Appendix 2 FIGURE 2-3. SAMPLE FATIGUE REPORT SAMPLE FATIGUE REPORT Answer A Fatigue Occurrence 1 In the previous 12 calendar-months, how many times have you experienced fatigue and reported the occurrence?
2 When the fatigue event occurred, how many consecutive days had you been on duty?
3 In the days leading up to this fatigue occurrence, how many segments had you flown during each duty day within the previous 72-hour period?
4 Were you rescheduled for duty during the previous 72-hour period?
(Yes or No)
5 Prior to this notification, how long has it been since you were on duty or operating as a flightcrew member?
6 In the days leading up to this fatigue occurrence, how many hours had you flown during each duty day within the previous 72-hour period?
7 In the days leading up to this fatigue occurrence, how many duty hours had you worked during each duty day within the previous 72-hour period?
8 Were you performing any other duties for the air carrier on any day within the previous 72-hour period? (Yes or No.) If Yes, answer the following question.
9 If you were performing other duties, what was the total time worked each day performing those duties?
B Commuter 1 Are you a commuter? (Yes or No.) If No, indicate so and move to the next section.
2 What form of transportation was used for your commute?
3 How long is your commute?
4 What was that total time from the time you left your home to start your commute until the time you reported for duty?
5 How much time elapsed between the time you arrived at your domicile and your report time?
6 Did you receive any additional rest at your domicile prior to reporting for duty?
If so, how much?
Appendix 2 C Reserve Pilot Assignment 1 During the previous 72-hour period, were you assigned as a reserve pilot?
(Yes or No.) If No, indicate so and move to the next section.
2 Do you regularly hold a reserve line? (Yes or No) 3 How many hours had your flown during the previous 24-hour period?
4 How many hours had you been on duty during the previous 24-hour period?
5 How many hours had your flown during the previous 72-hour period?
6 How many hours had you been on duty during the previous 72-hour period?
7 How many days had you been on duty during the previous 30 days?
8 How many hours had your flown in the previous 30 days?
9 When was the last period that you had been assigned at least 24 hours free from all duty?
D Operational Issues 1 Did you experience any operational or maintenance delays within the previous 72-hour period? If so, please provide details.
2 How many rest periods did you have in the previous 72-hour period leading up to the fatigue occurrence?
3 Did you have the opportunity to get additional rest between flights? If so, what was the quality of that rest?
4 During the previous 72-hour period, did your duty period involve consecutive night duty or continuous duty overnights? (Yes or No)
5 If you answered “Yes” to question D4, how many consecutive nights of duty did you perform consecutively?
6 If you answered “Yes” to question D4, how many continuous duty overnights did you perform consecutively leading up to the fatigue occurrence?
E Augmented Crew 1 During the 72-hour period leading up to the fatigue occurrence, did you serve as an operating crewmember in an augmented crew? (Yes or No.) If you answered No, move to the next section.
2 Within the previous 24 hours, how many hours did you operate as an augmented crew?
Appendix 2 3 Within the previous 72 hours, how many hours did you operate as an augmented crew?
4 What classification of onboard rest facility did you use for in-flight rest?
(Class 1, 2, or 3)
5 What would you estimate was the quality of rest you received during the previous 24-hour period? (Good, Fair, or Poor)
6 What would you estimate was the quality of rest you received during the previous 72-hour period? (Good, Fair, or Poor)
7 What was the length of your duty period within the previous 24-hour period?
8 How many hours had you spent on flight duty periods (FDP) during the previous 72-hour period?
9 Did you perform as an operating crewmember during the landing phase? If so, were you the flying pilot or the monitoring pilot?
10 During the previous 72-hour period, had you served in a two-pilot crew?
(Yes or No.) If Yes, please provide details regarding the length of FDP, number of segments flown in a two-pilot configuration, and the timeframe in which this occurred during the previous 72-hour period.
F Hotel/Suitable Accommodation 1 Within the previous 72-hour period, what type of suitable accommodation did you use? (Hotel or at Home)
2 If you rested at home, were there conditions that interrupted your sleep?
(Yes or No.) If Yes, how many interruptions?
3 Were the hotels you stayed in regular hotels used by your carrier? (Yes or No) 4 Were your hotel rooms located close to the elevator, ice machine, or high traffic area?
5 Did you experience environmental issues interrupting your ability to sleep such as social events occurring in the hotel, vehicular traffic, or air traffic?
(Yes or No.) If Yes, please explain.
6 Did you experience noise from hotel construction or remodeling that interrupted your ability to sleep during your rest period? (Yes or No)
G Rest (During the 72-hour period leading up to the fatigue occurrence) 1 What was the difference (in time) between your scheduled rest periods and your actual rest periods?
Appendix 2 2 How long (in time) was your sleep opportunity during your scheduled rest periods?
H Sleep Opportunities 1 Within the 24-hour period leading up to the fatigue occurrence, how many hours did you sleep?
2 Within the 48-hour period leading up to the fatigue occurrence, how many hours did you sleep?
3 Within the 72-hour period leading up to the fatigue occurrence, how many hours did you sleep?
I Circadian Issues 1 Within the previous 72-hour period, did any part of your duty period fall within the window of circadian low (WOCL)? (Yes or No.) If Yes, please elaborate.
2 How many time zones had you flown through within the previous 24-hour period?
3 How many time zones had you crossed within the previous 72-hour period?
4 Within the previous 72-hour period, had you operated through the nighttime hours (Between 0200 and 0559)? (Yes or No.) If Yes, please explain.
J Nutrition and Hydration 1 During the 24-hour period leading up to the fatigue occurrence, what was the quality of your meals? (Good, Fair, or Poor)
2 During the 72-hour period leading up to the fatigue occurrence, did you have the opportunity to eat properly? (Yes or No)
3 During the 24-hour period leading up to the fatigue occurrence, have you experience dehydration? (Yes or No)
4 During the 72-hour period leading up to the fatigue occurrence, did you have the opportunity to properly hydrate yourself? (Yes or No)
K Personal Factors 1 Are you currently experiencing any personal issues that may have contributed to your fatigue occurrence? (Yes or No)
Appendix 2 L Pre-Duty Activities 1 Within the 24-hour period leading up to the fatigue occurrence, were you engaged in any pre-duty activities? (Yes or No.) If Yes, please explain.
2 Within the 72-hour period leading up to the fatigue occurrence, were you engaged in any pre-duty activities? (Yes or No.) If Yes, please explain.
Remarks Section Question # Comments
Appendix 2 SECTION 5. FATIGUE RISK MANAGEMENT PROCESSES
1. SETTING UP FRM PROCESSES. This section describes the basic steps for setting up and applying FRM processes. FRM processes within an FRMS are specifically designed to manage the risks related to crewmember fatigue. Figure 2-4, Fatigue Risk Management Processes, illustrates these processes.
FIGURE 2-4. FATIGUE RISK MANAGEMENT PROCESSES
1. Identify operations where FRMS will be applied
2. Collect and Analyze Data
3. Identify Hazards
4. Assess Safety Risks
5.1 Select and Implement Controls and Mitigations
5.2 Set Safety Performance Indicators
5.3 Flighterew FRMS Operations Procedure Development
6. Monitor Effectiveness of Mitigations Page 24
Appendix 2
a. Processes. FRM processes are one part of the day-to-day operations of the FRMS. They are designed to enable the certificate holder to achieve the safety objectives defined in its FRMS policy, and are managed by the FSAG. The basic FRM processes are:
(1) Identify where fatigue is a hazard;
(2) Assess the level of risk that a given fatigue hazard represents; and
(3) If necessary, put in place controls and mitigation strategies, and monitor them to make sure that they manage the risk to an acceptable level.
b. Data Analysis. To be effective at managing risks, FRM processes require data input from a number of sources, including measurements of the crewmembers’ fatigue levels and measurement of operational performance. The key is choosing the right combination of measurements applicable to each operation covered by the FRMS. However, just collecting data is not enough. The data must be analyzed for data output that will be used by the FSAG and others accountable for FRM processes so that informed decisions can be made relative to the FRMS safety performance.
2. FRM PROCESSES OUTLINE. The following outlines the FRM processes:
a. Process 1.0: Identify Operation(s) to which FRMS Processes will be Applied. It is important that the certificate holder clearly identify the operations where the FRMS will be applied. Different types of flight operations can involve different causes of crewmember fatigue and may require different controls and strategies to mitigate the associated risks. Within its FRMS, a certificate holder may need to develop multiple sets of different FRM processes for different operations. These should be clearly identifiable.
b. Process 2.0: Collect and Analyze Data. The FRMS must provide an AMOC and demonstrate that it meets or exceeds the limitations (safety standards) prescribed in part 117. To demonstrate an AMOC of the FRMS, the certificate holder must, prior to FAA approval, define measurements of fatigue that will serve as performance safety standards for the evaluation of the effectiveness of the FRMS.
(1) Measurements Summary. An AMOC demonstration of effectiveness of the FRMS will require a combination of measurements.
• Subjective fatigue and sleepiness ratings,
• Objective performance measurements,
• Sleep monitoring and measurement, and
• Circadian rhythm measurements.
(2) Required Measurements. The suite of measurements should include the following:
(a) Performance Measurement. A range of objective performance tests are used in scientific research. Things to consider when choosing a performance test for measuring crewmember fatigue include the following:
Appendix 2
1. How long does the test last? Can it be completed at multiple time points
(e.g., in the operations room during preflight preparations, near top of climb, near top of descent, and post-flight before disembarking from the aircraft) without compromising a crewmember’s ability to meet duty requirements?
2. Has it been validated? For example, has it been shown to be sensitive to the effects of sleep loss and the circadian body clock cycle under controlled experimental conditions?
3. Is the test predictive of more complex tasks (e.g., crew performance in a flight simulator)?
4. Has it been used in other aviation operations, and are the data available to compare fatigue levels between operations?
(b) Measurement Methodology. The certificate holder must provide a measurement methodology that will be sufficient to demonstrate that operations under the FRMS do not induce additional fatigue relative to operations under the prevailing prescriptive rules. The data collection and analysis methodology must specify the following components:
1. A description of the study population and the operations under which measurements will be collected. The methodology must provide for an unbiased and voluntary selection of participants.
2. A definition of what metrics will be derived from each measurement. For example, a reaction time test can provide multiple metrics, such as mean reaction time, long reaction times (lapses), and mean speed.
3. A definition of what level of each metric will serve as the safety standard, based on data collected during operations under the prevailing prescriptive rules. The safety standard serves as the baseline against which operations under the FRMS will be evaluated.
4. The duration of the study and a schedule of measurements. The data collection schedule must include measurements under the alternative operating procedures, as well as measurements during any subsequent trip by the same individuals.
5. A statistical analysis plan that will define how measurements under the FRMS will be evaluated against the safety standard to demonstrate an adequate level of compliance.
6. A description of methods used to assure the accuracy and integrity of all data collected to support the proposed FRMS.
(c) Fatigue Modeling. The analysis of empirical data may be supplemented by the use of a biomathematical model to estimate the level of fatigue or performance. For example, measurement of sleep could be used as input to a biomathematical model to derive estimates of fatigue or performance. If modeling is used, a justification of the choice of model must be provided, all modeling assumptions, parameters, and initial conditions must be defined, and a
Appendix 2 modeling safety standard must be defined, based on the prevailing prescriptive rules, that serves as the baseline for evaluation of fatigue or performance estimates under the FRMS operation.
(3) The collection and analysis of data are a prerequisite for the approval of the FRMS and issuance of Operations Specification (OpSpec) A318, Fatigue Risk Management System (FRMS) Authorization Applicable to Title 14 Code of Federal Regulations Part 117. Once the FRMS is approved, similar measurements will be obtained periodically as part of the SA process to confirm the continued effectiveness of the FRMS relative to the established safety standards.
c. Process 3.0: Identify Hazards. Identify the specific nature of the fatigue hazard(s) associated with the proposed operations where FRMS will be applied that may need to be managed. The current edition of ICAO Annex 6, Part I, Appendix 7 requires that a certificate holder develop, maintain, and document three types of processes for fatigue hazard identification. These are referred to as predictive, proactive, and reactive processes. A certificate holder shall develop and maintain the following three fundamental and documented processes for fatigue hazard identification as part of the approved FRMS:
(1) Predictive. The predictive process shall identify fatigue hazards by examining crew scheduling and taking into account factors known to affect sleep and fatigue and their effects on performance. Methods of examination may include but are not limited to:
• Certificate holder or industry operational experience and data collected on similar types of operations;
• Evidence-based scheduling practices; and
• Biomathematical models.
(2) Proactive. The proactive process shall identify fatigue hazards within current flight operations.
(a) Methods. Methods of examination may include but are not limited to:
• Self-reporting of fatigue risks;
• Crew fatigue surveys;
• Relevant flight and cabin crew performance data;
• Relevant flight and cabin crew sleep data;
• Available safety databases and scientific studies; and
• Analysis of planned versus actual time worked.
(b) Crewmember Fatigue Reports. Reports citing high fatigue levels or fatigue-related performance issues are vital to keep the FSAG informed about fatigue hazards in day-to-day FRMS operations. A series of fatigue reports on a particular route can be a trigger for further investigation by the FSAG. An effective fatigue reporting system requires an effective reporting culture. It needs to:
Appendix 2
1. Use forms that are easy to access, complete, and submit;
2. Have clearly understandable rules about confidentiality of reported information;
3. Have clearly understandable voluntary reporting protection limits;
4. Include regular analysis of the reports; and
5. Provide regular feedback to crewmembers about decisions or actions taken based on the reports and lessons learned.
(c) Crew Fatigue Surveys. Crew fatigue surveys fall into two basic types:
1. Retrospective surveys that ask crewmembers about their sleep and fatigue in the past. These can be relatively long and are usually completed only once, or at long time intervals (e.g., once a year); and
2. Prospective surveys that ask crewmembers about their sleep and fatigue right now. These are typically short and are often completed multiple times to monitor fatigue across a duty period, trip, or schedule. They usually include measures such as sleepiness, fatigue, and mood ratings.
(d) Performance Measurements. Performance measurements provide objective data that can be used to supplement the subjective data collected in fatigue reports and survey responses. Currently, there are three main approaches to monitoring crewmember performance:
1. Simple tests, developed in the laboratory, which measure aspects of an individual’s performance (e.g., reaction time, vigilance, and short-term memory). These performance measurements used to monitor the effectiveness of the FRMS may be the same as those utilized to obtain FAA approval of the FRMS;
2. Flight Data Analysis (FDA), which examines the relationship between identified elements of aircraft performance and pilot performance; and
3. Having trained flight deck observers rating the performance of crewmembers on the flight deck (e.g., Line-Oriented Safety Audit).
(e) Sleep Measurements. Sleep measurements provide objective data that verify that the sleep assumptions that were the foundation of the FRMS approval remain valid during the implementation of the FRMS. Sleep measurement technology used for ongoing hazard identification may be similar to those used for the FRMS approval.
(3) Reactive. The reactive process shall identify the contribution of fatigue hazards to reports and events associated with potential negative safety consequences in order to determine how the impact of fatigue could have been minimized. At a minimum, the process may be triggered by any of the following:
Appendix 2
• Fatigue reports,
• Confidential reports,
• Audit reports,
• Incidents, and
• Flight data analysis events.
d. Process 4.0: Assess Safety Risk. Conduct a safety risk assessment for each identified hazard. Decide which risks require mitigation. A certificate holder shall develop and implement risk assessment procedures that determine the probability and potential severity of fatigue-related events and identify when the associated risks require mitigation. The risk assessment procedures shall review identified hazards and link them to:
• Operational processes,
• Their probability,
• Possible consequences, and
• The effectiveness and controls of existing safety barriers and controls.
e. Process 5.1: Select and Implement Controls and Mitigations (Risk Management (RM)). Implement appropriate mitigation strategies and communicate them to all relevant personnel. When it is decided that a particular fatigue hazard requires action, then controls and mitigations must be identified and implemented. The specific expertise of the FSAG should be used in the selection of these controls and mitigations.
(1) All involved personnel should clearly understand the hazard and the controls and mitigations designed to reduce the associated risk. The certificate holder shall develop and implement risk mitigation procedures that:
(a) Select the appropriate mitigation strategies,
(b) Implement the mitigation strategies, and
(c) Monitor the strategies’ implementation and effectiveness.
(2) If the controls and mitigations perform to an established safety standard, they become part of normal operations and are monitored by the FRMS SA processes. If, however, the controls and mitigations do not perform to an acceptable standard, then it will be necessary to reenter the FRM processes at the Process 2.0, Collect and Analyze Data. This will require gathering additional information and data; and/or re-evaluation of the fatigue hazard and the associated risks; and/or identification, implementation, and evaluation of new or revised controls and mitigations.
f. Process 5.2: Set Safety Performance Indicators. Set safety performance indicator(s) to be able to assess whether the mitigation strategies are delivering the required level of risk reduction. Data collected during the first 4 months of the FRMS operation will be compared to the respective model predictions and the performance safety standards from the FRMS validation (Process 2.0) to establish whether crewmember performance and fatigue are in the acceptable range. By the fourth month of the FRMS operation, the fatigue reporting rate (reports per
Appendix 2 flight segment) and average fatigue report risk level should be comparable to operations under the prevailing prescriptive rules. No “intolerable” fatigue reports should be received.
g. Process 5.3: Develop Flightcrew FRMS Operations Procedures. Flightcrew FRMS operations procedures, are developed by the certificate holder and approved by the FAA to provide operational guidance for flightcrew members, dispatchers, schedulers, persons holding operational control, and individuals with oversight management of these areas for operations where an FAA-approved FRMS is applied. Therefore, flightcrew FRMS operations procedures serve as the foundation for disseminating safety-related guidance and procedural information for operations where an FRMS is proposed. FRMS operations procedures should be designed with supporting validated data collected and analyzed from various sources associated with the FRMS operation. Such data sources includes, but not limited to, actigraphy, performance tests, biomathematical modeling, and fatigue monitoring and reporting. Whenever FRMS is applied to any operation flightcrew members, dispatchers, schedulers, persons holding operational control, and individuals with oversight management of these areas for operations, all must comply with the FRMS operations procedures for that operation.
(1) As mitigations and controls are identified and validated to reduce fatigue risks associated with a specific FRMS operation, the certificate holder will be responsible for developing operating procedures that support those mitigations and controls. Specific limitations and conditions outlined in the certificate holder’s OpSpec A318 must also be reflected in the FRMS operating procedures. The certificate holder should use FRM and SA to validate and update their FRMS operation procedures. This process adds an additional layer of safety with regard to demonstrating the certificate holder’s FRMS operation procedures support their AMOC.
(2) As part of the FRMS continuous monitoring and improvement process, the certificate holder will be responsible for evaluating the effectiveness of the FRMS and updating these procedures to support the data results. This data shall be submitted with the certificate holder’s reporting interval data. The certificate holder must make available to each flightcrew member, dispatcher, scheduler, person holding operational control, and individual with oversight management of these areas for operations a current copy of the flightcrew FRMS operations procedures. When an FRMS is being applied to any part of the certificate holder’s operation, each person involved with the FRMS shall comply with the flightcrew FRMS operations procedures.
h. Process 6.0: Set Up Processes for Monitoring the Effectiveness of Controls and Mitigations. If mitigation strategies perform to an acceptable standard, they become part of normal operations and are monitored by the FRMS SA processes. If mitigation strategies do not perform to an acceptable standard, then reenter the FRM processes at the appropriate step.
(1) There is a defined validation period for the first 4 months of the operation that involves more intensive monitoring. The FSAG will have regular oversight of all data and fatigue reports coming in and will act in a timely manner when issues arise. Copies of all data collected and associated monitoring data, along with actions taken by the certificate holder to mitigate fatigue events and occurrences, shall be submitted to the FAA during regular scheduled reporting intervals. A report will be compiled and routine processes will be defined for fatigue