relevant information shall be adequately communicated between the outgoing and the incoming personnel.

(e) The organisation shall ensure that any aviation safety hazards associated with external working teams carrying out maintenance at the organisation’s facility are considered by the organisation’s management system.

Limitations of Human Performance

In the context of planning safety-related tasks, refers to the upper and lower limits, and variations, of certain aspects of human performance (Circadian rhythm/24 hours body cycle) which personnel should be aware of when planning work and shifts.

With regard to fatigue, there are three primary factors that are relevant:

The amount of proper sleep
The amount of time awake
The time of day where work is performed

Fatigue is also impacted by high workloads (mental and/or physical activity) and by the physical and mental health of the staff concerned.

Type of Fatigue Background & Understanding

The term fatigue can refer to several different types, please consider the following:

a) Physical fatigue (examples include – muscular, lack of oxygen, lack of sleep, illness, and poor nutrition)
b) Mental fatigue (examples include – any activity associated with tasks requiring intense concentration, analysis, and process of complex data/information)
c) Emotional fatigue (examples include – working under constant pressure, and undergoing continuous critics)

It is often difficult to determine which of the different types of fatigue are active – when we believe we have a fatigue-related issue.

Identifying Fatigue-Related Signs

It is useful and easier to consider the indicators for some classical fatigue-related signs.

Often the fatigue is subjective and is not practically quantifiable. With the assessment being made based on the visible effects. The classical symptoms of fatigue are:

a) Lack of awareness
b) Diminished movement capacity
c) Diminished vision
d) Slow reactions
e) Short-term memory problems
f) Too limited concentration losing an overview of the situation
g) Easily distracted by different things
h) Increased mistakes
i) Poor judgement
j) Inadequate decisions or no decision at all
k) Abnormal moods

One of the prevailing factors playing a role in fatigue is related to working hours and shift working. Noticeable is an increase of the risk of errors in the case of shifts with long working hours and night shifts knowing that these risks increase significantly when these types of the shift are aggregated.

Optimising Working Hours/Shift Work Within the Organisation

The main points required to minimise the effects of the fatigue of the personnel working in the shift are as follows:

a) Avoid excessive shift working periods
b) Anticipate enough amount of night’s sleep
c) Minimise sleep loss
d) Give the opportunity for extended rest when night sleep has been disrupted
e) Take into account reduced physical and mental capacity at night
f) Take into account individual situations
g) Provide enough support/help to the technicians outside administrative periods
h) Give the opportunity for recovery
i) Overall minimisation of night shifts
j) Provide longer rest periods after night shifts
k) Launch the most complex tasks generally during the day
l) Ensure that appropriate checks are made after night shifts
m) Avoid repetitive tasks over a long period or anticipate intermediary breaks
n) Studies enabled to draw great principles, which can be used to implement an organisation of work taking into account human performance and limitations
o) To follow the hierarchy of standards, the maintenance organisation must reconcile the requirement related to labour regulations with Human factors related principles and their operational requirements

Next Steps

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Note – Sofema Aviation Services offers the following EASA SMS Part 145 training in support of the understanding regarding development of an effective Fatigue Risk Management System (FRMS):

For additional questions or to register please email team@sassofia.com