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.
Appendix 2 FIGURE 2-3. SAMPLE FATIGUE REPORT SAMPLE FATIGUE REPORT Answer A Fatigue Occurrence 1 2 3 4 5 6 7 8 9 In the previous 12 calendar-months, how many times have you experienced fatigue and reported the occurrence?
When the fatigue event occurred, how many consecutive days had you been on duty?
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?
Were you rescheduled for duty during the previous 72-hour period? (Yes or No) Prior to this notification, how long has it been since you were on duty or operating as a flightcrew member?
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?
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?
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.
If you were performing other duties, what was the total time worked each day performing those duties?
B Commuter 1 2 3 4 5 6 Are you a commuter? (Yes or No.) If No, indicate so and move to the next section.
What form of transportation was used for your commute?
How long is your commute?
What was that total time from the time you left your home to start your commute until the time you reported for duty?
How much time elapsed between the time you arrived at your domicile and your report time?
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 2 3 4 5 6 7 8 9 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.
Do you regularly hold a reserve line? (Yes or No) How many hours had your flown during the previous 24-hour period?
How many hours had you been on duty during the previous 24-hour period?
How many hours had your flown during the previous 72-hour period?
How many hours had you been on duty during the previous 72-hour period?
How many days had you been on duty during the previous 30 days?
How many hours had your flown in the previous 30 days?
When was the last period that you had been assigned at least 24 hours free from all duty?
D Operational Issues 1 2 3 4 5 6 Did you experience any operational or maintenance delays within the previous 72-hour period? If so, please provide details.
How many rest periods did you have in the previous 72-hour period leading up to the fatigue occurrence?
Did you have the opportunity to get additional rest between flights? If so, what was the quality of that rest?
During the previous 72-hour period, did your duty period involve consecutive night duty or continuous duty overnights? (Yes or No) If you answered “Yes” to question D4, how many consecutive nights of duty did you perform consecutively?
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 2 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.
Within the previous 24 hours, how many hours did you operate as an augmented crew?
Appendix 2 3 4 5 6 7 8 9 10 Within the previous 72 hours, how many hours did you operate as an augmented crew?
What classification of onboard rest facility did you use for in-flight rest?
(Class 1, 2, or 3) What would you estimate was the quality of rest you received during the previous 24-hour period? (Good, Fair, or Poor) What would you estimate was the quality of rest you received during the previous 72-hour period? (Good, Fair, or Poor) What was the length of your duty period within the previous 24-hour period?
How many hours had you spent on flight duty periods (FDP) during the previous 72-hour period?
Did you perform as an operating crewmember during the landing phase? If so, were you the flying pilot or the monitoring pilot?
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 2 3 4 5 6 Within the previous 72-hour period, what type of suitable accommodation did you use? (Hotel or at Home) If you rested at home, were there conditions that interrupted your sleep? (Yes or No.) If Yes, how many interruptions?
Were the hotels you stayed in regular hotels used by your carrier? (Yes or No) Were your hotel rooms located close to the elevator, ice machine, or high traffic area?
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.
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 2 3 Within the 24-hour period leading up to the fatigue occurrence, how many hours did you sleep?
Within the 48-hour period leading up to the fatigue occurrence, how many hours did you sleep?
Within the 72-hour period leading up to the fatigue occurrence, how many hours did you sleep?
I Circadian Issues 1 2 3 4 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.
How many time zones had you flown through within the previous 24-hour period?
How many time zones had you crossed within the previous 72-hour period?
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 2 3 4 During the 24-hour period leading up to the fatigue occurrence, what was the quality of your meals? (Good, Fair, or Poor) During the 72-hour period leading up to the fatigue occurrence, did you have the opportunity to eat properly? (Yes or No) During the 24-hour period leading up to the fatigue occurrence, have you experience dehydration? (Yes or No) 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) Page 22
Appendix 2 L Pre-Duty Activities 1 2 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.
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 Page 23
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 Flightcrew 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 Page 26