Late this summer, the International Civil Aviation Organisation organised a “Fatigue Risk Management System” (FRMS) Symposium, followed by a FRMS Forum, in Montreal. Attended by over 500 participants – including safety experts from ECA – this important event demonstrated that prescriptive rules are a necessary basis, but not sufficient to manage fatigue. Compliance with the rules does not mean an operation is safe. Instead, fatigue needs to be managed proactively and FRMS is an important additional tool in that respect. However, the event also showed that FRMS is still a young new concept which will take time to work as intended.
Only if operators, crews and the national Authorities are fully committed to managing fatigue in a responsible and cooperative way, and only if they put in the necessary resources – including for effective oversight by the Authorities – will FRMS show the way for the future.
It is therefore encouraging that two FRMS guides were presented: one for helping national Authorities to understand, approve and control FRMS, and a second one for the operators. The latter is the result of a partnership between ICAO, IFALPA (International Federation of Air Line Pilots’ Association) and IATA (International Air Transport Association), and should become the industry’s reference document. Because, if operators consider FRMS simply as an easy way out of the prescriptive rules – rather than using it to provide for an equivalent or even higher level of safety – FRMS could undermine safety levels rather than increasing them.
The good news is that almost everywhere fatigue risks are now addressed as a safety issue that needs to be taken seriously. All three co-authors of the Operators’ Guide – ICAO, IFALPA, IATA – recognize that fatigue is a contributing factor in airplane accidents. And some Authorities, like the US FAA are keen to be proactive. In the US legislation FRMS will remain optional, but a detailed ‘Fatigue Risk Management Plan’ is mandatory for air carriers (part 121). This is a significant move: Fatigue has to be managed proactively through a plan within each airline. Non-compliance with that plan will ultimately lead to the airline facing civil penalties.
In Europe, however, the approach looks different. Based on the presentation made by the European Aviation Safety Agency (EASA) Europe seems to be one step behind the international community. EASA seems to start from the premise that prescriptive rules are «safe enough». Hence, Fatigue Risk Management (FRM) will not be mandatory. It will only be “required to those using certain special provisions or derogating from the prescriptive rules” e.g. in cases of reduced rest, certain flight duty extensions, certain night operations and East-West or West-East transitions.
FRMS is a safety net that has to be added in the whole safety organization, as stated by Dr Curt Graeber, leader of the ICAO FRMS Task Force. So, why should Europe choose to rely mainly on prescriptive rules compliance? – As EASA’s rules are not yet finalized, it remains to be seen whether the Agency will eventually embrace a more proactive approach.
To conclude with Dr Graeber: “FRMS represents a paradigm shift in managing fatigue as a safety risk, and offers a major opportunity to improve aviation safety worldwide”. Something the ‘old Europe’ still needs to get ready for.
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