Appendix 2 FIGURE 2-1. MIDSIZE AND LARGE AIR CARRIERS NOTE: The FSAG should consist of members from management, flight operations, and dispatch or flight following, as applicable. Advisors are assigned to provide the FSAG with input on their area of responsibility to shape the overall FRMS. Additionally, the FSAG will communicate specifics regarding the FRMS to the advisors, as it relates to the advisor’s area of responsibility.
Appendix 2 FIGURE 2-2. SMALL AIR CARRIERS.
Appendix 2 SECTION 3. FATIGUE RISK MANAGEMENT SYSTEM PROMOTION PROCESSES
1. INTRODUCTION TO FRMS PROMOTION PROCESSES. This section outlines the FRMS promotion processes, which includes training programs, a communication plan, and the links between the FRMS promotion processes and other FRMS components. Along with the FRMS policy and documentation, the FRMS promotion processes support the core operational activities of the FRMS.
a. Training. An Education and Awareness Training program, as prescribed in part 117, § 117.7(b)(2), is a required element of the certificate holder’s FRMS. The objective of the certificate holder’s FRMS Education and Awareness Training program is to ensure that all involved personnel are trained and competent to undertake their responsibilities relevant to the certificate holder’s FRMS. In addition to the FRMS training program, the training completion standards for both initial and recurrent training should be specified in the FRMS documentation.
The certificate holder must maintain FRMS training records in accordance with 14 CFR part 121, § 121.683. The FRMS training program should emphasize the key principles of fatigue science, management of sleep, and understanding the effects of the circadian body clock to illustrate the relevancy not only to individual’s roles in the FRMS but also to their lives outside of work. Thus, FRMS training covers issues that everyone can identify with personally and promotes the concept of shared responsibility in an FRMS.
b. Communication. An FRMS relies on effective communication throughout the certificate holder’s organization. On the one hand, there needs to be regular communication about the activities and safety performance of the FRMS to all stakeholders. Depending on the structure of the organization, this may come from the FSAG or an accountable executive responsible for the FRMS communication plan. On the other hand, crewmembers and other stakeholders need to communicate promptly and clearly about fatigue hazards to the FSAG or other relevant management.
2. FRMS PROMOTION PROCESSES. FRMS promotion processes support the ongoing development of the FRMS and the continuous improvement of its overall performance for maintaining optimum safety levels. The following shall be established and implemented by the certificate holder as part of its FRMS:
a. Training Programs. Training programs to ensure competency commensurate with the roles and responsibilities of management, flight and cabin crew, and all other involved personnel under the planned FRMS; and
b. Communication Plan. An effective FRMS communication plan that:
(1) Explains FRMS policies, procedures, and responsibilities to all relevant stakeholders;
and
(2) Describes communication channels used to gather and disseminate FRMS-related information.
3. FRMS EDUCATION AND AWARENESS TRAINING PROGRAMS. In addition to the above requirements, the current edition of ICAO Annex 6, Part I, Appendix 7 requires that a
Appendix 2 certificate holder maintain documentation that describes and records FRMS training programs, training requirements, and attendance records. It further recommends that regulators have competency requirements for FRMS training instructors, who may be part of a certificate holder’s internal training department or external contractors.
4. WHO NEEDS TO BE TRAINED? For an FRMS to be effective, all personnel who contribute to FRMS safety performance need to have appropriate training. The FRMS training audience should include the executive accountable for the FRMS, crewmembers, crew schedulers, dispatchers, persons holding operational control, individuals responsible for management oversight of these areas, all members of the FSAG, and personnel involved in overall operational risk assessment and resource allocation.
5. FRMS TRAINING PROGRAM. The content of training programs should be adapted according to the knowledge and skills required for each group to play their part effectively in the FRMS. All groups require basic education about the dynamics of sleep loss and recovery, the effects of the daily cycle of the circadian body clock, the influence of workload, and the ways in which these factors interact with operational demands to produce fatigue. In addition, it is useful for all groups to have information on how to manage their personal fatigue and sleep issues.
Schedulers and dispatchers should have a comprehensive understanding in the use and limitations of any scheduling tools and biomathematical models or other algorithms that may be used to predict the levels of crewmember fatigue across schedules and rosters.
a. Curriculum. The FRMS training curriculum should provide a full understanding of all FRMS components and elements: policy and documentation; processes for hazard identification, risk assessment, mitigation, and monitoring; SA processes for monitoring FRMS performance, managing change, and continuously improving the FRMS; and FRMS promotion processes, including training and communication. The training should provide a robust understanding of how scheduling affects sleep opportunities and interacts with the circadian biological clock cycle, the fatigue risk that this creates, and how it can be mitigated through scheduling. The training should provide an in-depth understanding of the certificate holder’s flightcrew member FRMS operating procedures. Lastly, the training program should highlight the processes and procedures for implementing scheduling changes recommended by the FSAG.
b. Outline. The following is an outline of subjects that may be incorporated into the FRMS training curriculum:
(1) Overview of the FRMS Concept.
(a) Definition.
(b) Purpose.
(c) An overview of the FRMS structure and how it works in the certificate holder’s organization, including the concepts of shared responsibility and an effective reporting culture.
(d) FRMS SA metrics used by the organization.
(e) FRMS regulatory requirements.
Appendix 2
(f) FRMS structural components.
(g) The role of the FSAG.
(h) The current edition of Advisory Circular (AC) 120-100, Basics of Aviation Fatigue.
(2) Fatigue Mitigation and Managing Rest.
(a) An overall understanding of crewmember fatigue and the safety risk that it represents to the organization.
(b) Basic environmental factors that lead to fatigue.
(c) General strategies to maintain alertness and recover from sleep loss.
(d) Causes and consequences of fatigue in the operation(s).
(e) Signs of fatigue.
(f) The importance of accurate fatigue data (both subjective and objective).
(g) Personal strategies that they can use to improve their sleep at home and to minimize their own fatigue risk while on duty.
(h) Basic information on sleep disorders and their treatment.
(3) Tools for an Effective FRMS.
(a) Fatigue assessment and analysis methods.
(b) Identification and management of aviation fatigue drivers.
(c) Fatigue mitigation approaches.
(d) Positive safety culture.
(4) Components of an FRMS.
(a) FRM policies.
(b) Education and awareness training.
(c) Fatigue analysis and reporting system.
(d) Fatigue monitoring methods.
(e) Fatigue-related incident reporting process.
Appendix 2
(f) FRMS performance evaluation.
(g) Continuous improvement process.
(5) FRMS Roles and Responsibilities.
(a) Certificate holder.
(b) Crewmember/employee.
(c) Schedulers/dispatchers.
(d) Operational control personnel.
(e) Management personnel.
(f) FSAG.
(g) Other stakeholders.
(h) FAA responsibilities.
(6) FRMS Implementation.
(a) Policies and procedures.
(b) Organization and personnel.
1. FSAG.
2. Relationships to other safety personnel.
(c) Tools and methods.
(d) Training and awareness.
(7) Safe Scheduling Policies and Procedures.
(a) Proactive and adaptive fatigue mitigation.
(b) Work schedule oversight and monitoring.
(c) Crew augmentation.
(d) Circumstances beyond the control of the certificate holder.
(8) Records and Reports.
(a) Schedule accuracy.
Appendix 2
(b) Reports of fatigue by flightcrew members.
(c) Fatigue-related events.
(d) How reports of fatigue and other related data are processed.
(e) Records of the activities of the FSAG and resulting interventions.
(9) FRMS Implementation Policies and Procedures.
(a) Organizational policies and procedures that establish the FRMS.
(b) Flightcrew member operating procedures related to FRMS.
(10) Continuous Performance Improvement Process.
(a) FRMS performance evaluation.
(b) Work schedule modeling and fatigue risk analysis.
(c) Management and mitigation of fatigue risk.
(d) Assessment, feedback and corrective action.
(e) Reporting intervals.
6. DELIVERY OF FRMS TRAINING. There is a variety of ways in which FRMS training can be delivered, each of which has strengths and limitations. Live training sessions with a trained instructor have the advantage that crewmembers can ask questions about their specific issues or concerns and can learn from each other’s experiences. Face-to-face contact with different stakeholders in the FRMS can facilitate building the safety culture. However, live training requires coordinating a time and place that groups of participants can attend, and involves time getting to and from the venue, in addition to the time required for the actual training session.
a. Alternative Methods. Web-based learning and distributed training (for example, using DVDs) allow greater flexibility in the time and place that training occurs. Individualized training allows participants to proceed at their own pace through the training materials. In Web-based learning, sessions can be networked so that multiple participants can join in with a tutor online.
Material can also be made interactive (a task has to be completed, e.g., a short quiz must be answered, before the participant can move on to the next part of the training).
b. Alternative Materials. Providing different materials and formats for recurrent training can help to maintain interest. For example, recent fatigue reports or FSAG interventions can be used as case studies to illustrate and revise concepts covered in the initial training material.
Recurrent training can also cover changes to the operations or the FRMS and scientific and regulatory updates. The frequency and nature of recurrent training needs to be decided by the
Appendix 2 FSAG, in consultation with professional trainers (internal or external to the certificate holder) as needed.
7. TRAINING FREQUENCY. The FRMS training program must contain an initial and recurrent curriculum. The frequency of the recurrent FRMS training is every 12 calendar-months.
8. FRMS TRAINING EVALUATION. The effectiveness of FRMS training and education programs should be periodically evaluated. Examples of evaluation tools can include the following.
a. Quizzes. To evaluate immediate knowledge transfer from a training session, participants can be given a short quiz assessing fatigue knowledge, to be completed before and after the training session.
b. Surveys. To evaluate the amount of knowledge retained, crewmembers’ use of suggested countermeasure strategies, and perceived usefulness of training, a survey can be conducted at a fixed time (e.g., 6 months) after training.
c. Feedback and Improvement. Findings from the quizzes and surveys can be used to:
(1) Revise the content of the training package, to improve the training on topics that a significant proportion of crewmembers have not fully understood;
(2) Provide feedback to trainers on areas where they may need to change or improve their teaching approaches; and
(3) Identify areas that need to be reviewed or added in recurrent training.
9. FRMS TRAINING DOCUMENTATION. The current edition of ICAO Annex 6, Part I, Appendix 7 requires that a certificate holder keep documentation that describes and records FRMS training programs, training requirements, and attendance records.
10. FRMS COMMUNICATIONS PLAN. The current edition of ICAO Annex 6, Part I, Appendix 7 requires a certificate holder to have an FRMS communication plan that explains FRMS policies, procedures and responsibilities to all stakeholders; and describes communication channels used to gather and disseminate FRMS-related information.
a. Communication. The FRMS training programs are clearly an important part of the communication plan. Since training intervals are annual, ongoing communication to stakeholders is required. Various media channels may be used to report the activities and safety performance of the FRMS, to sustain interest in fatigue-related matters, and to encourage the continuing commitment of all stakeholders to the FRMS processes. A variety of types of communication can be used, including electronic media (websites, online forums, email), newsletters, bulletins, seminars, periodic poster campaigns in strategic locations, and the like.
b. Content. Communications about the activities and safety performance of the FRMS (from the FSAG or other designated management) need to be clear, timely and credible
Appendix 2
(i.e., consistent with the facts and with previous statements). The information provided also needs to be tailored to the needs and roles of different stakeholder groups, so that people are provided information that is relevant, practical, and concise.
c. Crewmember Feedback. Communications from crewmembers are vital for fatigue hazard identification, for feedback on the effectiveness of controls and mitigations, and in providing information for FRMS safety performance indicators (e.g., by participating in surveys and fatigue-monitoring studies). For these communications to be open and honest, all FRMS stakeholders need to have a clear understanding of the policies governing data confidentiality and the ethical use of information provided by crewmembers. There also must be clarity about the thresholds that separate nonculpable fatigue-related safety events from deliberate violations that could result in penalties. Timely feedback to crewmembers who submit fatigue reports is vital. Feedback does not require completion of a full investigation. Every crewmember should receive a timely response to their report with some indication of the planned follow-up activity, such as: “This report has been forwarded to the Fatigue Safety Action Group, which is currently investigating an adverse trend in fatigue reports associated with this trip and is evaluating a number of potential mitigation strategies.”
d. Documentation and Assessment. The communication plan needs to be described in the FRMS documentation and assessed periodically as part of FRMS SA processes. The communications plan explains FRMS policies, procedures and responsibilities to all stakeholders, and providing timely information on FRMS-related activities, trends, corrective actions, pairing and scheduling policy changes, and fatigue management tips for crewmembers.
Appendix 2 SECTION 4. DATA COLLECTION
1. DATA COLLECTION SOURCES. Data collection is a fundamental element for determining the effectiveness of an FRMS. Data collection and analysis is not a task undertaken once in the life cycle of an FRMS; rather, it is one of the certificate holder’s day-to-day functions. Data collection provides the certificate holder with an understanding of the suspected areas that contribute to fatigue. It is essential for the certificate holder to gather enough data and information to be confident that they can identify the likely fatigue hazards in their operations. It is instrumental in achieving the objective that the certificate holder must have a good understanding of the operational factors that are likely to cause crewmember fatigue.
a. Prioritization. Because fatigue-related impairment affects many skills and has multiple causes, there is no single measurement that gives a total picture of a crewmember’s current fatigue level or the factors that might cause fatigue. To decide which types of data to collect, the most important thing to consider is the expected level of fatigue risk. It is not a good use of limited resources to undertake intensive data collection with multiple measures on a route where the fatigue-related risk is expected to be minimal. Therefore, resources should be targeted towards operations where the risk is expected to be highest.
b. Efficiency. A balance needs to be maintained between gathering enough data for the certificate holder to be confident about its decisions and actions and the additional demands and cost of the data collection and analysis. Data analysis should provide the certificate holder with an idea of the appropriate mitigations and controls necessary for managing the risk. All measures require resources (financial and personnel) for data collection and analysis. Limited resources need to be used effectively to identify fatigue hazards where controls and mitigations are most needed.
c. Sample Sources. A sampling of the following data collection sources might be useful and should be considered by the certificate holder:
(1) Crew Reporting.
• Reports of sickness.
• Crews calling in fatigued.
• Crews filing fatigue reports.
(2) The Company.
• Flat or peaking flying program on monthly and seasonal basis.
• Category of airfields or seasonality of airfield use.
• Single- or multi-flightcrew member operations.
• Market sector.
• Aircraft operated.
Appendix 2
(3) Scheduling.
• Schedule stability (especially changes of plus or minus 2 hours, unplanned night stops, time between schedule change, and new/revised duty).
• Scheduling buffers.
• Use of reserves flightcrew members.
• Block hours.
• Duty hours.
• Extensions of flight duty periods (FDP).
• Extension of flight times.
(4) Days Off.
• Number of days off.
• Days off spread through the schedule.
• Frequency of single day off usage.
• Leave (how many days taken and how long since last leave period).
(5) The Duties.
• Duty transitions.
• Working the Window of Circadian Low (WOCL) (early, late, night duties, scheduled and actual).
• Rest between duties.
• Number of segments per day (scheduled and actual).
• Long/extended duty days (including extended duties due to positioning or 14 CFR part 91 operations).
• Length of FDPs.
• Number of consecutive duty days.
• Augmented and unaugmented flightcrew operations.
• Time zone crossings: frequency and direction.
• Augmented crew routes.
• Length of layovers.
• Rest facilities on the aircraft: class of rest facility.
• Travel time between airport and hotel and the return trip.
• Waiting time for transport (hotel pickups).
(6) Contingency Plans.
• Delayed report usage.
• Reserve assignments.
• Time between reserve call and show time.
• Working on days off.
• Delays during the FDP.
Appendix 2
(7) Scheduled vs. Actual.
• Task analysis of the duty days.
• Operational issues.
(8) Reportable/Measurable Data.
• Fatigue incident reports.
• Aviation Safety Reporting Systems (ASRS).
• Aviation Safety Action Program (ASAP) reports.
• Biomathematical computer modeling: fatigue modeling.
• Modeling of pairings, assignments, and actual FDPs and flight times.
(9) Internal Actions.
• FSAG meeting minutes.
• Fatigue survey.
• Fatigue report data.
• Internal incident/accident reports.
• External reports, studies, reviews, and accident/incident reports.
(10) Planned Data Collections.
• Sleep data.
• Cognitive performance data.
• Flight performance data.
• Scheduling data.
(11) Other Data Sources.
• Hazard reporting and investigations.
• Operational data related to fatigue.
• Audits and surveys.
• Reviews and fatigue studies.
2. FATIGUE REPORT. A fatigue reporting system is an integral component of the FRMS, as it supports the evaluation of the air carrier’s FRMS and provides data points from fatigue-related occurrences. However, to be effective, the fatigue reporting policy must be based upon open communications encouraging employees to report fatigue-related occurrences without fear of reprisal. Voluntary disclosure has proven to be an excellent vehicle for conveying safety information to those individuals having the authority to effect and change policy. The air carrier’s fatigue reporting system should support this concept. In return, the air carrier is afforded the opportunity to collect valuable safety information and effect changes in policies, as appropriate, and continue to build upon their safety culture. Figure 2-3, Sample Fatigue Report, is a sample fatigue report providing multiple data points. This sample report may be incorporated as one of the certificate holder’s data collection sources.