Fatigue Risk Management

System (FRMS)

IATA’s Perspective

CNPAA Meeting25/APR/2014

Safety and Flight Operations

IATA Brazil

� A IATA (International Air Transport Association) is an international

organization that supports the global commerce related to the

aviation industry.

� Founded in 1945, has 240 member airlines representing 84% of theworld air traffic.

� Our mission is to represent, lead and serve the industry.

� Our Vision is to deliver standards and solutions in order to ensure a

successful and safe air transport worldwide.

About IATA

Fatigue Management Approaches

� Prescriptive;

• Flight and duty time limitations.

• Identified by regulator.

• One-size fits all.

• Arbitrary “safety” line.

� Fatigue Risk Management System (FRMS);

• FTLs identified through operator’s processes.

• Specific to operational context.

• Continually evaluated and updated.

Fatigue Management Provisions

� ICAO Annex 6 Part 1 (Flight and Cabin Crew):

• FRMS Standards and Recommended

Practices (SARPs).

• Appendix 8.

• Attachment A (guidance for FTL regulations).

� ICAO Doc 9966 - FRMS Manual for Regulators

� FRMS Guides (IATA & ICAO) developed for:

• Operators.

• Regulators.

Annex 6 - FM SARP: 4.10.2

� The Operator:

Where FRMS regulations are offered, can choose

how to manage their fatigue risks:

• Comply with prescriptive regulations

or;

• An FRMS for all operations.

or;

• An FRMS for some operations and prescriptive regulations for the remainder of operations.

� Safety policy & objectives

� Safety risk management

� Safety assurance

� Safety promotion

SMS Components FRMS Components

� FRMS policy & documentation

� Fatigue risk management processes– Identification of hazards

– Risk assessment– Risk mitigation– Implementation

� Fatigue safety assurance processes– Monitor effectiveness of FRMS– Processes for managing change– Continuous improvement of the FRMS

� FRMS promotion processes– Training programmes– FRMS communication plan

Annex 6 - Appendix 8

IATA’s FRMS Guide� Collaboratively developed.

� Aligned with ICAO’s FRMS Manual for Regulators.

� Provides comprehensive implementation guidance including scientific principles.

� Freely available on the web

• www.gsic.iata.org

• www.icao.int

• www.ifalpa.org

Regulatory Decisions, Activities and Tools

Chapter 1. Chapter 1.

FRMS defined.

FRMS SARPs and their intent.

Chapter 7.

Considerations when deciding to offer FRMS

regulations.

Chapter 8.

Process

Chapter 8.

The FRMS Approval Process

Chapter 9.

Oversight

Chapter 9.

Providing FRMS Oversight

Appendix D. FRMS

(Example)

Appendix D. FRMS

Evaluation Form (Example)

The Scientific Background

Chapter 2.

The scientific principles on which an FRMS approach is based.

Components of an FRMS

Chapter 3.

Policy and Documentation

Chapter 4.

Fatigue Risk Management Processes

Chapter 5.

Fatigue Safety Assurance Processes

Chapter 6.

FRMS Promotion Processes

Supporting Information

Appendix A.

Glossary

Appendix B.

Tools for measuring fatigue

Appendix C. Procedures for Controlled Rest on

the Flight Deck

IATA’s FRMS Guide

FRMS Definition (IATA/ICAO)

“ A data-driven means of continuously monitoring and

managing fatigue-related safety risks, based upon scientific

principles and knowledge as well as operational experience,

that aims to ensure relevant personnel are performing at

adequate levels of alertness.”

What are the scientific principles?� The physiological need for sleep:

• Quantity.

• Quality.

� Recovery from sleep loss:

• Transient;

• Cumulative;

� Circadian biological clock;

Doctor?

Scientist?

Safety Expert?

Labour?

Who is the expert?

Pilot

Fatigue Subject Matter

Expert (SME)

Flight Operations

Management

Fatigue (ICAO Definition)

� “…A physiological state of reduced mental or physical

performance capability resulting from sleep loss or

extended wakefulness, circadian phase, or workload

(mental and/or physical activity) that can impair a crew

member’s alertness and ability to safely operate an aircraft or perform safety related duties.”

� “Fatigue” vs. “Tired”

There is a difference!!

Why is Fatigue Getting so Much Attention?� All aspects of a carrier’s operation are affected

• Headcount

• Crew Utilization

• Equipment Utilization

• Network Planning

• Scheduling

� Fatigue Management = Additional Constraints

� Increasing operating costs with sick crews.

Ops Conference 14 16-18 April 2012, Rio de Janeiro

Sitting at the Fatigue Management Table

The Regulator

� Role

• Provide a regulatory framework for the

adequate management of fatigue related

risks.

• Ensure that the operator is managing their

fatigue related risks to an acceptable level

of safety.

• Recognizes that FRMS needs to be

unique to each operator.

Regulator Needs� A platform of robust prescriptive flight and duty limitation

regulations;

� Time and resources to develop sufficient knowledge related

to fatigue management processes;

� Access to scientists;

� Experience in oversight of performance-based regulations;

� Clear approval and oversight processes;

� Basis : ICAO Doc 9966 (FRMS Manual for Regulators, 2011)

� Outputs:

• FAR117 (2013) “Flightcrew Member Duty and Rest Requirements”.

• AC 117-3 “Crew Fitness”.

• EASA CAP371.

Challenges for the Regulator� Providing a regulatory environment that supports effective safety

reporting.

� Performance-based regulations require different regulatory skill sets

� Assessing the balance - flexibility with tolerable risk.

� Provision of consistent and comprehensive guidance to operators.

� Consistency in regulatory decisions.

The Operator

� Role

• Own and manage their fatigue related risk to an acceptable level of safety;

• Within the regulatory framework provided, identify the most appropriate means of managing their fatigue-related risk;

• Provide the operational environment to allow a pilot to manage their fatigue-related risk on any given day or time.

Operator Needs� Operate competitively within the global aviation environment.

� A level playing field amongst global carriers.

� Operational flexibility to react quickly to unforeseen circumstances.

� Data-driven and/or results-oriented resource allocation.

� Free-flow of information from pilots.

Challenges for the Operator� Limited Resources:

• Data collection.

• Undertaking scientific research.

• Effective application of available information.

• In-house expertise.

� Regulatory demands…

The Pilot

� Role

• Use the resources provided to assure

he/she is adequately rested to perform

his/her duties safely.

• Recognize when they are unable to

perform their duties safely and if so

remove themselves from the operation.

Pilots Needs� Information, schedules and resources for allowance to responsibly

prepare for, and execute duties.

� Effective safety reporting culture.

� High standards of professional behaviour.

Challenges for Pilots� Focusing on safety needs vs. industrial desires.

� Focusing on safety needs vs. personal preference.

� Group acceptance of scientific principles and their application.

� Confidence in the operator’s reporting system.

Pilots - Fitness For Duty� Essential Elements

• Opportunity for rest

• Use of rest opportunity

• What do we do when it doesn’t

work as planned.

� Responsibilities

• Pilot’s role

• Operator’s role

Safety x Labor Relations� Deal breakers:

• Pilots - Interrupt data collection and/or halt participation for

industrial reasons.

• Operators - Use voluntary information for punitive reasons or

other than intended purposes.

• Regulators - Fail to set rules to protect data.

How to Avoid the Deal Breakers� Collaborative Relationship (CDM)

• Pilots;

• Operators;

• Regulators;

� Mutual Respect.

� Commitment to meet respective

responsibilities.

FRMS Basics� Data-driven and scientifically based process;

� Allows for continuous monitoring and management of safety risks associated with fatigue-related error;

� Part of a repetitive performance improvement process;

� Leads to continuous safety enhancements;

• Identification and management of fatigue factors across time

• Changes physiological and operational circumstances associated with a specific operation

� May be integrated into an operator’s overall SMS.

Elements of an FRMS

� Current flight time and duty period limitations.

� Rest scheme consistent with limitations.

� A fatigue management policy.

� Education and awareness training program.

� Fatigue reporting process.

� System for monitoring and analyzing flight crew fatigue.

� Evaluation program.

FRMS Process

Identify / Assess

Current Risk

Assessment of

Fatigue Risk

Manage and Mitigate Fatigue

Risk

Monitor for Effectiveness

Effective Safety Reporting System� Permits crewmembers and other employees to report fatigue.

� Contains valuable data.

� An effective safety reporting system.

• Does not provide full immunity from acts resulting from willful and/or gross negligence and illegal acts;

• Does provide clear descriptions of acceptable and non-acceptable behavior and their consequences;

• Does provide the environment that encourages free reporting.

Types of Data� Reactive - wait for incidents to happen

and try to understand why;

� Proactive - analyze near misses,

identified risks to mitigate before they turn

into an accident / incident;

� Predictive - mature system which

conducts predictive analytics (statistical

modeling) to identify and mitigate risks;

Fatigue Reports� A system for monitoring flight crew member fatigue in day-to-day

operations

• Not-fit for duty;

• Hazard report ;

� Should contain operational procedures to follow when one identifies

or suspects fatigue risk in oneself or others.

Confidential Reporting� Confidential reporting can be used for the following safety concerns:

• Unsafe behaviors;

• Inadvertent errors and mistakes;

• Near miss occurrences (incidents that did not occur but could

have easily resulted in a serious event);

• Inadvertent errors or violations of aircraft handling or servicing

systems;

• Procedures or processes that could be improved;

Other Data Sources� Other data sources to consider when identifying and assessing

fatigue occurrences:

• Internal audit results;

• Procedural errors

• Schedule deviations ~ planned vs. actual

• Accident Reports

� Summarizes supporting science

� Explains the minimum requirements

� Describes how to implement an FRMS

� Provides operational examples of various means of compliance

� Stresses the need for joint responsibility amongst all stakeholders

IATA’s FRMS Guide

SMS and FRMS

SMS Framework FRMS

Safety policy and objectives FRMS policy and documentation

Safety risk management FRM processes

• Identification of hazards

• Risk assessment

• Risk mitigation

Safety assurance FRMS safety assurance processes

• FRMS performance monitoring

• Management of operational and organizational change

• Continuous FRMS improvement

Safety promotion FRMS promotion processes

• Training programs

• FRMS communication plan

FRMS Framework

Fatigue Safety

Action Group

Co-ordinates fatigue

risk management

activities

Risk Management

Processes (Chapter

Four)Policy (Chapter 3)

Safety Assurance

Processes (Chapter

Five)

Promotion

Processes

(Chapter Six)

Documentation

(Chapter 3)

Methods of Hazard Identification� Reactive Methods

• Assess the contribution of crewmember fatigue to safety reports and events.

• At what time of day did the occurrence take place?

• Was the crewmember’s normal circadian rhythm disrupted?

• How many hours had the crewmember been awake at the time

of the occurrence?

• Does the 72-hour sleep history suggest a sleep debt?38

Methods of Hazard Identification� Predictive Methods

• Identify areas of future fatigue related risks:

o Previous experience;

o Evidence-based scheduling practices;

o Bio-mathematical models;

39

Methods of Hazard Identification

� Proactive Methods

• Monitor fatigue levels in an operation;

• Self-reporting of fatigue risks;

• Crew fatigue survey;

• Flight crew performance data;

• Available safety databases and scientific studies;

• Analysis of planned x actual time worked;

• Sleep monitoring (sleep diary, actigraphy, polysomnography)

I f conf ident ialit y r equir ed t ick her e ● Fatigue Report

Form

Nam e Em ployee No. Pilot / CCM ( cir cle)

WHEN DI D I T HAPPEN? Local r epor t dat e Tim e of event ( local r epor t t im e)

Dut y descr ipt ion ( t r ip pat t er n)

Sect or on which f at igue

occur r ed

Fr om To

Hour s f r om r epor t t im e t o when f at igue occur r ed Disr upt ? Yes / No

Air cr af t t ype Num ber of cr ew

WHAT HAPPENED?

Descr ibe how you f elt ( or what you obser ved)

Please cir cle how you f elt

1 Fully aler t , wide awake 5 M oder at ely let down, t ir ed

2 Ver y lively, som ewhat r espons ive, but not at peak

3 OK, som ewhat f r esh 6 Ext r em ely t ir ed, ver y dif f icult t o concent r at e

4 A lit t le t ir ed, less t han f r esh 7 Com plet ely exhaust ed

Please m ar k t he line below wit h an ‘ X’ at t he point t hat indicat es how you f elt

aler t - - - - - - - - - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -- - -- -- - -dr owsy

WHY DI D I T HAPPEN?

Fat igue pr ior t o dut y? Yes / No How long had you been awake when t he

Hot el Yes / No event happened? hr s m ins

Hom e Yes / No How m uch s leep did you have in t he 24 hr s

Dut y it self Yes / No bef or e t he event ? hr s m ins

I n- f light r est Yes / No How m uch s leep did you have in t he 72 hr s

Disr upt Yes / No bef or e t he event ? hr s m ins

Per sonal Yes / No f light deck nap? Yes / No I f yes , when

st ar t end

Ot her com m ent s

WHAT DI D YOU DO? Act ions t aken t o m anage or r educe f at igue ( f or exam ple, f light deck nap)

WHAT COULD BE DONE? Suggest ed cor r ect ive act ions

40

1 = extremely alert

c2

3 = alert

4

5 = neither sleepy nor

alert

6

7 = sleepy, but no

difficulty remaining

awake

8

9 = extremely sleepy,

fighting sleep

Data Collection Devices

Data Analysis

Data Analysis� Analysis and interpretation

• Scientists

• SME

� Application

• Operator

Note: Ask scientists about science, not operations

Applying the Findings

� Build into pairings.

� Build into rosters.

� Build into day-to-day crew scheduling.

� On-Board Sleep facilities.

� Training

• Management.

• Flight Crew.

• Support Staff.

FRM Processes

� What they do:

• Identify where fatigue is a hazard;

• Assess the level of risk that given fatigue hazard

represents;

• If necessary, put in place controls and mitigation

strategies, and monitor to make sure that they manage the risk at an acceptable level

DAY FLT DEPARTS ARRIVES BLK M/U TURN M 60 EQP ACT/MAX

10 D 920 ATL 1440 LGA.1705 2.25 932 2.25DHD

JFK 0.00/Layover 0.00B

2.25TL 11 16 JFK 2050 BOM.2150 15.30 0.15 * 7102

BOM 48.26/Layover 15.30B 15.45TL

15 17 BOM 0020 JFK.0650 16.00 0.04 *

EWR 22.13/Layover 16.00B 16.00TL

16 D1749 EWR 0552 ATL.0803 2.11 0.03 3735 2.11DHD

0.00B

� Is there existing science / experience / literature?

� Does anyone already do something similar?

� Answer : Yes

• Flight Safety Foundation ULR Working Group

• NASA studies

• Singapore Airlines

• SIN-LAX

o Safety Case

o Validation

� What do we already know from our own experience?

JFK-BOMB777-200ER

16+ hours block time

10.5 hour time zone shift

Evening departure

Maximum capabilities of aircraft

No crew base for aircraft

Sequence of Events� Commercial

• City Pair/Time/Aircraft

� Ops/Safety

• Can we conduct this flight at an acceptable level of risk?

� Ops/Scientists/Commercial

• What are the available mitigations?

� Ops

• Formulate a plan using available resources to conduct the flight

� Ops/Safety/Scientists

• Review the plan

FRMS Implementation (the real truth!)

� There is no ‘off-the-shelf’ version of an FRMS that will suit all operators;

� An FRMS needs to be developed, understood and managed by people who have comprehensive experience in the complex operational environment to which it will apply;

� A fully functioning FRMS doesn’t happen overnight;

� Implementation is necessarily accomplished in phases;

Ops Conference 55 16-18 April 2012, Rio de Janeiro

Phased Implementation

Bio-mathematical Models� Used for:

• Pairing/Roster Comparisons

• New Routes

• Evaluation of Mitigations

• Incident Investigation

• Complaint Resolution

• Evaluation of New Regulations

� Not Used for:

• Firm Go/No Go Decisions

The Circadian Component

� The circadian component of alertness follows a sinusoidal trend

� The peak in the late afternoon (1700-1800)

� The trough is in the morning (0500-0600)

copyright frms int l td.

0 2 4 6 8 10 12 14 16 18 20 22 24

Time of day (h)

Alertness

The Alertness Component

� Alertness is low immediately

after waking

• Effect of sleep inertia

� It increases to a peak 2-4

hours after waking

� Thereafter it decreases

exponentially

copyright frms int l td.

0

6

12

18

24

30

36

42

48

54

60

0 2 4 6 8 10 12 14 16 18

Time since sleep (h)

Alertness

Examples

copyright frms int l td.

Examples

Current State� 5 models commercially available

• BAM

• CAS

• FAID

• SAFE

• SAFTE/FAST

� 3 models public domain (maybe more)

� 1 model produced by an operator.

� More coming….

Current State� No International Standards.

� No International Validation Process.

� Experience with Most has Been Outside of Aviation.

Model Challenges� Straight Science vs. Reality

� Which Model is the Best?

� Over Reliance by Stakeholders

� User Education

� Accuracy of Predictions-Limited Data

� Validation

� Accounting for Crew Mitigations

� Additional Constraint During Optimization

IATA Activities

� IATA, ICAO, IFALPA FRMS Seminars:

• All Stakeholders invited and encouraged to

attend;

- Regulators;

- Airlines;

- Pilot Associations;

- Etc..

• Deliver a consistent message with a

collective voice.

IATA FRMS TASK FORCE� Provide assistance and guidance to Industry with FRMS

implementation;

� Collaborate with Regulators;

Opportunities� Standardization;

� Safety Performance Measures;

� Acceptance and use of credible Scientific Principles / Data;

� Identification of Models / “Experts”;

� Common Data Reporting;

� Training ~ including CBT training for front line employees (regulatory

requirement);

� Inclusion of fatigue management provisions into IOSA;

Opportunities – CBT Training

� CBT Training under development

• Flight Crew

• Cabin Crew

• Maintenance

• Dispatch / Ops Control

• Crew Scheduling / Crew Planning

Opportunities - IOSA� FRMS concept introduced as

Guidance Material in ISM Edition 6 effective by September 2012.

• Applicable to Flight and Cabin Crew items:

- FLT 3.4.3

- CAB 3.1.4

Summary� Overall an FRMS may offer a way to more safely conduct flights by

offering flexibility that may not be available within regulatory limits;

� An FRMS complements prescriptive flight time, duty, and rest

requirements;

� Improves operational efficiency;

� Provides for a performance-based regulatory approach that is

“tailored” to an operator’s specific operation;

José Alexandre.T.G. FregnaniAssistant Director – Safety & Flight Operations

IATA Brazil

fregnanij@iata.org

Tel: +55 11 2187 4236

“Represent, lead and serve the industry.”