With the introduction of ICAO obligations and additional regulatory requirements to deal effectively with the challenge of Fatigue we should acknowledge the fact that the obligation sits on multiple shoulders.
Whilst clearly the regulator sets out the initial requirements and in the case of EASA this may be found in EASA ORO.FTL.120 Fatigue Risk Management (FRM)
In accordance with EASA ORO.FTL.120 (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 Fatigue Risk Management System (FRMS) 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.
Different approaches may be found in different organisations however the overriding obligation is to ensure that collectively we are able to deliver an Effective fatigue management system.
An essential obligation affecting all parties is the recognition of the shared responsibility between the Service Provider (The operator – Airline or Air Carrier) and the individual employee, together with the need for effective oversight by the regulatory authority.
Every organisation is different and there are different aspects which will affect in some way or influence how the organisation interacts with the employees and how the individuals take responsibility for their own particular role and deliver in a meaningful way their fatigue management obligations or responsibilities.
The Operator must be able to demonstrate to the State (typically through the medium of audit) how the program operates and how effective is the actual delivery of what is essentially a shared responsibility undertaking.
The State is responsible for providing:
A regulatory framework that enables adequate fatigue management and ensures that the Service Provider is managing their fatigue related risks to achieve an acceptable level of safety performance.
Note that as FRMS is a performance based system the regulators should be competent in delivering performance audits.
The Operator is responsible for providing:
Sufficient Manpower and resources to ensure the system can operate correctly (this is a scalable endeavour and is dependent on the size of the organisation);
An environment that is both conducive to delivery of an effective FRMS and is able to provide the appropriate management capacity to ensure the correct oversight and ability to develop appropriate mitigations where required;
Effective and robust fatigue reporting mechanisms;
Sufficient evidence of appropriate responses to fatigue reports; schedules that enable fatigue on duty to be maintained at an acceptable level, as well as providing adequate opportunities for rest and sleep; and
The organisation is also responsible to ensure appropriate training for all stakeholders.
The training should provide information on how the organization’s fatigue management system works in the organisation and to identify the role of the individuals to better manage their own fatigue.
Finally Individuals also have a very important role to play !
They are responsible for “playing fair” by making sure they receive adequate sleep;
By being fit for duty when they present themselves for work
By managing their own fatigue levels so they do not pose a threat to themselves
By self reporting in the event they identify Fatigue Issues
And finally by appropriate use of discretionary measure for example related to Pilot in Command (PIC) discretionary powers.
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
