Appendix 2
7. FRMS COMPLEXITY. The complexity of the FRMS structure will vary according to:
The size of the organization, The scope of the FRMS, The type of operations where the FRMS will be applied, The type and complexity of the operations being managed, The relative maturity of the FRMS; and The relative importance of the fatigue hazards governed by the FRMS.
Appendix 2 SECTION 2. FRMS POLICY AND DOCUMENTATION
1. OVERVIEW OF FRMS POLICY AND DOCUMENTATION. The FRMS policy and documentation are instrumental in defining the organizational measures to support the core operational activities of the FRMS. While FRMS policy specifies the certificate holder’s commitment and approach to the management of fatigue risk, it should be noted that the certificate holder must clearly define all elements of their FRMS policy. The certificate holder’s FRMS policy must be distinguishable from the general safety policy to allow for a separate review. FRMS documentation describes the components and elements of the entire FRMS.
Additionally, the use of FRMS documentation makes it possible to audit the effectiveness of the FRMS (internally and externally) to verify that it is meeting the safety objectives defined in the FRMS policy.
2. FRMS DOCUMENTATION. The FRMS documentation describes all the elements of the FRMS and provides a record of FRMS activities and any changes to the FRMS. The documentation can be centralized in an FRMS manual. However, it needs to be accessible to all personnel who may need to refer to it and to the FAA for auditing purposes. The current edition of ICAO Annex 6, Part I, Appendix 8 requires that the certificate holder shall develop and keep current FRMS documentation that describes and records:
FRMS policy and objectives;
FRMS processes and procedures;
Accountabilities, responsibilities and authorities for these processes and procedures;
Mechanisms for ongoing involvement of management, flight and cabin crewmembers, and all other involved personnel;
FRMS training programs, training requirements, and attendance records;
Scheduled and actual flight times, duty periods, and rest periods with significant deviations and reasons for deviations noted; and FRMS outputs including findings from collected data, recommendations, and actions taken.
3. FATIGUE SAFETY ACTION GROUP (FSAG). As a way of meeting the ICAO requirements described in paragraph 2, it is expected that a certificate holder establish a functional group that is responsible for coordinating the fatigue management activities within the organization.
a. FSAG Role. This task should be the responsibility of the FSAG. The FSAG is a group comprised of representatives of all stakeholder groups (e.g., management, scheduling, and crewmembers) together with specialist scientific, data analysis, and medical expertise, as required), that is responsible for coordinating all fatigue management activities in the organization. The principle functions of the FSAG are to:
(1) Develop and maintain the FRMS documentation;
(2) Manage the FRM processes;
(3) Contribute to the FRMS SA processes;
Appendix 2
(4) Be responsible for the FRMS promotion processes; and
(5) Maintain the required documentation.
b. FSAG Composition. The composition of the FSAG should reflect the shared responsibility of individuals and management by including representatives of all stakeholder groups (management, scheduling staff, and crewmembers and/or their representatives) and other individuals as needed to ensure that it has appropriate access to scientific and medical expertise.
c. FSAG Scalability. The size and composition of the FSAG will vary for different certificate holders, but should be related to the size and complexity of the operations covered by the FRMS, and to the level of fatigue risk in those operations. Figure 2-1, Midsize and Large Air Carriers, illustrates midsize and large air carrier operations and Figure 2-2, Small Air Carriers, depicts operations for a small air carrier. In small certificate holders, a single individual may represent more than one stakeholder group; for example, the chief pilot may also be the primary scheduler. In very small operations, there may not even be a designated FSAG, but simply extra items on the safety meetings agenda, as long as long as all FRM activities are documented. Larger airlines will have specialized departments that interact with the FSAG.
While the FAA may wish to observe FSAG meetings as part of its oversight activities, the FAA is not a required part of this group. However, the FAA may also wish to review the minutes and outputs of such meetings as part of their continuous oversight activities.
4. FRMS SCOPE. Within the FRMS manual, the certificate holder must identify the scope of the FRMS operations for which the FRMS is applied to their operations. Otherwise, all operations not covered by the FRMS must operate under the applicable prescriptive flight time, duty time, and rest limits. A certificate holder may choose to apply the FRMS to all its operations, or only to specific types of its operations (e.g., a particular fleet, a particular route, or only ultra long-range (ULR) operations). Because the policy statement is typically short, it does not have to detail the scope of the operations to which the FRMS applies; however, the policy statement must identify where the scope of FRMS operations is detailed. As a certificate holder’s familiarity and experience with the FRMS builds, they may wish to expand the scope of the FRMS.
5. FRMS POLICY. The FRMS policy provides the umbrella under which the FRMS operates.
Within the FRMS policy, the certificate holder shall clearly define all elements of the FRMS.
The FRMS policy shall also require that the scope of the certificate holder’s FRMS operations be clearly defined in their FRMS manual.
a. Minimum Requirements. The FRMS policy must identify and address the minimum requirements of the FRMS, which are essentially the prerequisites of an FRMS. As with prescriptive flight and duty limitations, the management of fatigue-related risks associated with the FRMS is a joint responsibility between the certificate holder and individual crewmembers due to the particular nature of fatigue. The FRMS policy specifies the certificate holder’s commitment and approach to the management of fatigue risk. It is the responsibility of the certificate holder to clearly define all elements of the FRMS in its policy. Additionally, the certificate holder’s FRMS policy must be able to be distinguished from the general safety and operational policy to allow separate review. Minimum requirements for the FRMS policy shall:
Appendix 2
(1) Reflect the joint responsibility among the certificate holder’s management, flight and cabin crews, and other involved personnel;
(2) Clearly state the safety objectives of the FRMS;
(3) Be signed by the accountable executive of the organization;
(4) Be communicated, with visible endorsement, to all the relevant areas and levels of the organization;
(5) Declare management’s commitment to effective safety reporting;
(6) Declare management’s commitment to providing adequate resources for the FRMS;
(7) Declare management’s commitment to continuous improvement of the FRMS;
(8) Require that clear lines of accountability for management, flight and cabin crews, and all other involved personnel are identified; and
(9) Require periodic reviews of the FRMS policy to ensure that it remains applicable and appropriate.
b. Responsibility of Crewmembers. Fatigue is affected by all waking activities, not only work demands, sometimes described as “day-to-day life issues.” For example, crewmembers have personal responsibility because they can choose the amount of time they spend trying to sleep during available rest breaks, and choose when to use personal fatigue mitigation strategies.
They have a responsibility to use rest periods effectively to be properly rested and fit for duty.
Ultimately, as required in § 117.5(d), it is the responsibility of the flightcrew member to affirmatively state on the dispatch or flight release, prior to commencing a flight segment, that he or she is fit for duty. To that point, it is imperative that the flightcrew member obtain the proper amount of rest to safely perform their assigned duties during that flight. In addition, their cooperation is vital for voluntary reporting of fatigue hazards, and when fatigue levels need to be measured for FRM processes and FRMS SA processes. Crewmembers’ willingness to cooperate will depend on their confidence that the certificate holder is committed to promoting a “just” culture an effective safety reporting culture.
c. Responsibility of Management. Management is primarily responsible for the management and mitigation of fatigue risk because it schedules the work activities of personnel and the distribution of resources in the organization. The FRMS is an organizational system that enables management to meet that responsibility. The accountable executive, when signing the FRMS policy, accepts accountability for the FRMS, either directly or through supervision and management of others, including those to whom the accountable executive has delegated this responsibility. The safety objectives in the FRMS policy must specify what the certificate holder wants the FRMS to achieve. To track whether the FRMS is meeting these objectives, its performance needs to be monitored. The FRMS policy needs to be reviewed periodically by the certificate holder to ensure that it is adequate to meet changing operational demands. In addition, it will be subject to periodic review by the FAA.
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.
FSAG Management Flight Operations Dispatch/Flight Following Page 8
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 8 requires that a Page 9
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 Page 13
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 8 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 8 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 (Web sites, 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 Page 14