Trip scheduling, Crew scheduling (rostering), and Rest periods.
(2) There are analysis methods, such as biomathematical models of fatigue, which can be used to evaluate the fatigue implications of specific city pairs or trips and monthly pilot schedules. This system includes two components: an analysis of the risk of fatigue associated with the trip/schedule and an analysis of the potential consequences of that fatigue risk. Based on this risk and consequence analysis, proactive corrective action can be taken to mitigate the risk.
In addition, the fatigue reporting system may suggest that certain schedules are causing fatigue, and corrective steps can be taken to analyze the source of the fatigue and prevent a similar set of circumstances in the future.
d. Monitoring Fatigue in Flight and Cabin Crew (§ 117.7(b)(4)). Conceptually, this is similar to the fatigue analysis and reporting system component, but this component focuses on individual crewmember reports of fatigue. These reports provide feedback to the certificate holder about conditions perceived to contribute to fatigue.
(1) To maximize the utility of such reports, procedures must be arranged to capture all relevant information, such as the schedule leading up to the fatigue report, the actions of the employee to obtain rest, subjective and objective evidence of fatigue, environmental conditions that may have exaggerated or contributed to fatigue, relevant health or medical conditions, specific actions (commissions and/or omissions) related to the incident, and communications prior to and during the event. Corporate policy must provide protection of privacy and methods to protect the employee from adverse actions that would discourage reports of fatigue.
(2) Technologies developed to monitor sleep and performance in crewmembers can be used to supplement self-reports of fatigue. While it may not be practical to apply these technologies continuously, periodic studies of actual sleep (using actigraphs or logbooks) and fatigue (using performance measures and subjective ratings) can be highly valuable for objectively measuring the extent of fatigue across different kinds of operations and isolating key fatigue drivers (Hursh and Van Dongen, 2010). The certificate holder can use the results of these assessments to inform the analysis and forecasting functions of the FRMS to better assess potential fatigue in future operations (e.g., in a proposed new schedule).
e. Incident Reporting Process (§ 117.7(b)(5)). Reports of adverse events that may be attributable wholly or in part to fatigue are similar to crew reports, and can serve as a mechanism for obtaining all relevant information regarding fatigue contributions to the incident. Ideally, corporate policy would define how an adverse event is evaluated for potential fatigue involvement and also define a methodology for conducting a detailed Root Cause Analysis (RCA). Details of RCAs are available elsewhere (refer to the current edition of AC 120-59, Air Carrier Internal Evaluation Programs) but at a minimum, the incident investigation and reporting process must obtain all the necessary information to trace the root cause of the incident, especially the potential level of fatigue and the conditions that contributed to the fatigue-related event. The FRMS policy must provide for protection of privacy and methods to protect the employee from adverse actions that would discourage reporting events and conditions surrounding the events.
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f. Performance Evaluation (§ 117.7(b)(6)). An FRMS is a self-correcting process that includes evaluating the results of prior monitoring, analysis, training, and mitigation. Policies and procedures, based on the evaluation of results and the effectiveness of the FRMS in reducing fatigue, provide feedback to the system for continuous performance improvement.
(1) The CIP includes the following:
A system for evaluating and reporting the effectiveness of the FRMS, including reporting that is available to the regulator.
A process whereby the results of evaluations provide guidance to the FRMS program for self-correction and improvement.
A system for periodic independent review of the FRMS for its effectiveness in managing fatigue-related risk.
(2) While not required, it may be desirable to have a process for capturing economic benefits and costs of the program.
12. THE CONTINUOUS FRMS PROCESS. This paragraph reviews four steps that comprise a typical continuous FRMS process (refer to Figure 1, Fatigue Risk Management System Process).
Calling an FRMS a “process” means that it consists of a series of actions that build on corporate policies, organizations, and procedures. An FRMS is not just a written set of rules, but a living system that envisions certificate holders detecting and adapting to fatigue impact on their operation and employees carrying out specific actions that implement the policies and procedures within an established organization. The specific actions that comprise the FRMS process break down into four general steps that repeat, leading to continuous performance improvement and reductions in fatigue-related risk. Each step in the process relies on one or more of the fatigue management tools.
FIGURE 1. THE FATIGUE RISK MANAGEMENT SYSTEM PROCESS The FRMS Process
a. Measure and Assess Current Conditions
b. Modeling and Analysis of Fatigue Risk
c. Manage and Mitigate Fatigue Risk
d. Assessment and Feedback
a. Measurement and Assessment of Current Conditions. The first step is to measure and assess the level of fatigue risk associated with current schedules and operations by collecting Page 10 Par 11
information on crewmember reports of fatigue or fatigue-related errors and incidents, and information on the schedules that led up to these reported fatigue-related errors and incidents.
Understanding the current conditions within the organization is critical for the development of a valid mitigation plan.
b. Modeling and Analysis. This second step helps to determine the root cause of fatigue by modeling the work schedules and analyzing fatigue risk associated with them. This step is crucial to the process because it uses scientific principles about fatigue, perhaps aided by computer modeling, to find the specific operational and crewmember factors that could contribute to significant performance changes due to fatigue (Hursh and Van Dongen, 2010). Managing and mitigating fatigue depends on this step because fatigue risk needs to be measured and connected to the conditions (fatigue drivers) that contribute to the risk. Analysis of the fatigue risk can be broken down into two components: likelihood of occurrence of a particular level of fatigue and the severity of the consequence of fatigue, should it occur (Van Dongen and Hursh, 2010). For example, flight time that occurs between midnight and 0600 will inevitably include the period identified as the WOCL. This low point in performance should be evaluated in relation to the duties to be performed at that time; an expected raised level of fatigue is of greater concern if it coincides with critical flight maneuvers.
c. Management and Mitigation of the Fatigue Risk. This third step is based on the measurement and analysis of the fatigue-causing conditions. It requires explicit and regular management activity to consider the information from the first two steps and engage all the stakeholders in a collaborative process to develop solutions to address the fatigue-causing factors.
d. Assessment and Feedback. The fourth step in the process is collection of evidence of success in the form of improved schedules, additional sleep opportunities, enhanced training, and revised policies combined with objective data that demonstrate that these changes have effectively reduced fatigue. Evidence of reduced fatigue includes fewer reports of fatigue and/or errors due to fatigue, evidence of increased sleep, or modeling of schedules that predicts improved performance and reductions in fatigue related risk. This step is important and essential for continuous process improvement. Some measures may not prove to be as effective in reducing fatigue as anticipated, leading to a need for further adjustments. Additionally, changes in schedules, turnover in the workforce, added demands for service, and the addition of new routes can lead to emerging pressures that contribute to increased fatigue risk. This step allows for further adjustments to improve current operations and correct for changes in future operations.
13. ROLES AND RESPONSIBILITIES. This paragraph describes the general roles and responsibilities of the three primary stakeholders in the FRMS process: the certificate holder, the employees, and the FAA. The stakeholders should regard the roles and responsibilities described here as a starting point. These general roles and responsibilities are not an exhaustive description of the various actions to be taken by each group during the development and execution of the FRMS. Many of the details left to be defined depend on the specifics of each operation.
a. Certificate Holder. For the certificate holder, there are five general responsibilities:
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(1) Initial Commitment. The certificate holder is responsible for taking the initiative to develop, document, and implement the scientifically based FRMS. First, the organization must understand what developing an FRMS entails and must garner the commitment of its leadership to support the process. Second, the organization must be willing to commit the resources of time and money to assign individuals in the organization to develop and sustain the FRMS.
(2) Assign FRMS Team. Once the certificate holder identifies a team to develop the FRMS, the certificate holder is responsible for tasking the team to develop policies, training, data acquisition processes, analysis methods, and management procedures to implement, audit, and guide the FRMS process.
(3) Commitment of Resources. An FRMS is not a one-time activity; an FRMS is a living system that requires a continuing commitment of resources to support the effectiveness and progressive improvement of the process. The size of the resource commitment will depend on the size and complexity of the operation, but it does not end once the certificate holder establishes the FRMS.
(4) Collaboration. An effective FRMS is a collaborative process that involves all the stakeholders in discussion and joint action to be successful. It is the certificate holder’s responsibility to provide the mechanisms for collaboration/consultation among managers, employees, and the regulator. The certificate holder is responsible for creating a “just culture” where managers and employees can share information about fatigue without threat of reprisal or disciplinary action. In keeping with the responsibility of each crewmember to only accept duty when he or she is adequately rested to safely perform his or her duties, it is the responsibility of the organization to develop a nonpunitive policy for responding to legitimate reports of fatigue and providing reserves to replace fatigue-impaired crewmembers.
(5) Customization. The certificate holder can tailor an FRMS to the size of the organization. For a large organization with an entire department dedicated to each primary function, it will be necessary to have a Fatigue Safety Action Group (FSAG) to coordinate the fatigue-related initiatives across departmental boundaries. Within a smaller organization, it may only require that a single person be assigned the responsibilities to oversee the program.
Likewise, within a large organization, there may be multiple sources available to support the data requirements of the FRMS, while, in a small organization, data may be limited to reports of fatigue from pilots and occasional reports of procedural errors.
b. Employees/Crew. For the employees/crew there are three main responsibilities:
(1) Get Enough Sleep. The only remedy for sleep deprivation is sleep and it is the employee’s responsibility to use the facilities and sleep opportunities to obtain rest, sleep, and meals. Each person has a unique requirement for sleep and only the individual can decide how much sleep is adequate to maintain alertness and performance. As a general guide, the average person is thought to require about 8 hours of sleep per day, although individual differences exist in sleep need, ranging from 7-9 hours. In general, it is the employee’s responsibility to get as much sleep as they need and to take additional sleep when they feel fatigued or unfit for duty.
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(2) Plan Sleep Ahead of Time. Getting adequate sleep requires planning with future duty times in mind. For example, if duty will require an early morning awakening, then the employee should plan to go to bed early the night before so as to be fully rested for the next duty.
If the next duty will commence in the evening, the employee is responsible for taking an afternoon or evening nap so that her or she does not start work with eight or more hours of continuous wakefulness before the start of duty.
(3) Report Fatigue. If circumstances preclude sufficient sleep for the employee to be adequately alert and rested and to perform duty, whether they are the result of the schedule, delays, illness, life events, or personal actions, it is the employee’s responsibility to report his or her state of fatigue to the certificate holder. The employee should not accept the responsibilities of duty when fatigued or feeling unfit to perform assigned duties to the extent that the safety of the flight may be jeopardized.
c. Regulator. A regulator needs to be able to see that a certificate holder has a well defined FRMS plan that provides for at least an AMOC to that provided by the applicable prescriptive flight, duty, and rest regulations. Beyond evaluation of the plan, the regulator has the responsibility to monitor the application of the FRMS plan and evaluate measures of outcomes to ensure that an AMOC is, in fact, provided by the FRMS. Both of these steps are critical to the success and public acceptance of an FRMS. The assessment requires evaluation of both the FRMS plan and the FRMS process and outcomes. The following are the regulator’s responsibilities for guiding and assessing a certificate holder’s FRMS:
(1) The regulator has the responsibility to provide descriptions of the essential components and guidance for the steps required to implement an acceptable FRMS. Given the complexity of the aviation industry, such guidance will necessarily be general in nature to allow for adaptation to the size of the organization. This AC provides useful guidance for the regulator and certificate holder.
(2) For each certificate holder, the regulator reviews the components of the system (structures, policies, and process) and assesses whether those components are implemented on an ongoing basis.
(3) Prior to implementation, the regulator evaluates whether the FRMS, as planned, would be expected to establish an AMOC (forecasting function) to that provided by compliance with established flight time/duty time regulations.
(4) Once implemented, the regulator periodically evaluates if the FRMS, in practice, is meeting safety goals (auditing function).
(5) The regulator must evaluate if the FRMS process itself is responsive to feedback for continuous improvement (tracking progress).
14. IMPLEMENTATION. Details of implementation will depend greatly on the complexity of the organization and the demands of the operational conditions confronted by flightcrew. This AC does not provide a step-by-step implementation guide, but rather details the general progression of the implementation process and several potential implementation pitfalls.
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a. Resources. In order to implement an effective FRMS, the organization must commit resources to acquire and develop the four basic building blocks (refer to Figure 2, Building Blocks of a Fatigue Risk Management System):
FIGURE 2. BUILDING BLOCKS OF A FATIGUE RISK MANAGEMENT SYSTEM Building Blocks of an FRMS Organization and Personnel Training and Publicity Policies and Procedures Tools and Methods
(1) Policies and Procedures. The foundation of the FRMS is documentation that defines the policies and procedures that guide FRM, representing the commitment of the organization to the process and clear statements defining how the system will function. The basic elements of that documentation have been outlined in this AC, but the detail and complexity of the system will depend on the size and diversity of the organization and its operation.
(2) Organization and Personnel. An FRMS is more than documentation; it is an active process that is implemented by members of the organization who regularly meet to review data on fatigue indicators, analyze contributing factors to fatigue, take reactive and proactive actions to mitigate fatigue, audit the effectiveness of the system, and take corrective action to continuously improve the system. Most organizations can form a defined FSAG to implement the system. The committee should include representatives of all departments and groups that have a role in reporting, managing, and mitigating fatigue.
(3) Tools and Methods. A variety of tools and methods are instrumental in aiding the activities of the FRMS organization, such as fatigue modeling, statistical analysis software, performance and sleep measurement systems, and reporting forms and databases. The tools do not constitute the FRMS, but they are essential for the system to function effectively. The organization must be willing to commit resources to procure the necessary supporting tools if the FRMS is to be effective.
(4) Training and Publicity. Training operational personnel and managers about the physiological and behavioral foundations of fatigue, the operational and environmental drivers of fatigue, and effective fatigue mitigations is essential to managing fatigue risk. Furthermore, all personnel must know the corporate policies that are the foundation of the corporate FRMS Page 14 Par 14
process, including policies and procedures that govern fatigue reporting, fitness for duty, absence for fatigue, incident reporting, employee privacy, and prevention of coercion to perform duties while fatigued. Finally, an effective FRMS includes feedback and publicity about the system to all affected employees to encourage cooperative participation in the corporate FRM strategy.
b. Extending Processes. The building blocks of the FRMS will be an extension of existing processes to manage overall operational safety. For example, incident report forms may already exist and need only be expanded to collect information relevant to a fatigue analysis. An organizational structure may already exist to implement safety management, and the addition of an FSAG might be the only change in the organization.
c. Developing an FRMS. The initial development of an FRMS will start with a certificate holder assembling the building blocks described above, starting with developing the policies and procedures and establishing the FRMS organization. The organization will then acquire the necessary tools and methods, and develop supporting training and publicity programs. There are several pitfalls to avoid in this complex process.
(1) The FRMS organization, such as the FSAG, should include representatives of all the key departments and groups that have a role in identifying, managing and mitigating fatigue in operations. FRM is a collaborative process and will require the commitment of key leaders of the organization and the cooperative participation of relevant groups. An example would be the marketing department, which plays a key role in defining trips and schedules. While their primary responsibility is to advance the business interests of the corporation and provide service to customers, marketing also has a key role in defining the requirements of schedules that may be causing excessive fatigue. Its participation in finding acceptable alternatives that reduce fatigue is essential to a successful FRMS. At the same time, employee groups (e.g., union representatives) should also participate in the process because managing and mitigating fatigue is a shared responsibility between the organization and the employees. Ensuring that employees understand and embrace their responsibilities to report for duty well rested is just as important as arranging schedules that provide sufficient rest opportunities.
(2) There is a danger that the FSAG may adopt a reactive approach to fatigue management, taking constructive action only in response to reports of fatigue or fatigue-related adverse events. The more effective approach is to minimize fatigue by using available tools to forecast potential fatigue well in advance of actual operations, and taking corrective action to proactively eliminate potentially fatiguing schedules or conditions prior to their occurrence. An indicator of a highly effective FRMS is the frequency of such proactive corrective actions.
(3) The FRMS should include a methodology for evaluating the success of the program and make changes in the program for process improvement. Two equally important parts of the evaluation and validation process are necessary. The first is self-evaluation using established metrics that reflect the degree of fatigue in the organization. The FSAG should monitor those metrics regularly, looking for trends over time that suggest the need for change or validate the effectiveness of actions already taken. The second is an occasional independent audit of the program by an outside agency or consultant.
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(4) An outside observer familiar with FRMS principles and cognizance of best practices developed by other organizations can be an invaluable aid to improving the effectiveness and efficiency of the FRMS process.
15. FRMS APPLICATION PROCESS. For a full description of the FRMS approval process, see Appendix 2, Section 7. The FRMS approval process consists of five steps that must be satisfactorily completed in succession. Each step is referred to as a phase. Within each phase are specific tasks that must be completed before the certificate holder may move to the next phase.
These tasks are compiled into number gates. Each gate must be completed in succession before that phase is considered completed. Appendix 2, Figure 2-6, Fatigue Risk Management System Approval Process, provides a graphic depiction of the FRMS approval process. The five phases of the approval process are:
Phase 1: Preapplication, Planning, and Assessment (4 Gates).
Phase 2: Formal Application (2 Gates).
Phase 3: Documentation and Data Collection Plan (1 Gate).
Phase 4: Demonstration and Validation (1 Gate).
Phase 5: Authorization, Implementation, and Monitoring (1 Gate).
NOTE: Appendix 2 of this AC provides a complete, step-by-step process for applying for an FRMS authorization.
/s/ for John M. Allen, Director, Flight Standards Service
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Appendix 1 APPENDIX 1. REFERENCES
1. Bonnet, MH. Sleep Deprivation. In M. H. Kryger, T. Roth, & W. C. Dement (Eds.), Principles and Practice of Sleep Medicine (3rd ed). Philadelphia: Saunders; 2000:53–71.
2. Carskadon, MA, Dement, WC. Daytime Sleepiness: Quantification of a Behavioral State.
Neuroscience Biobehavioral Review 1987; 11:307–17.
3. Dinges, DF. The Nature of Sleepiness: Causes, Contexts and Consequences. In A. Stunkard & A. Baum (Eds.), Perspectives in Behavioral Medicine: Eating, Sleeping and Sex. Hillsdale, NJ; 1989: Lawrence Erlbaum.
4. Dinges, DF. Probing the Limits o Functional Capability: the Effects of Sleep Loss on Shortduration Tasks. In R. J. Broughton & R. D. Ogilvie (Eds.), Sleep, Arousal, and Performance.
Boston: Birkhauser; 1992:177–88.
5. Dinges, DF, & Kribbs, NB. Performing While Sleepy: Effects of Experimentally-induced Sleepiness. In T. Monk (Ed.), Sleep, Sleepiness, and Performance. Chichester, UK: John Wiley and Sons, Ltd; 1991:98–128.
6. Horne, JA. Human Sleep, Sleep Loss and Behaviour: Implications for Prefrontal Cortex and Psychiatric Disorder. British Journal of Psychiatry 1993; 162:413–9.
7. Horne, JA, Reyner, LA. Sleep Related Vehicle Accidents. Br Med Journal 1985; 310:565–7.
8. Hursh, SR & Van Dongen, HPA. Fatigue and Performance Modeling. In Meir H. Kryger, Thomas Roth, William C. Dement (Ed.), Principles and Practice of Sleep Medicine, 5th edition.
Saunders; 2010 (in press).
9. Naitoh, P. Sleep Deprivation in Humans. In P. H. Venables & M. J. Christie (Eds.), Research in Psychophysiology. London: John Wiley; 1975.
10. Reason, JT. Managing the Risks of Organizational Accidents. New York: Ashgate Publishing; 1997.
11. Rosekind MR, Graeber RC, Dinges DF, Connell LJ, Rountree MS, Spinweber CL, et al.
Crew Factors in Flight Operations IX: Effects of Planned Cockpit Rest on Crew Performance and Alertness in Long-haul Operations. Moffett Field, CA: NASA Ames Research Center; 1994 Report No: DOT/FAA/92/24.
12. Van Dongen, HPA & Hursh, SR. Fatigue, Performance, Errors and Accidents. In Meir H.
Kryger, Thomas Roth, William C. Dement (Ed.), Principles and Practice of Sleep Medicine, 5th edition. Saunders; 2010 (in press).
13. Wylie CD, Shultz T, Miller JC, Mitler MM, Mackie RR. Commercial Motor Vehicle Driver Fatigue and Alertness Study: Project Report (Report No.: FHWA-MC-97-002). Washington, DC: U.S. Department of Transportation; 1996.
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Appendix 2 APPENDIX 2: FATIGUE RISK MANAGEMENT SYSTEM DEVELOPMENT SECTION 1. INTRODUCTION
1. PRACTICAL APPLICATION OF A FATIGUE RISK MANAGEMENT SYSTEM (FRMS). An FRMS is as an alternative regulatory approach to providing a means of managing, monitoring, and mitigating fatigue to improve flightcrew member alertness and reduce performance errors. Under an FRMS, a certificate holder develops processes that manage and mitigate fatigue that serve as an alternate method of compliance (AMOC) to the prescriptive rule. Essentially, a certificate holder may apply an FRMS, which is an approved AMOC, to a specific limitations imposed by Title 14 of the Code of Federal Regulations (14 CFR) part 117.
However, before the certificate holder may conduct operations under a Federal Aviation Administration (FAA)-approved FRMS, the certificate holder must satisfactorily demonstrate to the FAA that their proposed FRMS satisfactorily demonstrates that the AMOC provides an equivalent level of safety to the safety standards set forth in part 117. At a minimum, the certificate holder’s proposed FRMS must include the following elements listed in part 117, § 117.7:
A Fatigue Risk Management (FRM) policy, An education and awareness training program, A fatigue reporting system, A system for monitoring flightcrew fatigue, An incident reporting process, and A performance evaluation.
2. FRMS STRUCTURE. An FRMS structure employs multilayered defensive strategies to manage fatigue-related risks, regardless of their source. It includes data-driven, ongoing adaptive processes that can identify fatigue hazards and then develop, implement, and evaluate controls and mitigation strategies. These include both organizational and personal mitigation strategies.
However, the cost and complexity of an FRMS may not be justified for operations that remain inside the flight and duty time limits and where fatigue-related risk is low. Some certificate holders, therefore, may choose to place only certain parts of their operations under an FRMS, or not to implement an FRMS at all. Nonetheless, where an FRMS is not implemented, it remains the certificate holder’s responsibility to manage fatigue-related risks through their existing safety management processes, the Fatigue Risk Management Plan (FRMP), and the prescriptive flight, duty, and rest limitations.
3. FRM AND SAFETY ASSURANCE (SA). FRM and SA are the core components of the FRMS. These core activities are governed by an FRMS policy and supported by FRMS promotion processes, and the system must be documented. The FRMS relies on the concept of an effective safety reporting culture, in which personnel have been trained and are constantly encouraged to report hazards whenever they observed them in the operating environment. To encourage the reporting of fatigue hazards by all personnel involved in an FRMS, a certificate holder must clearly distinguish between unintentional human errors, which are accepted as a normal part of human behavior and are recognized and managed within the FRMS, and deliberate violations of rules, policies, and established procedures. The certificate holder should have processes independent of the FRMS to deal with intentional noncompliance. Table 2-1, Page 1
Appendix 2 Components of Fatigue Risk Management Systems, describes the basic components of an FRMS.
TABLE 2-1. COMPONENTS OF FATIGUE RISK MANAGEMENT SYSTEMS.
Components Elements Fatigue Risk Management System (FRMS) policy and documentation Fatigue Risk Management (FRM) Identification of hazards processes Risk assessment Risk mitigation Safety Assurance (SA) processes FRMS performance monitoring Management of operational and organizational change Continuous FRMS improvement FRMS promotion processes Training programs FRMS communication plan
4. THE ADVANTAGE OF FRMS. Since an FAA-approved FRMS is applied to exceed a specific limitation, the potential exposure to a fatigue-related event must be mitigated, managed, and monitored. Typically, accidents and incidents result from interactions between organizational processes (i.e. workplace conditions that lead crewmembers to commit active failures) and latent conditions that can penetrate current defenses and have adverse effects on safety. The FRMS approach is designed to apply fatigue science and safety management. It is intended to provide an equivalent, or enhanced, level of safety, while also offering greater operational flexibility to that provided by the prescriptive limitation(s).
5. PERFORMANCE-BASED APPROACH. Essentially, an FRMS represents a performancebased regulatory approach. This means that the FRMS defines the requirements and processes required for certificate holders to measure, manage, mitigate, and monitor potential fatigue risk associated with the operation for which the FRMS is applied. Data collection and analysis are vital in determining the flightcrew members’ level of performance during that operation proposed by the certificate holder. The FRMS requirements and processes are derived from the data collection and analysis output. Applying the FRM and SA components, the FRMS requirements and processes are measured, managed, and monitored for continuous improvement of the FRMS.
6. FRMS LIMITATIONS AND CONDITIONS. The certificate holder’s FAA-approved FRMS authorization will be based on analyzed and validated data applicable to the specific limitation to be exceeded under the FRMS. Therefore, the FAA will impose specific limitations and conditions applicable to the FRMS authorization. While conducting operations under an FRMS authorization, the certificate holder must comply with these limitations and conditions along with their FAA-approved FRMS processes and procedures.